2026 Canadian Trade & Customs Outlook: Forced Labour

Why It Matters

Stagnant enforcement and pending legislation expose Canadian importers to heightened compliance risk and potential trade friction with the United States.

Key Takeaways

• CBSA detained 50 shipments; one confirmed forced labour
• Bill C-251 seeks rebuttable presumption for forced‑labour imports
• Supply Chains Act reports due May 31 2026, template available
• CORE remains unfunded and without permanent leadership
• USMCA review may pressure Canada to tighten enforcement

Pulse Analysis

Canada’s forced‑labour framework has long been a patchwork of prohibitions and limited enforcement. Since the 2020 import ban, the Canada Border Services Agency (CBSA) has publicly detained only a single shipment conclusively linked to forced labour, despite 50 detentions overall. This enforcement gap, coupled with a stalled Canadian Ombudsperson for Responsible Enterprise (CORE), leaves businesses navigating ambiguous liability while the government’s 2024 ambition for robust due‑diligence legislation remains unrealized.

Legislative momentum is now centered on Bill C-251, a private‑member proposal that would embed a rebuttable presumption into the Customs Act, mirroring the U.S. Uyghur Forced Labour Prevention Act. If enacted, importers would bear the evidentiary burden to prove goods are free of forced or child labour, triggering mandatory detentions for non‑compliant shipments. The upcoming USMCA/CUSMA review in July 2026 adds a geopolitical dimension, as U.S. lawmakers have already signaled intent to tighten the agreement’s forced‑labour provisions, potentially compelling Canada to align its standards.

For companies operating in or through Canada, proactive steps are essential. The Supply Chains Act now requires multi‑jurisdictional reporting by May 31 2026, with a new template designed to streamline disclosures across Canada, the UK, and Australia. Conducting mock customs audits, integrating forced‑labour risk assessments into broader sanctions compliance, and monitoring Bill C‑251’s progress will help mitigate exposure. As enforcement remains soft but political pressure builds, firms that embed rigorous due‑diligence now will be better positioned for any regulatory tightening ahead.