Made in Canada or Product of Canada: Which Label Can You Use?

There are two Canadian origin labels, and they are not interchangeable. One needs 98% of your total direct costs to be Canadian. The other needs 51% and a line of small print most businesses leave off.

Here is the difference, and how to work out which one your product qualifies for.

The short answer

Both come from the Competition Bureau's guidance on origin claims. Both apply to non-food products. Food is a separate system, and there is a section on that below.

What "Product of Canada" requires

Two conditions.

The last substantial transformation has to happen in Canada. That means the step that turned your inputs into the finished product, not the packing or the labelling.

And at least 98% of the total direct costs of producing the product have to be incurred in Canada. The Bureau describes this as "all or virtually all".

That 98% is a high bar on purpose. Almost anything with imported components will miss it. A cabinet built in Canada from Canadian lumber with imported screws and hinges may well fall short once you count the hardware. If you are not confident you clear 98%, you are looking at the other label.

What "Made in Canada" requires

Three conditions, and the third is the one that trips people up.

The last substantial transformation has to happen in Canada, same as above.

At least 51% of the total direct costs of producing the product have to be incurred in Canada.

And the claim has to carry a qualifying statement about the imported content. The Bureau's own examples are "Made in Canada with imported parts" or "Made in Canada with domestic and imported parts". You can also be specific, as in "Made in Canada with 60% Canadian content and 40% imported content".

The qualifying statement most businesses forget

This is the part worth reading twice.

A bare "Made in Canada" with nothing after it does not meet the guidance. The qualifying statement is not a nice extra. It is one of the three conditions.

The bare version is easy to spot once you know to look for it, on tags, on shelf talkers, on packaging. Most of it is not deliberate. People know their product is made here, they say so, and nobody ever told them there was a second half to the sentence.

If you are printing new tags or ordering new packaging, this is the moment to fix it. Adding six words costs nothing at the design stage and is expensive to fix after a print run.

What counts as total direct costs

Total direct costs are the costs tied directly to producing the product. Materials and production labour are the bulk of it.

This is where most of the judgement sits, and where the arithmetic gets genuinely difficult. A maker who buys imported raw material but does all the work in Canada may clear 51% on labour alone. A business that imports a nearly finished item and does the last few steps here almost certainly will not.

If your split is anywhere near the line, work it out properly on real figures rather than on a feel for it, and get advice on your specific product.

Food is different

If you sell food, none of the above is your rule.

Food origin claims run under the Canadian Food Inspection Agency, and the tests are different. A lot of what comes up when you search this question is written about food, which is why so many people selling candles or furniture end up with the wrong answer. Check the CFIA guidance instead.

Three worked examples

A candle maker in Ontario. Wax and fragrance oils are imported. The pouring, curing, finishing and labelling all happen in her studio, and the jars and wicks are bought in Canada. Pouring and curing in the studio is the kind of step the transformation test looks at. Whether she clears 51% depends on what the imported wax costs against her labour and her Canadian-bought components, and many small makers clear it on labour alone. If she does, the claim would read "Made in Canada with imported materials". Product of Canada is out of reach either way, because the imported wax alone exceeds 2% of her costs.

A furniture builder in British Columbia. Solid wood is milled locally, the drawer slides and hinges come from overseas. Building the piece here is what the transformation test looks at. Whether the hardware is a small enough share to clear 51% is a numbers question on his own costs. If it clears, the qualifying statement still applies, because the hardware is still imported content. Product of Canada is a different matter, since it needs the imported share under 2% of total direct costs, which imported slides and hinges will rarely allow.

An apparel brand cutting and sewing in Toronto. Fabric is milled in Portugal, everything else happens in the studio. Cutting and sewing is a substantial transformation. Fabric is usually the single largest cost in a garment, so 51% is a real question and needs the actual numbers. If it clears, the label reads "Made in Canada with imported fabric". If it does not, the honest options are to say where it was designed and sewn without claiming origin, or to change the supply chain.

None of these are rulings. They are the shape of the question you need to answer for your own product.

Getting it wrong

Origin claims are covered by the general provisions of the Competition Act on misleading representations. A claim that is not supported is a problem whether or not anyone meant it that way.

There is a commercial risk alongside the regulatory one. Shoppers who care about origin are the ones who read the label properly. A claim that does not hold up is worse for trust than no claim at all.

Putting it on the product

Once you know which claim applies, the label is the easy part.

We carry both designs as bilingual peel-and-stick labels, 1,000 to a roll for $10.90. That is just over a cent a sticker. They go on hang tags, boxes, bags, or the shelf edge, and they save you reprinting packaging to make the point.

Made in Canada
Bilingual, 1,000 per roll, $10.90
View the label

Product of Canada
Bilingual, 1,000 per roll, $10.90
View the label

Browse both designs

If you are labelling a lot of stock at once, a tagging gun makes short work of it. And if you sell at markets and fairs, the display range for markets and pop-ups is worth a look while you are here.

Not sure which roll size you need, or how the labels sit on a particular surface? Call the order desk at 1-877-433-3437.

Questions we get asked

Can I say Made in Canada if I assemble here from imported parts?

Possibly. You need the last substantial transformation to happen in Canada, at least 51% of total direct costs incurred here, and a qualifying statement such as "Made in Canada with imported parts".

What is the difference between Made in Canada and Product of Canada?

Product of Canada needs at least 98% of total direct costs incurred in Canada and carries no qualifying statement. Made in Canada needs at least 51% and must carry a qualifying statement about imported content. Both need the last substantial transformation to happen in Canada.

Do I really need the qualifying statement?

Yes. Under the Bureau's guidance it is one of the three conditions for a Made in Canada claim, not an optional addition.

Does any of this apply to food?

Not these thresholds. Food origin claims run under CFIA guidance and the tests are different. General rules against misleading claims still apply.

Where can I get Made in Canada stickers?

We carry both designs, bilingual, 1,000 per roll at $10.90. See the links above.

This is general information, not legal advice. The source is the Competition Bureau's guidance on "Product of Canada" and "Made in Canada" claims. For a decision on your specific product, talk to a lawyer.