🟡 45th Parliament, 1st Session — No upcoming sitting dates scheduled
C-251 Trade

C-251 (45-1) - An Act to amend the Customs Act and the Customs Tariff (forced labour and child labour)

Chamber

commons

Stage

1st Reading

Introduced

Oct 21, 2025

Progress

This bill bans imports from countries or companies suspected of using forced or child labour, unless importers prove otherwise.

Key Changes

  • Customs officers must detain goods from designated countries or listed entities until they confirm the goods are not prohibited imports
  • Creates a legal presumption that goods from designated areas or listed entities were made using forced or child labour
  • Importers can rebut the presumption by demonstrating supply chain monitoring, due diligence, and providing required certifications
  • The Governor in Council can designate countries or areas as 'subjects of concern' based on a recommendation from the Minister of Public Safety
  • The Governor in Council can list specific companies or entities believed to use forced or child labour
  • Listed entities must be reviewed every five years to determine if they should remain on the list

Gotchas

  • The presumption of prohibited import is rebuttable, meaning importers bear the burden of proving their goods are clean rather than the government proving wrongdoing — this is a significant shift in how trade enforcement typically works
  • The criteria for designating a country or listing an entity require only 'reasonable grounds to believe,' a relatively low legal threshold
  • Regulations governing supply chain tracing, certifications, due diligence standards, and information requirements have not yet been defined in the bill — they will be set later by the Governor in Council, leaving key details unspecified
  • The five-year review cycle for listed entities means a company could remain on the list for up to five years before a mandatory reassessment, even if circumstances change
  • The bill relies on definitions from two other existing laws — the Fighting Against Forced Labour and Child Labour in Supply Chains Act and the Special Economic Measures Act — meaning changes to those laws could affect how this bill operates

Who's Affected

  • Canadian importers who source goods from countries or companies flagged for forced or child labour
  • Customs officers responsible for inspecting and detaining goods at the border
  • Foreign manufacturers and suppliers in designated countries or listed entities
  • Canadian businesses that rely on global supply chains
  • Workers in countries where forced or child labour is a concern

Summary

Bill C-251 changes two existing laws — the Customs Act and the Customs Tariff — to crack down on goods made using forced labour or child labour entering Canada. It creates a system where the government can designate certain countries, regions, or specific companies as 'subjects of concern' if there are reasonable grounds to believe they use forced or child labour. Goods from those places or entities would automatically be presumed to be prohibited imports unless the importer can prove otherwise. Customs officers would be required to detain goods from designated countries or listed entities until they are satisfied the goods were not made using forced or child labour. Importers can challenge this presumption by showing they tracked their supply chain, took required steps to manage risks, provided required certifications, and exercised due diligence to ensure their goods are clean. The bill was introduced by MP Simon-Pierre Savard-Tremblay and builds on Canada's existing Fighting Against Forced Labour and Child Labour in Supply Chains Act. It aims to strengthen enforcement at the border by shifting the burden of proof onto importers rather than requiring the government to prove wrongdoing before stopping a shipment.

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