Guidance on Made in Canada and Product of Canada Claims for Consumer Products

In light of the interest from many customers in supporting Canadian products, RCC is aware that many retailers are taking steps to identify food products that are made partially or wholly in Canada. Please note that these claims are subject to verification by the Canadian Food Inspection Agency (in the case of food products) and the Competition Bureau (for non-food products). See below for informational guidance below on how “Made in Canada” or “Product of Canada” claims can be applied.

This information does not denote legal advice and we encourage all retail businesses to consult with legal counsel and with CFIA and the Competition Bureau, as appropriate.

Food Products

The guidelines for “Product of Canada” and “Made in Canada” claims are administered by the Canadian Food Inspection Agency (CFIA) and promote compliance with subsection 5(1) of the Food and Drugs Act and subsection 6(1) of the Safe Food for Canadians Act, which prohibit false and misleading claims.

The use of “Product of Canada” and “Made in Canada” claims is voluntary. However, once a company chooses to make one of these claims, the product to which it is applied should meet these guidelines.

Guidance for these claims apply to foods sold at all levels of trade, including bulk sale or wholesale foods for further processing. They also apply to claims made in advertising (including signage) and by restaurants.

Made in Canada

A “Made in Canada” claim can be used on a food product when the last substantial transformation of the product occurred in Canada. A substantial transformation occurs when a food product undergoes processing that changes it to the point that it becomes a new, different food product. For example, the processing of cheese, dough, sauce and other ingredients to create a pizza would be considered a substantial transformation.

If Made in Canada is printed on the label, the claim must be qualified where applicable to indicate that it is manufactured in Canada from imported ingredients or a combination of imported and domestic ingredients.

Product of Canada

A food product may use the claim “Product of Canada” when all or virtually all major ingredients, processing, and labour used to make the food product are Canadian. This means that all the significant ingredients in a food product are Canadian in origin and that non-Canadian material is negligible.

The following circumstances would not disqualify a food from making a “Product of Canada” claim:

• very low levels of ingredients that are not generally produced in Canada, including spices, food additives, vitamins, minerals, flavouring preparations, or grown in Canada such as oranges, cane sugar and coffee. Generally, the percentage referred to as very little or minor is considered to be less than a total of 2% of the product;
• packaging materials that are sourced from outside Canada, as these guidelines apply to the Canadian content and production or manufacturing of the food product and not the packaging itself;
• the use of imported agricultural inputs such as seed, fertilizers, animal feed, and medications.

Local claims

CFIA has also adopted a policy which recognizes “local” food as:

• food produced in the province or territory in which it is sold, or
• food sold across provincial borders within 50 km of the originating province or territory

It is important to note that claims such as “local” are voluntary and industry is encouraged to add qualifiers, such as the name of a city, to provide consumers with additional information.

For both Made in Canada and Product of Canada claims, while there is no specific documentation required, a company should be able to provide evidence that a product meets the criteria set out in the guidelines on Product of Canada and Made in Canada claims if such claims are used in labelling or advertising. For more information on other domestic content claims (e.g. Roasted in Canada, Canned in Canada), multiple country of origin claims, and commodity specific information for meat and poultry, fish and seafood, and dairy and eggs, please see CFIA’s Origin Claims on Food Labels guidance.

Non-Food Products

Country of origin claims on consumer products other than food as detailed above are governed by the Competition Bureau under the Competition Act, the Consumer Packaging and Labelling Act and the Textile Labelling Act (the Acts). As with food products, while businesses are not required to place country of origin labelling on their product, any claims they do choose to make must not be false or misleading. 

Product of Canada

In order to be confident in representing a non-food product as a “Product of Canada”,  two conditions must be met:

1. the last substantial transformation of the good occurred in Canada; and
2. all or virtually all (at least 98%) of the total direct costs of producing or manufacturing the good have been incurred in Canada.

Made in Canada

In order to be confident in representing a non-food product as a “Made in Canada”,  three conditions must be met:

3. the last substantial transformation of the good occurred in Canada;
4. at least 51% of the total direct costs of producing or manufacturing the good have been incurred in Canada; and
5. the “Made in Canada” representation is accompanied by an appropriate qualifying statement, such as “Made in Canada with imported parts” or “Made in Canada with domestic and imported parts”. This could also include more specific information such as “Made in Canada with 60% Canadian content and 40% imported content”.

For questions or more information contact

Avery Bruenjes
Director, Regulatory Affairs
abruenjes@retailcouncil.org