Above Ground submitted comments to the Public consultation on regulatory approach under Bill C-35, An Act respecting the prohibition of the importation of goods produced by forced labour, led by Global Affairs Canada.
Our comments provide detailed recommendations on how Canada should develop its “list of goods” suspected to be made with forced labour and enforce the prohibition in a manner that is transparent, credible, and centred on workers’ interests and perspectives. This includes ensuring that enforcement of the ban extends beyond the list of goods.
We also urge the government to acknowledge the limitations of import bans and to pursue the far more consequential path of adopting mandatory human rights and environmental due diligence legislation.
These comments complement a separate submission prepared for Employment and Social Development Canada’s Public consultation on potential due diligence and civil liability measures to fight labour exploitation in supply chains.