Canada’s Bill C-13, known as the Child Labour Denial Amendment, took effect in February 2023 and represents a critical step in the nation’s efforts to eliminate child labor from imported supply chains. The legislation prohibits the importation of goods that are mined, manufactured, or produced wholly or in part by child labor. With increasing scrutiny from both regulators and consumers, Canadian retailers, importers, and brand owners must act decisively to align their supply chain practices with the law’s requirements. Beyond compliance, proactive measures offer a means to build consumer trust and demonstrate leadership in ethical sourcing.
Under Bill C-13, the onus is on Canadian importers to exercise due diligence in verifying that their goods are free of child labor at all stages of production. Enforcement is administered by the Canada Border Services Agency (CBSA), which has the authority to detain, seize, or refuse entry to goods suspected of violating the law. Retailers and importers therefore need robust systems to assess, document, and demonstrate their efforts to mitigate child labor risks across their supply networks. Failure to do so not only exposes companies to regulatory penalties but also to significant reputational harm.
A vital first step for Canadian retailers is to make use of the International Labour Organization’s (ILO) open database of child labor risks. The ILO provides comprehensive, country-specific and sector-specific data on the prevalence of child labor, covering industries such as textiles, agriculture, mining, and manufacturing. Retailers should consult this database during supplier onboarding and periodically thereafter to identify high-risk jurisdictions and commodity chains. Integrating this risk intelligence into supplier selection criteria allows companies to prioritize sourcing from low-risk regions or require enhanced documentation from suppliers operating in higher-risk environments.
Retailers should build a structured due diligence process that uses the ILO’s database as a baseline for supplier risk assessments. This process should require suppliers to provide documentary evidence demonstrating the absence of child labor in their operations and those of their subcontractors. Evidence can include audit reports from accredited third-party verifiers, participation in recognized industry certification schemes, and alignment with international labor standards. Retailers should maintain a centralized repository of this documentation and update it regularly to ensure its relevance and accuracy.
In addition to external data checks, Bill C-13 compliance can be strengthened by integrating supplier self-certifications directly into point-of-sale and inventory management systems. Canadian retailers should require suppliers to submit signed declarations confirming that their goods were produced without the use of child labor. These declarations should be linked to purchase orders and product SKUs within enterprise resource planning (ERP) or point-of-sale (POS) systems. By embedding compliance data at the product level, retailers can improve internal oversight and create an auditable trail that demonstrates due diligence to CBSA inspectors or other authorities.
To operationalize this integration, retailers should design standard supplier self-certification templates aligned with the language and intent of Bill C-13. These templates should clearly state that the supplier affirms no child labor was used at any stage of production and that supporting records are available upon request. Retailers can provide these templates in digital formats, allowing suppliers to complete and submit them through secure online portals. Once received, the self-certifications should be validated against existing supplier profiles and stored alongside transactional records in the retailer’s ERP or POS systems. This approach not only streamlines compliance but also enables traceability from the supplier declaration to the final sale.
Furthermore, Canadian retailers should establish internal controls for periodic review of supplier certifications and risk profiles. High-risk suppliers should be subject to enhanced monitoring, which could include unannounced factory visits, independent social audits, or participation in multi-stakeholder initiatives focused on eradicating child labor. Where possible, retailers should collaborate with peers, NGOs, and government agencies to share intelligence on supply chain risks and promote industry-wide improvements. Transparent reporting of these efforts in corporate responsibility disclosures can further reinforce a retailer’s commitment to ethical trade.
Bill C-13 also presents an opportunity for Canadian retailers to leverage technology to improve compliance and transparency. Blockchain-based traceability systems, for example, can provide immutable records linking raw materials, intermediate goods, and finished products to verified sources. Retailers might also explore the use of mobile applications that enable workers to report grievances anonymously or flag potential labor abuses in real time. While such technologies are still emerging, early adoption could help retailers stay ahead of regulatory requirements and consumer expectations.
Canada’s Child Labour Denial Amendment signals a clear mandate for retailers to take responsibility for conditions throughout their supply chains. The combination of data-driven risk assessments, rigorous supplier declarations, integration with core business systems, and a commitment to continuous improvement will be essential for meeting both the letter and the spirit of the law. By investing in these practices, Canadian retailers can not only ensure compliance but also contribute to global efforts to eliminate child labor and promote decent work for all.