# Risk Assessment & Heat Mapping

How official Canadian and international materials describe risk identification, prioritization, and the link between risk mapping and defensible supply-chain controls.

## What It Means to Identify Risk Under the Act

Public Safety Canada treats risk identification as a transparency exercise about potential exposure, not an admission that forced labour has been proven in a given supply chain.

Public Safety Canada's guidance is explicit that identifying a risk in activities or supply chains does not mean saying forced labour or child labour is actually being used. The point of the disclosure exercise is to show that the entity has examined how its activities, suppliers, goods, geographies, and business relationships could contribute to risk, and what steps it has taken in response.

The 2025 annual report to Parliament gives a useful picture of how reporting organizations are currently describing risk. It records that many entities are identifying risks tied to raw materials or commodities, sectors and industries, direct suppliers, and locations of operations or factories. That is valuable benchmarking for heat-map design because it shows what the regulator is seeing as the common anatomy of a risk analysis in the second reporting cycle.

The OECD Due Diligence Guidance adds the method that the Act itself does not spell out in detail. It supports proportionate, risk-based prioritization by severity and likelihood, and it expects the assessment to connect to prevention, mitigation, tracking, communication, and remediation. A useful heat map therefore should not end at a coloured score. It should lead into concrete control choices and review intervals.

### Citations

- PSC Guidance: Public Safety Canada, Guidance for entities (https://www.publicsafety.gc.ca/cnt/cntrng-crm/frcd-lbr-cndn-spply-chns/prpr-rprt-en.aspx)
- 2025 Parliament Report: Public Safety Canada, 2025 Annual Report to Parliament on the Fighting Against Forced Labour and Child Labour in Supply Chains Act (https://www.publicsafety.gc.ca/cnt/rsrcs/pblctns/2025-frcd-lbr-chld-lbr-spply-chns-ct-scnd-rprt/index-en.aspx)
- OECD DDG 2018: OECD, Due Diligence Guidance for Responsible Business Conduct (2018) (https://www.oecd.org/en/publications/2018/02/oecd-due-diligence-guidance-for-responsible-business-conduct_c669bd57.html)

## Border Risk, Commodity Risk, and High-Risk Supply Chains

Risk mapping should reflect the legal reality that Canada bars imports made wholly or in part by forced labour and that trade-law commitments reinforce that prohibition.

Article 23.6 of CUSMA commits each Party to prohibit the importation of goods produced in whole or in part by forced or compulsory labour, including forced or compulsory child labour. Canada implemented that commitment through the forced-labour import prohibition reflected in tariff item 9897.00.00 and described in CBSA Memorandum D9-1-6.

The CBSA memorandum states plainly that goods mined, manufactured, or produced wholly or in part by forced labour are prohibited from entering Canada and that importers are responsible for conducting due diligence on their supply chains. That means risk mapping is not only a transparency exercise for annual reporting. It is also relevant to import compliance, detention risk, and downstream commercial disruption.

A legally grounded heat map should therefore flag not just broad geography or sector but also border-touching nodes: imported finished goods, imported components, high-risk commodities, and suppliers that are several tiers away but still materially connected to goods entering Canada. Public Safety Canada's guidance supports this by encouraging entities to explain how risks were identified and what sources or methods were used, including supply-chain mapping, questionnaires, audits, and stakeholder engagement.

### Citations

- CUSMA Art 23.6: Canada-United States-Mexico Agreement, Article 23.6 (Forced or Compulsory Labor) (https://www.international.gc.ca/trade-commerce/trade-agreements-accords-commerciaux/agr-acc/cusma-aceum/text-texte/23.aspx?lang=eng)
- CBSA D9-1-6: CBSA Memorandum D9-1-6, Goods manufactured or produced by prison or forced labour (https://www.cbsa-asfc.gc.ca/publications/dm-md/d9/d9-1-6-eng.html)
- PSC Guidance: Public Safety Canada, Guidance for entities (https://www.publicsafety.gc.ca/cnt/cntrng-crm/frcd-lbr-cndn-spply-chns/prpr-rprt-en.aspx)