TRUMP PLAYS HARDBALL WITH CANADA
NEW 50% US TARIFFS DIRECTLY LINKED TO CANADA'S SUPPLY MANAGEMENT POLICIES?
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On July 20, 2026, President Donald Trump invoked a Great Depression-era trade statute to announce 50% tariffs on a wide array of Canadian exports. The sweeping orders rely on Section 338 of the Tariff Act of 1930 (“Section 338”, codified at 19 U.S. Code § 1338) and specifically target Canadian dairy, alcohol, and automobiles.
BILL C-251 AND MODERN SLAVERY
CANADA'S PROPOSED PRESUMPTION AGAINST FORCED-LABOUR IMPORTS
Bill C-251 (An Act to amend the Customs Act and the Customs Tariff) was introduced in October 2025. If enacted, it would establish a statutory presumption that goods originating from designated countries are made in whole or in part by forced or child labour and are therefore prohibited from importation into Canada.
The Bill would also impose due diligence obligations on importers, who would be required to demonstrate to the Canada Border Services Agency (“CBSA”) that they have performed effective due diligence on their supply chain. Given the potential impact of this Bill, all importers should closely monitor developments as the bill moves through Parliament.
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