Forced Labor in Canadian Supply Chains Reporting Obligations 

The Government of Canada's Fighting Against Forced Labor and Child Labor in Supply Chains Act (the Supply Chains Act) came into force on January 1, 2024. The Act is intended to increase transparency and promote responsible business practices by addressing the risk of forced labor and child labor in global supply chains connected to the Canadian market. Certain entities and government institutions are required to submit an annual report to the Minister of Public Safety, describing steps taken during their previous financial year to prevent and reduce the risk of forced labor and child labor in their activities and supply chains. 

Who Must Submit a Report

An entity must submit a report if it is listed on a Canadian stock exchange, or has a place of business, conducts business, or holds assets in Canada, and meets at least two of the following criteria in at least one of its two most recent financial years:

• $20 million or more in assets;
• $40 million or more in revenue; and 
• An average of 250 or more employees 

Entities meeting these criteria are required to report only if they produce goods in Canada or elsewhere, import goods into Canada, or control another entity that produces or imports goods.

Reporting Requirements 

Reports must be submitted to Public Safety Canada by May 31 and made publicly available by:

• Posting the report in a prominent location on the entity's website; and 
• Including it in Public Safety Canada's online catalogue.

Information submitted may be subject to review or verification by Public Safety Canada.

What Does This Mean for You?

• Determine whether your organization qualifies as a reporting entity under the Act.
• Review internal policies, procedures, and supply chain risk controls related to forced labor and child labor.
• Be prepared to request and collect information or documentation from suppliers -- including exporters to Canada that are not Canadian entities -- to support your reporting and due diligence obligations. 

For additional guidance, please visit Crane's Trade Advisory Notices or contact the Crane Global Trade Compliance Team at globaltradecompliance@craneww.com.