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Canada Forced Labour and Child Labour Act For Supply Chain

Canada’s Forced Labour and Child Labour Act came into effect on January 1, 2024, and the responsibility to file a report on your supply chain is due on May 31st, 2024. The act is designed to remove or severely limit products of slave or child labour from the Canadian market.

Forced labour can be found in every country and every sector. The International Labour Organization estimates that there are approximately 27.6 million victims of forced labour worldwide, including 17.3 million in the private economy. Forced labour and child labour risks occur primarily through the global supply chains of businesses. There is a risk that goods imported into and distributed in Canada were produced with forced labour or child labour. Entities and government institutions doing business in Canada have a responsibility to ensure that exploitative practices are addressed and eradicated from their supply chains.

The measures introduced through former Bill S-211, An Act to enact the Fighting Against Forced Labour and Child Labour in Supply Chains Act and to amend the Customs Tariff (the Act), aim to increase industry awareness and transparency and drive businesses to improve practices.

What does this mean for you?

Certain importers, exporters, and businesses that meet the criteria set out in the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Act) must satisfy the reporting requirements.

What businesses are subject to the Act? Those who are:

  • “Producing, selling or distributing goods in Canada or elsewhere
  • Importing into Canada goods produced outside Canada, or
  • Controlling an entity engaged in either of the above activities”

The Act defines an entity as:

  • Is listed on a stock exchange in Canada
  • Has a place of business in Canada, does business in Canada or has assets in Canada and, based on its consolidated financial statements for the last two financial years, has met at least two of the following three conditions:
    • Had at least $ 20 million Canadian in assets
    • Generated at least $ 40 million Canadian in revenue
    • Employed an average of at least 250 employees, or
  • Is prescribed by regulations (no “other’ regulations have been made public)”

Source: Government of Canada | Public Safety Canada

NOTE: All details pertaining to CARM R2 processes are based on the current information available at the time of writing. As this is subject to change, it’s recommended you periodically check in with the CBSA or your customs broker.