Canadian Food Inspection Agency's 2024 to 2025 report on Fighting against forced labour and child labour in supply chains

ISSN: 2818-2642

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Purpose of the report

On January 1, 2024, the Fighting Against Forced Labour and Child Labour in Supply Chains Act (hereafter referred to as the act) came into effect.

The act represents a pivotal step forward in Canada's commitment to eradicate forced labour and child labour from Canadian supply chains, and advance concrete action to uphold human rights and international labour standards.

Entities and government institutions doing business in Canada have a responsibility to ensure that exploitative practices are addressed and eradicated from their supply chains. This means making sure that goods produced by forced labour or child labour do not enter Canada, and Canadian companies operating around the world observe responsible business practices.

Under the act, certain entities and government institutions are required to assess and mitigate the risk of forced labour and child labour in their supply chains, implement transparent reporting mechanisms, and demonstrate compliance through annual disclosure.

The act requires these entities and government institutions to submit a report to the Minister of Public Safety by May 31 of each year detailing the steps taken during the previous fiscal year to prevent and reduce the risk that forced labour or child labour is used by them or in their supply chains. This report covers the activities that took place within the period April 1, 2024 to March 31, 2025.

Canadian Food Inspection Agency

The Canadian Food Inspection Agency (CFIA) is a science-based regulator of food safety and the health of plants and animals. The agency is mandated to:

  • implement the requirements of Canada's food safety system to enhance people's health and well-being
  • protect Canada's plant and animal resources from pests and diseases
  • facilitate market access of food, plants, animals and related products at home and abroad to support the economy

In 2024 to 2025, dedicated CFIA employees worked to safeguard Canada's food system and vital plant and animal resources on which we depend, while contributing to the Canadian economy through the trade of Canadian goods. The CFIA is also actively working to support Government of Canada priorities including climate change, reconciliation and accessibility, among others.

Structure, activities and supply chains

The Minister of Health is responsible for the CFIA. Led by its President, employees work across Canada - in the National Capital Region and four domestic operational areas (Atlantic, Quebec, Ontario and Western), as well as abroad.

The CFIA uses a centralized approach to procurement. Under this model, strategic direction and advice on procurement and contracting, and the functional authority to enter into contracts, is consolidated under one branch. Centralized procurement enhances transparency and compliance by implementing standardized procedures and oversight mechanisms, thereby reducing risks and ensuring adherence to regulatory requirements.

The CFIA purchases goods, services and construction to support and advance its mandate. The main types of goods and services purchased in 2024 to 2025 include scientific goods and services, construction services, information technology goods and professional services.

The CFIA employs the following mechanisms and tools to purchase goods:

  • utilizes the CFIA's delegated authority up to $25,000
  • utilizes the Public Services and Procurement Canada (PSPC) and Shared Services Canada (SSC) standing offers and supply arrangements
  • engages PSPC or SSC to purchase goods on behalf of the CFIA under their delegated authority
  • utilizes the CFIA's emergency authority to purchase goods in response to a threat to Canada's food safety, animal, or plant health

Steps to prevent and reduce the risk of forced labour or child labour

In 2024 to 2025, the CFIA delivered on all items outlined in its action plan to prevent and reduce the risk of forced labour and child labour in its supply chains. Activities were focused on agency-wide education and awareness, internal and external engagement and collaboration, as well as assessing the risk of its supply chains.

As part of these efforts, the CFIA continued to integrate PSPC's standard contract clauses into its contracts, including PSPC's Code of Conduct for Procurement and anti-forced labour clauses. The code requires vendors to comply with all applicable laws and regulations, including Canada's prohibition of imported goods which have been produced using forced labour or child labour, regardless of their country of origin. In addition, the CFIA proactively mitigated the risks of forced labour and child labour by leveraging existing PSPC standing offers and supply arrangements which already include anti-forced labour contract clauses.

In February 2025, the CFIA participated in the International Contracting Officers Forum discussing effective actions that governments can take to prevent and address forced labour in public procurement and private sector supply chains.

Finally, the CFIA updated its action plan to incorporate new activities based on the progress made in 2024 to 2025.

Policies and due diligence processes

In August 2024, the CFIA updated its Procurement Management Framework to incorporate its commitment to combating forced labour and child labour, ensuring these issues are addressed as part of the agency's priorities, and reinforcing the CFIA's responsibility to promote ethical procurement practices.

Activities and supply chains that carry a risk

In May 2021, a risk analysis of PSPC's supply chains was completed by Rights Lab of the University of Nottingham (U.K.) to determine which goods were at the highest risk of exposure to human trafficking, forced labour, and child labour. The analysis and subsequent report outlined key strategies for PSPC to leverage public spending power in order to raise awareness about forced labour in supply chains.

PSPC took note of the findings and recommendations in this risk analysis, and is pursuing related follow-on actions, including the implementation of the Policy on Ethical Procurement, and the development of a human rights due diligence framework.

In 2024 to 2025, the CFIA leveraged the Risk Analysis of Human Trafficking, Forced Labour, and Child Labour in PSPC's Procurement Supply Chains report to assess the goods it procured during the 2023 to 2024 fiscal year, identifying activities and supply chains at risk of involving forced or child labour.

The findings of the risk assessment suggest that the CFIA's overall risk exposure to forced labour or child labour in its supply chains is low, with only 1.63% of in-scope procurements made from the identified high-risk commodity categories. The largest portion of high-risk procurement occurred in Office Supplies and Devices (1.52%), followed by smaller percentages in Clothing, Individual Equipment, and Insignia, and Alarm, Signal, and Security Systems (0.07% and 0.04% respectively).

While the analysis indicates a low risk, the CFIA recognizes the need to continuously monitor procurement activities for any changes in risk, ensuring that corrective measures can be applied proactively.

Measures taken to remediate any forced labour or child labour

The CFIA has not taken measures to remediate forced labour or child labour cases or support victims as none have been discovered. The agency will continue to monitor the risk within its supply chain and implement strategies to support victims affected by these issues as needed.

Measures taken to remediate the loss of income

The CFIA has not taken measures to remediate the loss of income to the most vulnerable families as none have been discovered.

Training provided to employees

The CFIA updated its mandatory authority delegation training for individuals responsible for contracting and purchasing decisions. The revised training includes a dedicated component on awareness of forced labour and child labour in supply chains. Additionally, an internal resource knowledge and support page was created and shared with the agency at large via an information bulletin to raise awareness of the issue.

In addition to these training initiatives, the CFIA is aware that PSPC has developed and is currently piloting a course for procurement officers on ethical procurement. The CFIA will leverage the course upon its publication for use across the Government of Canada.

Assessment of effectiveness

The CFIA does not currently have a defined approach in place to assess its effectiveness in ensuring that forced labour and child labour are not being used in its activities and supply chains. Given that the CFIA's activities are considered to be low risk, no measurable indicators have been implemented to date. The agency's current strategy focuses on monitoring and raising awareness, with the intention of taking further action if and when it becomes necessary.

Closing remark

In 2024 to 2025, the CFIA advanced its efforts to prevent and mitigate the risk of forced labour or child labour in the production of goods purchased. These efforts included conducting a risk assessment, raising awareness and providing education across the agency, updating its procurement management framework, continuing to utilize PSPC tools that include language supporting the prevention and reduction of forced labour and child labour, and engaging in both internal and external collaboration. The CFIA remains dedicated to improving its practices and making meaningful contributions to Canada's goals of promoting transparency, accountability, and social sustainability within its supply chains.

Key definitions

For key definitions refer to Section 2 of the Fighting Against Forced Labour and Child Labour in Supply Chains Act.

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