Proposed legislation will push health and safety leaders to examine supply chains well beyond their own worksites
A new federal bill introduced in June 2026 is set to significantly expand the compliance obligations of Canadian employers, and health and safety leaders may be among those most affected.
Bill C-35, the Ban on Importing Goods Made with Forced Labour Act, received its first reading in the House of Commons on June 12, 2026. If passed, the legislation would give the Minister of Foreign Affairs the authority to ban goods produced wholly or in part by forced labour from entering Canada, building on the country's existing forced labour import framework enforced by the Canada Border Services Agency (CBSA).
Lavanga Wijekoon, a shareholder and attorney at Littler Mendelson, a global labour and employment law firm, says the bill represents a meaningful escalation of Canada's existing commitments.
"This is an enhancement by the Canadian government of its existing forced labor import ban," he told Canadian Occupational Safety.
What the bill would do
Wijekoon outlined five core elements of Bill C-35. The Minister of Foreign Affairs can establish a list of high-risk goods. Importers of listed goods would face enhanced supply chain tracing requirements. The government would gain authority to deem certain goods prohibited following investigation. The bill creates stronger coordination mechanisms among federal authorities. And it introduces a cost recovery model, making importers liable for enforcement costs when forced labour is identified.
"That is the element that I would say is of the most concern to our clients," Wijekoon said of the enhanced tracing requirements.
The bill is currently at an early stage. Public consultations with stakeholders are still forthcoming, and the final version may change. No timeline has been set for when the high-risk goods list will be published. Canada's majority government, however, makes passage of some version of the bill likely.
The pace of Canada's response is also being shaped by pressure from the United States. The U.S. Trade Representative investigated countries it deemed insufficiently committed to forced labour import bans and threatened additional tariffs on Canada, which was announced on June 2.
"Canada is one of the few countries that actually has an importation ban," Wijekoon noted. "But the issue that the U.S. Trade Representative has is that there's not enough implementation of it."
How Bill S-211 prepared the ground
Bill C-35 does not arrive in a vacuum. Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act, known as Bill S-211 (S-211), came into force in January 2024. That transparency law requires covered entities to disclose what steps they are taking to identify and address forced and child labour risks in their supply chains.
Wijekoon says S-211 compliance has positioned many companies reasonably well heading into C-35's requirements.
"A lot of companies, as a result of S211… have been forced to relook at their supply chains and forced to relook at their human rights due diligence practices," he said. "I think a lot of Canadian companies are probably in a better place to comply with the forced labor ban as a result of efforts that they've made to comply with S211."
What health and safety leaders need to do now
For occupational health and safety (OHS) professionals, Wijekoon's message is direct: take stock of your organisation's current sourcing practices before the legislation is finalised.
"They need to take stock of a particular entity's current practices with regards to how they are sourcing goods, how they are tracing those goods," he said. "For many companies, this is a huge challenge because if you have multi-level supply chains that are all over the world, you may not have visibility, nor might you have the revenue and the resources to track the many levels of your suppliers all the way down to the raw materials."
Practical steps include reviewing supplier codes of conduct, examining supply contracts for compliance guardrails, and engaging procurement teams and subsidiaries to assess current status. Wijekoon recommends involving legal counsel versant in both hard and soft laws, and soliciting input from EU-based clients, who are further along on human rights due diligence requirements. Safety leaders in sectors such as construction, manufacturing and energy, where complex subcontracting structures have already drawn scrutiny for forced labour risks in Canadian workplaces, face particular exposure.
"It's sort of a multi-pronged approach that involves multiple stakeholders to kind of do an audit of what your current practices are, figure out where the gaps are, and then figure out what to do in terms of filling those gaps," he said.
Looking beyond Canada, the European Union's forced labour ban carries penalties effective December 2027, alongside existing national due diligence laws in Germany and France. Combined with Canadian and U.S. frameworks, the cumulative effect will be far-reaching.
"All of those interacting together are going to have a serious impact on just trade in general," Wijekoon said. "It could change quite a lot of the global supply chains and which countries companies can continue to go to in terms of sourcing their materials."
For Canadian safety leaders whose roles are increasingly spanning both occupational health and ESG responsibilities, Wijekoon's advice is to move early.
