Bill C-251 Customs Act Forced Child Labour
C-251 An Act to Amend the Customs Act and the Customs Tariff (Forced Labour and Child Labour)
Bill Type: Private Member’s Bill
Bill Sponsor: Simon-Pierre Savard-Tremblay (Saint-Hyacinthe—Bagot—Acton)
The presumption mechanism is the key: goods from designated countries or listed entities are assumed to be forced/child labour products unless the importer proves otherwise. Burden of proof flips to the importer.
Status: Introduced — October 21, 2025. This Bill hasn't passed yet.
How would YOU vote? Scroll down to vote and comment below.
WHO GAINS POWER
- Customs officers gain authority to detain goods from designated countries or listed entities until satisfied they are not prohibited imports
- The Governor in Council gains power to designate countries and areas as subjects of concern by order
- The Minister of Public Safety gains power to list, amend and remove entities from the forced labour list
- Canadian workers and consumers gain stronger import controls against goods produced by forced or child labour
WHO LOSES POWER
- Importers lose the presumption of innocence — goods from designated areas are assumed prohibited until proven otherwise
- Foreign governments and entities lose automatic market access to Canada if designated
- Parliament loses direct oversight — designations and listings are made by order of the Governor in Council, not by vote
WHO GAINS MONEY
- Canadian manufacturers competing against cheaper forced-labour imports gain a more level playing field
- Supply chain auditing and certification firms gain new mandatory business
WHO LOSES MONEY
- Importers face new compliance costs — supply chain tracing, certification, due diligence documentation
- Businesses sourcing from designated countries face potential detention of goods and supply chain disruption
- No cost estimate provided for customs enforcement capacity required to implement detention obligations
THE CATCH
- ⚠️ Definitions borrowed from other Acts — "forced labour," "child labour" and "entity" are defined by reference to the Fighting Against Forced Labour and Child Labour in Supply Chains Act (1) and the Special Economic Measures Act (2). Changes to those Acts automatically change the scope of this Bill without a vote
- ⚠️ Designation is by Governor in Council order, not Parliament — a country or entity can be added to or removed from the list without a parliamentary vote. The Minister recommends, Cabinet decides
- ⚠️ "Prescribed" appears throughout but regulations are not yet written — supply chain tracing requirements, certification procedures, due diligence standards and information requirements are all left to future regulation. The Bill creates the framework; the rules come later
- ⚠️ Rebuttable presumption places burden on importers — goods are guilty until proven innocent. Small importers with limited compliance capacity face a higher barrier than large corporations with dedicated legal teams
- ⚠️ Five-year review cycle for listed entities — an entity confirmed to use forced labour stays listed for up to five years before mandatory review. No mechanism for faster removal if circumstances change
- ⚠️ No appeal mechanism specified — the Bill does not provide importers with a clear path to challenge a designation or detention decision
Source: Bill C-251, House of Commons of Canada
(1) Fighting Against Forced Labour and Child Labour in Supply Chains Act
https://laws-lois.justice.gc.ca/eng/acts/F-10.6/
(2) Special Economic Measures Act
