International Trade Committee on June 18th, 2026

[Robert Brookfield]

I think you probably will have experts, or Parliament will have experts who would be better placed to provide a more neutral assessment. However, that is certainly the intent.

[Peter Fonseca, Liberal, Mississauga East—Cooksville, ON]

Canada would have one of the most comprehensive forced labour frameworks in the world.

[Robert Brookfield]

That's the intent.

[Peter Fonseca, Liberal, Mississauga East—Cooksville, ON]

Would you also agree that Bill C-35 shifts Canada's approach from proving forced labour after the fact to preventing suspect goods from entering Canada in the first place?

[Graeme Hamilton]

Obviously, I think that, when you look at Canada's overall forced labour regime, there is that dual intent. In many ways, the forced labour import ban is the backstop or the last line of defence against the importation of those goods. That needs to work co-operatively with the supply chains act, incentivizing Canadian businesses to understand their supply chains and to make alternative purchasing decisions in order to eliminate those goods from even coming into Canada. I think that together those two items work to provide a very comprehensive regime.

I'm sorry, but I missed the last bit of your question. If I didn't respond to it, please let me know. I'm happy to elaborate.

[Peter Fonseca, Liberal, Mississauga East—Cooksville, ON]

Rather than proving forced labour after the fact, it's to prevent suspect goods from entering Canada in the first place. What are the steps that would change that, reverse that onus so that businesses would be able to provide the information? What information would you be looking for from businesses before that importation takes place?

[Graeme Hamilton]

There are two elements within Bill C-35 that facilitate that prevention element. One is the public list. Companies making purchasing decisions to import goods into Canada will know where there are risks, and they may choose to make purchases elsewhere. There will also be regulations that prescribe pieces of information that will need to be presented to the CBSA if they're importing goods off the list. That will require those purchasers and the importers to understand their supply chains and to really dig deep to understand where those products come from. Potentially, through that process they will proactively identify forced labour within their supply chain and make alternative purchasing decisions, and it will prevent those goods from being imported into Canada.

[Peter Fonseca, Liberal, Mississauga East—Cooksville, ON]

I understand there will be consultations over the summer as we go through Bill C-35. In terms of recommendations that have come from labour organizations, human rights groups and businesses that have called for these enforcement tools, have some of those been addressed within Bill C-35? Can you respond to that?

[Graeme Hamilton]

Yes. Broadly speaking, in 2023 and again in 2024, the government—once under Global Affairs, once combined with ESDC and CBSA—undertook public consultations around the forced labour frameworks. A number of the items that were identified through those consultations are reflected in the legislation that came forward, Bill C-35, primarily, the ability to produce a public list and provide transparency for importer obligations. I would say that the other piece that came up in 2023 was, obviously, the ability to do this prearrival, the ability for the government to work with importers to make sure that, for those goods, the determination is made in advance in order to smooth and facilitate, ultimately, the importation of those goods.

[Peter Fonseca, Liberal, Mississauga East—Cooksville, ON]

Thank you.

MP Acan, go ahead.

[Sima Acan, Liberal, Oakville West, ON]

Mr. Hamilton, the current framework relies on a risk-based approach using risk assessment and random selection to identify the shipments of goods that may have been produced by forced labour. With the introduction of Bill C-35, the agency would work from a targeted list of higher-risk products, with the onus on the importer to prove their goods are free of forced labour.

You explained very well the steps that you will be taking. Could you please also tell us how this targeted intelligence-led approach strengthens enforcement, as compared to the current method?

[Graeme Hamilton]

As we have learned to operationalize the current forced labour ban within the customs tariff, one challenge we've identified is that the application is done on a shipment-by-shipment basis. We need to identify a particular shipment at risk in order to be able to target it, as opposed to a much broader list. In fact, it's broader, but it's actually more targeted because it allows us to focus our enforcement efforts.

Through the elements in Bill C-35, we anticipate being able to better direct our officers' attention to very specific shipments coming in. Then, the information requirement elements within Bill C-35 will also mean that our officers will be able to make faster determinations because we will know that the importer will have to have the information available, which we will be able to review in making determinations around whether or not those goods were made with forced labour.

[Sima Acan, Liberal, Oakville West, ON]

Thank you very much.

[The Vice-Chair, Conservative, Adam Chambers]

Thank you very much.

For the last round, we have Mr. Kram, followed by Mr. Naqvi, and we'll have Mr. Bonin for two and a half minutes. That will conclude our meeting, and then we'll get to some of the motions.

Mr. Kram, go ahead.

[Michael Kram, Conservative, Regina—Wascana, SK]

Thank you, Mr. Chair.

I would like to circle back to the witnesses about the Chinese EV imports. Just a couple of weeks ago, in an article with the headline “Chinese-made electric vehicles start arriving in Canada”, CBC reported, “Nearly 3,000 Chinese-manufactured EVs landed in the country last month.”

I'm told that's all based on data from Global Affairs Canada.

What guarantees do we have today that those 3,000 Chinese EVs that arrived two months ago were not made with forced or child labour?

[Sara Wilshaw]

All I can say is that the existing forced labour import ban applies to all products, and that is currently the mechanism being used to prevent goods that are made with forced labour from coming into the country. In the customs tariff, that is the existing mechanism by which goods coming into the country would be assessed.

[Michael Kram, Conservative, Regina—Wascana, SK]

If the U.S. Department of Labor has found that many automobiles, electric vehicles and auto parts made in China are used with forced and child labour, can you give us some insight into the enforcement mechanism? Do we have inspectors who go to China to look at the assembly lines? How does that work?

[Sara Wilshaw]

I would defer to my colleagues about how the enforcement is currently done.

[Graeme Hamilton]

In some ways, you're stumbling onto some of the challenges we have identified through the use of the customs tariff. Because it's on a shipment-by-shipment basis, broad-based reporting around high risks of use of forced labour in general industries would not necessarily allow us to have a successful detention at the border. The burden of proof is that the particular car that is in front of you has a particular chassis which was made from aluminum that was produced using forced labour. Therefore, because it's shipment by shipment, it becomes a very challenging level to get to. Then, for the next shipment of cars, we'd have to re-prove that the exact same supply chain is in place in order to determine that they were made with forced labour. It becomes inherently difficult, on a shipment-by-shipment basis, under the customs tariff, which, I think, is one thing that Bill C-35's intent aims to address.

[Michael Kram, Conservative, Regina—Wascana, SK]

Okay, so we can anticipate that automobile parts and EVs from these regions of China probably should be included in the list in Bill C-35. Is that a fair statement?

[Graeme Hamilton]

I wouldn't want to speculate in terms of what will make the list, but I can say that, in terms of the targets that we currently have ongoing, automobile parts, textiles and seafood are some of the commodities that are in there, so it would not surprise me that automobile parts would be in there, whether or not they're specifically linked to a region. I wouldn't want to presuppose what ultimately makes it onto the list though.

[Michael Kram, Conservative, Regina—Wascana, SK]

Okay, but if we are, let's suspend disbelief for a minute and assume that the U.S. Department of Labor study is correct and that these parts and these imports do have to be stopped. We're going to stop these Chinese EVs as soon as Bill C-35 is up and running and in force then.

What does that look like, and what does that mean with the canola tariffs that the Chinese recently lifted?

[Sara Wilshaw]

I think we just have to go back to what we've said, which is that we can't presuppose what's on the list at the moment, nor can we anticipate the reaction of any trading partner to their position on the list if that is named at this point. It's too early to say.

[Michael Kram, Conservative, Regina—Wascana, SK]

Would you say that it's more than a little bit irresponsible for the government to have let in these 3,000 EVs from China without the ability to ensure at every step of the way that the supply chains do not have forced labour or child labour?

[Sara Wilshaw]

I'm not sure who's best placed to answer that question.

I don't think any of us would want to presume where the government has been in terms of this. We have a ban on imports made with forced labour. My colleagues have described the challenges with the enforcement of that, but there is a total ban on goods made with forced labour at this moment.