Labelling Canadian: Origin Claims and Compliance Under CFIA Rules

Since the wide-ranging introduction of U.S. tariffs on Canadian goods in March 2025, Canadian consumers have made efforts to buy locally made or Canadian products, including food. The removal of the de minimis exemption at the end of August 2025, which had allowed for goods valued under US$800 to cross the border duty-free, created additional challenges for trade between the two countries. These measures have fuelled national pride and a desire to support the Canadian industry, creating an opportunity for businesses to highlight Canadian-made products. However, to do so, they must comply with federal food labelling requirements.

As discussed in our March 2025 Blakes Bulletin: Maple-Washing: Regulatory and Civil Liability Risks of Calling a Product Canadian, making false or misleading claims on packaging or advertising can expose businesses to legal risk. In September 2025, two Montréal law firms launched a class action against several major grocery chains for selling food from the U.S. and other countries but labelled as “Canadian” on public signage.

In this bulletin, we address food producers who manufacture in Canada and provide an overview of labelling requirements and best practices. Given the scope and pace of recent tariff changes, it is more important than ever for businesses to accurately represent their products. Compliance with labelling regulations not only mitigates legal risk but also builds consumer trust in these challenging times.

Using Origin Claims

The use of claims to designate that a food is manufactured in Canada, with or without Canadian ingredients, is primarily enforced by the Canada Food Inspection Agency (CFIA). CFIA guidelines explain how it will evaluate country-of-origin related claims under the Food and Drugs Act and the Safe Food for Canadians Act, both of which prohibit false and misleading claims.

Unlike other labelling requirements that will be discussed below, these claims are voluntary. While they are not the only way to indicate that a product is made locally or with local ingredients, when used correctly, they can be powerful marketing tools for businesses seeking to benefit from consumers’ growing preference for Canadian-made products. The claims can be broken down as follows:

• “Product of Canada” / “Canadian”: Where businesses want to claim that their offerings are a “Product of Canada”, CFIA guidelines require that all or virtually all of the ingredients, processing and labour must be Canadian. In practice, less than 2% of the ingredients can be sourced from outside of the country. The CFIA applies this same standard to products labelled as “Canadian”. By contrast, products labelled as “100% Canadian” must be entirely made in Canada, from ingredients to processing and labour. Certain types of food, such as meat, fish and dairy, are subject to specific requirements to be labelled as a “Product of Canada.”
• “Made in Canada”: Products identified as “Made in Canada” must have undergone their last substantial transformation in Canada. Notably, “Made in Canada” claims must always be accompanied by a qualifying statement clarifying the origin of the ingredients, such as “Made in Canada with domestic and imported ingredients.” Even products made in Canada that contain no domestically produced ingredients can be labelled as “Made in Canada from imported ingredients” where the last substantial transformation occurs in Canada.
• “Local”: For food products to be considered “local”, the CFIA guidelines state that these must either be sold in the same province where they are produced, or within 50 kilometres if sold across provincial borders.
• Use of the Maple Leaf: Use of the stylized maple leaf from the National Flag of Canada (the 11-point maple leaf) may only be done with the permission of the Department of Canadian Heritage. The use of maple leaves other than the 11-point maple leaf is permitted on food packaging; however, depending on the context, this may be construed as a “Product of Canada” claim, and producers should be careful not to inadvertently mislead consumers.
• Other Claims: More specific claims that describe the Canadian value added may be used, such as “packaged in Canada” or “brewed in Canada,” where the above claims cannot be made.

Other Labelling Requirements

Beyond the rules regarding optional Canadian origin claims, packaged foods sold in Canada must comply with a range of labelling requirements to be sold to Canadian consumers. With respect to location information, businesses should be aware of the following:

• Certain imported ingredients, including dairy, fruit, eggs and meat, must be labelled with “product of” information
• All prepackaged food labels must display the name and place of business of the company responsible for the food in Canada
• Where a food is manufactured outside of Canada and imported into the country, this must be clearly indicated either by:
  • Explicitly stating that the product is imported
  • Stating the country of origin
  • Providing the name and address of a manufacturer located outside of Canada

These requirements address certain key origin-related rules and obligations for businesses selling food products to Canadian consumers.

For more information on the topic of packaging and labelling food, please contact the author or any member of our Food, Beverage & Agribusiness group.