Forced labour compliance in Canada is undergoing its most significant transformation in years. Bill C-35 and the dissolution of the Canadian Ombudsperson for Responsible Enterprise (CORE) are reshaping what Canadian textile retailers must do to stay compliant.
The changes signal a decisive break from voluntary, report-and-tick frameworks. For B2B textile businesses sourcing globally, the stakes have never been higher.
Bill C-35: What Changes for Canadian Retailers
Canada's new forced labour legislation raises the bar well beyond earlier disclosure requirements. Bill C-35 pushes compliance from reporting toward active due diligence and supply chain verification.
Textile retailers and importers must now demonstrate that their sourcing practices actively identify and address forced labour risks. Passive reporting is no longer sufficient to meet regulatory expectations.
- Mandatory supply chain due diligence — not just annual disclosure
- Greater scrutiny applied to high-risk sourcing regions
- Stronger penalties for non-compliant importers
- Alignment with international trade partner requirements
The Quiet Demise of CORE and Its Industry Impact
The Canadian Ombudsperson for Responsible Enterprise (CORE) was established in 2019 to investigate human rights complaints against Canadian companies operating abroad. Despite its mandate, CORE's limited enforcement powers drew sustained criticism from civil society groups and trade partners alike.
Its dissolution marks a strategic pivot in Canadian policy. Rather than maintaining an independent watchdog, the government is embedding compliance obligations directly into trade law. Companies can no longer rely on a CORE review process as a buffer against regulatory scrutiny.
For textile brands and retailers, accountability now moves inward. Your compliance systems must be robust enough to withstand direct statutory examination.
U.S. Pressure: USTR and the UFLPA Shadow
Canada's legislative shift does not occur in isolation. The U.S. Trade Representative (USTR) has made forced labour supply chain enforcement a top trade priority, and the Uyghur Forced Labor Prevention Act (UFLPA) has proven that import bans based on origin presumptions are both enforceable and consequential.
Canadian retailers sourcing from or exporting alongside U.S. markets now face a dual compliance burden. Goods that cannot withstand UFLPA scrutiny face U.S. Customs and Border Protection detention regardless of Canadian regulatory status.
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Frequently Asked Questions
What is Bill C-35 and how does it affect textile importers?
Bill C-35 updates Canada's forced labour framework to require active supply chain due diligence rather than voluntary disclosure. Textile importers must demonstrate they are actively identifying and mitigating forced labour risks across their entire supply chains.
Why was CORE dissolved and what replaces it?
CORE was criticised for lacking meaningful enforcement authority. Its dissolution shifts accountability directly into trade legislation — companies must now build internal compliance systems that meet statutory requirements, with no independent watchdog review available as a fallback.
How does the U.S. UFLPA affect Canadian textile retailers?
The UFLPA creates a rebuttable presumption that goods from certain high-risk regions are made with forced labour. Canadian retailers sourcing from these regions face potential U.S. import detention, making UFLPA compliance essential even for businesses that primarily operate within Canada.
Canada's forced labour regulatory overhaul demands a fundamental upgrade to supply chain compliance practices. Textile businesses that treat due diligence as a core operational function — rather than a reporting checkbox — will be best positioned to navigate the evolving international trade environment.
