Supply Chain Due Diligence & Forced Labour
Practitioner submissions to two Government of Canada consultations, August 2026
About These Submissions
TransPacific Trade Nexus (TPTN) submitted practitioner input on August 12, 2026 to two separate Government of Canada consultations addressing supply-chain due diligence and forced-labour import enforcement.
The first submission responds to Employment and Social Development Canada’s consultation on potential supply-chain due diligence and civil liability measures. The second responds to the consultation led by Global Affairs Canada and the Canada Border Services Agency on the regulatory approach under Bill C-35 and Canada’s prohibition on the importation of goods produced by forced labour.
The two processes serve different legal purposes and retain distinct legal tests. The submissions are presented together here because they raise overlapping implementation questions concerning evidence, provenance, interoperability, SME burden, auditability and institutional authority.
Public record note: The two submissions below were transmitted on August 12, 2026 to the Government of Canada departments identified with each entry and are published here in their submitted form for transparency and public reference.
Publication on this page does not imply endorsement, acceptance, adoption, pilot authorization, procurement interest, funding commitment, or any other commitment by the Government of Canada or by the departments and agencies named. Acknowledgement of receipt, where applicable, should not be read as evaluation, adoption or endorsement of the submission’s content.
August 12, 2026
Practitioner Submission
Potential Supply Chain Due Diligence Measures: Evidence Reuse, Regulatory Coherence, and Proportionate Digital Implementation
Submitted to Employment and Social Development Canada, Labour Program
The submission responds to the Government of Canada’s consultation on potential supply-chain due diligence and civil liability measures intended to address labour exploitation in supply chains.
It focuses on the implementation architecture required for a potential due diligence regime, particularly evidence reuse, provenance, interoperability, proportionality and the indirect compliance burden that can fall on smaller suppliers. It advances the principle that common underlying evidence can be reused where legally authorized without collapsing distinct statutory obligations into one another.
August 12, 2026
Practitioner Submission
Regulatory Approach under Bill C-35: Interoperable, Audit Ready Evidence for Effective Forced Labour Enforcement
Submitted to Global Affairs Canada and the Canada Border Services Agency
The submission responds to the Government of Canada’s consultation on the regulatory approach under Bill C-35 and Canada’s prohibition on the importation of goods produced by forced labour.
It focuses on the evidentiary and digital implementation requirements of effective forced-labour import enforcement, including provenance, attribution, amendment history, selective disclosure, interoperability, regulator-grade retrieval, and accountable human and institutional authority over consequential legal decisions. It makes clear that digital infrastructure can support stronger evidence but does not determine whether forced labour occurred or whether goods are legally admissible.
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