Federal government of Canada announces its intention to introduce new forced labour legislation

As noted in our previous update, the federal government’s 2023 budget has announced the federal government's intention to introduce new legislation by 2024 to eradicate forced labour from Canadian supply chains to strengthen the import ban on goods produced using forced labour, as well as to work to ensure existing legislation fits within the government's overall framework to safeguard our supply chains.

More recently, the office of federal Labour Minister, Seamus O'Regan, said the intent of the new legislation would be to create an impetus for firms and governments to act when they identify an instance of forced labour. Should the current federal government introduce a new bill aimed at combatting forced labour in supply chains, we anticipate that such bill may impose significant due diligence obligations, unlike Bill S-211, which is a transparency-based bill.

At the time of writing, Bill S-211, the Fighting Against Forced Labour and Child Labour in Supply Chains Act, continues to be at third reading in the House of Commons, having already completed third reading in the Senate. If Bill S-211 receives royal assent in 2023, Bill S-211 will come into force on January 1, 2024. However, given this new development, it is unclear whether Bill S-211 will now continue to proceed in the legislative process.