Canada has introduced new legislation aimed at strengthening its ban on goods made with forced labour. If passed, Bill C-35, the Ban on Importing Goods Made with Forced Labour Act, would create a standalone import control regime and give Canadian authorities stronger tools to stop goods linked to forced labour from entering the country.
The proposal is significant because it reflects a wider shift in modern slavery compliance. Governments are increasingly moving beyond annual transparency statements and asking whether businesses can actually identify, evidence and prevent forced labour risks in their operations and supply chains.
For businesses, the direction of travel is clear. Modern slavery compliance is no longer just about publishing a statement. It is becoming about traceability, due diligence, escalation, supplier oversight and being able to show what action was taken when a risk was identified.
What is Canada proposing?
Canada already has modern slavery reporting obligations under 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 and reduce the risk of forced labour and child labour in their supply chains.
The new proposal is different. Bill C-35 is focused on import controls. It would replace the current forced labour import prohibition under the Customs Tariff with a standalone legislative framework.
The proposed law would prohibit the importation of goods produced wholly or in part by forced labour. It would also allow the Minister of Foreign Affairs to establish a list of high-risk goods where there are reasonable grounds to suspect forced labour. Those goods could be identified by region, entity or individual.
Importers dealing with listed high-risk goods could be required to provide enhanced supply chain tracing information to the Canada Border Services Agency. If they fail to provide the required information, the goods could be deemed prohibited from importation.
The proposal would also improve information sharing between federal bodies and introduce a cost-recovery model where importers are found to have brought in goods made with forced labour.
In practical terms, this means importers may need a much clearer understanding of where goods are produced, who is involved at each stage of the supply chain, and what evidence exists to rule out forced labour risk.
Why this matters beyond Canada
Canada’s proposal is part of a broader international trend. Around the world, governments are asking whether existing modern slavery laws have done enough to change business behaviour.
The first generation of modern slavery laws focused heavily on transparency. Companies were required to publish statements explaining what they were doing to address modern slavery risks. That helped put the issue on corporate agendas, but transparency alone has often been criticised for allowing weak or generic reporting.
The next generation of laws is more interventionist. It focuses on whether goods linked to forced labour should be kept out of markets altogether. It also places more emphasis on due diligence, traceability and enforcement.
The EU Forced Labour Regulation is one of the clearest examples of this shift. It will prohibit products made with forced labour from being placed on the EU market, whether they are imported, produced domestically or exported. The rules are due to apply from December 2027.
The US has already taken a more enforcement-led approach through customs controls, including the Uyghur Forced Labor Prevention Act. Canada now appears to be moving in the same direction by strengthening the enforcement architecture behind its existing import ban.
The UK is also under pressure to move further
The UK’s Modern Slavery Act 2015 was once seen as a leading piece of legislation. Ten years on, the debate has moved on.
The Independent Anti-Slavery Commissioner has called for the UK framework to be strengthened through a draft Forced Labour and Human Rights Bill. The draft legislation would introduce mandatory human rights due diligence, a ban on goods produced with forced labour entering the UK market and a clearer enforcement framework.
That would mark a major change from the current approach under section 54 of the Modern Slavery Act, which is centred on transparency statements.
The case for reform is also being driven by the scale of the problem. Referrals into the UK’s National Referral Mechanism continue to rise, with 23,411 potential victims referred in 2025, a 22% increase on the previous year. Modern slavery risks are not confined to distant supply chains. They can also sit inside UK operations, labour providers, outsourced services, accommodation, payroll arrangements and recruitment practices.
For UK organisations, this means modern slavery compliance needs to be both local and global. It is not enough to check whether suppliers have a policy. Businesses need to understand how exploitation might appear in real commercial arrangements and whether staff know how to respond.
Brazil and New Zealand show the trend is spreading
The same direction of travel can be seen outside Europe and North America.
In Brazil, a committee in the Chamber of Deputies has approved a proposal to prohibit the importation and sale of goods made using proven child, forced or compulsory labour. The proposal would apply beyond its original focus on cocoa and extend to any product or raw material entering the Brazilian market. It also introduces the concept of labour due diligence, with importers potentially able to avoid penalties if they can show they had appropriate preventive and oversight processes in place.
The Brazilian proposal is still moving through the legislative process, but it is another example of governments looking at market access, not just corporate disclosure.
New Zealand is also taking steps to strengthen its modern slavery framework. Its Crimes Amendment Bill, introduced in late 2025, aims to close gaps in existing slavery and trafficking offences, including changes to child trafficking and penalties. A separate Modern Slavery Bill in 2026 has also proposed new reporting and progress-tracking requirements.
These reforms are not identical. Some focus on criminal offences. Some focus on corporate reporting. Others focus on import bans. But together they show that modern slavery legislation is becoming more active, more practical and more connected to enforcement.
Moving beyond annual transparency
The direction of modern slavery law is becoming clearer. Governments are no longer satisfied with broad statements that say a business is committed to preventing exploitation. They increasingly want evidence that businesses understand their risks and are taking practical steps to reduce them.
Canada’s proposed forced labour import ban is the latest sign of that shift. Alongside developments in the UK, Brazil, New Zealand, the EU and beyond, it shows that modern slavery compliance is moving into a new phase.
This means that businesses must move beyond simply having modern slavery statements and start demonstrating that their programmes are credible, risk-based and capable of identifying exploitation before it becomes embedded in the supply chain.
