Two phrases, one maple leaf: reading a Canadian origin label

By Ines Keane

Pick up almost anything this autumn and there is a decent chance it says something about Canada. A flag, a leaf, a phrase. People who want to buy Canadian have more reason than ever to read those marks closely, because the two best-known phrases are not interchangeable. “Product of Canada” and “Made in Canada” follow different rules, and a third kind of wording sits underneath both.

The thresholds below come from the Competition Bureau’s own Made in Canada claims page. The Bureau’s enforcement guidelines for non-food products were updated on 7 March 2025. We also read two law-firm summaries and an advertising trade body’s infographic, and where a point comes from one of those rather than from the Bureau, we say so.

Product of Canada

The Competition Bureau sets out the test for this phrase in two parts. At least 98 per cent of the total direct costs of producing or manufacturing the good must be incurred in Canada, and the last substantial transformation of the good must have happened in Canada. When both are met, the Bureau says, it will generally not challenge the claim.

Miller Thomson adds a point about wording. A product with foreign ingredients is not eligible, it says, even with a phrase like “Product of Canada and United States”.

Made in Canada

The bar is lower. The Bureau’s page says at least 51 per cent of the total direct costs must be incurred in Canada, and the last substantial transformation must again occur in Canada. The claim must also come with an appropriate qualifying statement. The Bureau’s examples are “Made in Canada with imported parts” and “Made in Canada with domestic and imported parts.”

So the two phrases differ in more than one number. The first is close to all-Canadian. The second allows a product that is mostly Canadian by cost but still has foreign content, and expects the label to say so.

Symbols count too

The Bureau says pictures count as claims. Symbols such as the Canadian flag or the maple leaf can carry the same weight as a written statement.

Food

The Bureau notes that the Canadian Food Inspection Agency has a mandate to enforce Canada’s food legislation, and that the Bureau’s guidelines do not address other statutory or regulatory requirements on country of origin. For a food product, check the CFIA’s own guidance.

Side by side

Product of CanadaMade in Canada
Direct costs in CanadaAt least 98 per centAt least 51 per cent
Last substantial transformationIn CanadaIn Canada
Qualifier neededNot among the Bureau’s conditionsYes, per the Bureau
Foreign ingredients or partsNot eligible, per Miller ThomsonAllowed, with a qualifier

The Ad Standards infographic, from the trade body that handles advertising self-regulation, gives no figures at all. It says only that the last substantial transformation must occur in Canada, and that where imported materials are present a disclaimer is required. That agrees with the Bureau’s page but says less.

What kind of sources these are

The Competition Bureau’s page is the enforcer’s own short account of its guidelines. The Bureau notes that it is not a regulator and that it does not approve or certify origin claims. Two law firms writing for clients supply the detail on food, wording and enforcement; both read as careful, but they are summaries. The advertising trade body is an industry group explaining a rule to advertisers.

Questions a buyer would ask

Which phrase is on the label, and is it followed by a qualifier? Where was the last big change made to the goods? If the label shows only a leaf or a flag and no words, what does the seller say it means? If the seller says “made here”, can they say what part? For food, which ingredients are not Canadian? These are plain questions, and an honest seller can answer them in one sentence.

What we left out

Penalty sums, specific brands or complaints, tariff and trade-policy questions, and any count of products that meet either threshold.

A label is a small piece of writing with a legal weight behind it. Read the words, then read the words around the words.

Roam first. Shop later.

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