Canada has introduced new federal legislation to strengthen the country’s ban on importing goods produced with forced labour. The proposed legislation, titled An Act respecting the prohibition of the importation of goods produced by forced labour (Bill C-35), was announced by Global Affairs Canada on June 12, 2026. If adopted, it would create a standalone framework to help prevent goods connected to forced labour from entering the Canadian market.

For businesses in Windsor-Essex, the announcement may be particularly relevant, given the region is closely tied to manufacturing, automotive supply chains, agriculture, logistics, warehousing, construction, retail, and cross-border trade. Many local businesses import goods, parts, materials, equipment, packaging, or finished products, either directly or through Canadian and international suppliers.

The proposed legislation does not mean every importer will face the same level of scrutiny. However, supply chain visibility, documentation, and import compliance may become increasingly important parts of doing business in Canada.

Canada’s Existing Forced Labour Import Ban

Canada has already had a forced labour import ban in place since 2020 under the Customs Tariff. That ban was introduced to meet Canada’s obligations under the Canada-United States-Mexico Agreement, commonly known as CUSMA. Under the current framework, goods produced wholly or in part by forced labour are prohibited from being imported into Canada.

The current ban is enforced at the border by the Canada Border Services Agency, with support from federal partners. According to the federal backgrounder, enforcement currently relies on a risk-based approach to identify shipments that may involve goods produced by forced labour.

Canada has also introduced supply chain transparency obligations through the Fighting Against Forced Labour and Child Labour in Supply Chains Act, which came into force in 2024. That legislation requires certain entities and federal institutions to report annually on steps taken to prevent or reduce the risk that forced labour or child labour was used in their supply chains.

What the Proposed Legislation Would Change

The newly proposed legislation would replace the current import prohibition under the Customs Tariff with a standalone legislative framework. The federal government has described the proposed Act as a way to strengthen Canada’s ability to identify, intercept, and prohibit goods linked to forced labour at the border.

A key feature of the proposed legislation is the creation of a list of high-risk goods. The Minister of Foreign Affairs would have authority to establish that list where there are reasonable grounds to suspect that goods are produced by forced labour. The list could identify high-risk goods by region, entity, or individual.

The proposed legislation would also create enhanced supply chain tracing requirements for importers of certain high-risk goods. If importers do not provide the required information, those goods could be deemed prohibited from importation. This deeming mechanism may become one of the most significant practical changes for businesses that import goods into Canada.

Potential Impacts on Windsor-Essex Businesses

Windsor-Essex is a major trade corridor. Businesses in the region often operate within complex supply chains that cross provincial, national, and international borders. Even companies that do not see themselves as “importers” may rely on imported materials, components, packaging, tools, equipment, electronics, textiles, or consumer goods.

The proposed legislation may affect more than large multinational companies. Small and mid-sized businesses may also need to consider how much they know about their suppliers, where goods originate, how materials are sourced, and what documentation is available if questions arise at the border.

For a Windsor manufacturer, this could involve parts or raw materials sourced through multiple tiers of suppliers. For a retailer, this could involve purchasing finished goods from distributors. For an agribusiness, food processor, contractor, or logistics company, it could involve equipment, packaging, machinery, or imported inputs used in ordinary operations.

The 90-Day Border Hold and Narrow Appeal

Beyond tracing, the bill equips the Canada Border Services Agency with sharper tools. Customs officers would have the explicit power to detain suspected shipments for up to 90 days (and possibly longer under future regulations) while they investigate whether forced labour was involved at any stage of production.

Further, unlike standard customs disputes, decisions made under the new Act will not be subject to standard administrative appeals or redeterminations under the Customs Act. If a local importer’s shipment is blocked, their only possible challenge is to file for judicial review in Federal Court (which can be significantly slower and more complex than other appeal options).

Supply Chain Visibility May Become More Important

One of the central themes in the federal announcement is supply chain tracing. The government has indicated that importers of certain high-risk goods may be required to provide enhanced supply chain information to customs authorities.

This may place greater emphasis on business records that show where goods came from, who supplied them, and what steps were taken to understand supply chain risks. Businesses may wish to review whether their existing contracts, purchase orders, supplier onboarding practices, and import records are detailed enough to respond to future inquiries.

In some cases, businesses may not have direct relationships with overseas producers. Instead, they may buy through brokers, distributors, wholesalers, or other intermediaries. That structure can make supply chain tracing more difficult. It can also create practical questions about who is responsible for obtaining information and what happens if a supplier is unable or unwilling to provide it.

Contract Terms Can Play a Bigger Role

As forced labour compliance becomes more closely connected to import risk, commercial contracts may become an important tool for managing supplier relationships. Businesses may consider whether their contracts address issues such as compliance with Canadian import laws, cooperation with information requests, record-keeping obligations, audit rights, and consequences if goods are detained or deemed prohibited.

Supplier representations may also become more relevant. For example, a purchaser may want contractual language confirming that goods are not produced using forced labour and that the supplier will provide reasonable documentation about sourcing if requested. The specific wording, scope, and practicality of those provisions may vary depending on the industry, bargaining power, and nature of the supply relationship.

Contracts may also need to address delay, substitution, cancellation, indemnity, and cost allocation. If goods are stopped at the border, businesses may face production delays, customer issues, storage costs, or lost revenue. Advance planning can help clarify which party bears the risk if a supply chain issue disrupts delivery.

Import Documentation and Record-Keeping

The proposed legislation is not only about whether goods are permitted into Canada. It is also about whether importers can provide the information required by customs authorities when goods are identified as high-risk.

That makes documentation an important business issue. Businesses may wish to consider how they store supplier records, certificates, invoices, shipping documents, origin information, purchase agreements, and communications about sourcing. If records are incomplete or scattered across departments, it may be harder to respond quickly to a request for information.

For businesses with cross-border operations, documentation practices may need to be coordinated among purchasing, compliance, customs brokers, logistics providers, finance teams, and management. Windsor-Essex businesses that rely on just-in-time delivery or cross-border production schedules may be especially sensitive to border delays.

The Connection to Supply Chain Reporting

Canada’s existing supply chain reporting law already requires certain entities to file annual reports about steps taken to prevent or reduce forced labour and child labour risks. This is intended to increase industry awareness and transparency and to encourage responsible business practices.

The proposed import legislation appears to build on that broader policy direction. The reporting law focuses on transparency. The proposed import framework focuses more directly on border enforcement, tracing, and the prohibition of high-risk goods where mandatory information requirements are not met.

Not every business is subject to the same reporting obligations. However, the broader direction is clear: Canadian businesses are increasingly expected to understand and document supply chain risk. Even companies that are not currently reporting entities may encounter these issues through customers, lenders, insurers, government procurement, supplier audits, or commercial contract requirements.

Considerations for Business Planning

The proposed legislation has not yet become law, and many details may depend on the final version of the Act and future regulations. However, businesses can still use the announcement as an opportunity to review current practices.

A business may begin by identifying which goods, components, or materials are imported into Canada, whether directly or indirectly. It may also consider which suppliers are essential to operations, which products would be difficult to replace, and whether alternative sources are available if a shipment is delayed or prohibited.

Businesses may also review supplier contracts, procurement policies, customs broker arrangements, and internal responsibility for import compliance. In some organizations, responsibility may be shared across multiple roles. Clear internal processes can help reduce confusion if information is requested quickly.

Questions About Forced Labour Import Rules? Contact Willis Business Law in Windsor-Essex County

For Windsor-Essex businesses involved in importing, manufacturing, distribution, automotive supply chains, agriculture, retail, construction, or cross-border trade, evolving forced labour import rules may raise important commercial and compliance considerations.

The modern business lawyers of Willis Business Law assist companies with supplier agreements, commercial contracts, import-related business planning, supply chain risk management, and cross-border business matters. Contact us online or call (519) 945-5470 to discuss how proposed federal forced labour import legislation may affect your contracts, operations, and business relationships.