Origin Claims

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Table of Contents

Overview

In some cases, a company may choose to voluntarily declare the country of origin of the food product on the label, in order to further assist consumers in their purchasing decisions. A company may also choose to apply an origin claim regarding their food product or an ingredient contained within their food product. Guidance on the use of these types of claims can be found below.

Multiple Country of Origin Statements

The use of a voluntary multi-country of origin statement (e.g. "Product of France and United States") is not acceptable. In this context, a product can only have one country of origin, which, at a minimum, is the country of last substantial transformation. All claims must be truthful and not misleading; declaring multiple countries of origin on the label may result in false information.

A blended claim, such as "A blend of [Naming the country] (naming the product) and [Naming the country] (naming the product)", may be considered (e.g. "A blend of Brazilian and American soybean oil").

Guidance on the use of a voluntary multi-country of origin statement that includes or makes reference to Canada can be found below in the Guidelines for Product of Canada and Made in Canada Claims.

Claims Regarding the Origin of Ingredients within a Food

A product may make a claim regarding the origin of ingredients within a food, provided the claim is truthful and not misleading (e.g. "Contains Italian olive oil") In addition to this claim, a company may choose to highlight the amount of an ingredient in the product (e.g. "10% Italian olive oil"). Further guidance on stressing or highlighting particular ingredients can be found in the Highlighted Ingredients Claims.

Guidance on the use of claims regarding the Canadian origin of ingredients within a food can be found below in the Guidelines for Product of Canada and Made in Canada Claims.

"Local" Claims

The Canadian Food Inspection Agency (CFIA) is adopting an interim policy on Local Food Claims which recognizes "local" 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

Guidelines for "Product of Canada" and "Made in Canada" Claims

The guidelines for "Product of Canada" and "Made in Canada" claims promote compliance with subsection 5.(1) of the Food and Drugs Act and subsection 7(1) of the Consumer Packaging and Labelling 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.

The guidelines for "Product of Canada" and "Made in Canada" 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 and by restaurants.

These guidelines do not apply to:

  • Products destined for export markets: These products must continue to meet the requirements of the importing country. This could result in different labels for domestic and exported products.
  • Other consumer goods such as animal feed, agricultural seed or plants that are not food products: These products may be assessed under the Competition Bureau's Guide to Made in Canada Claims.
  • Content claims regarding regional or provincial content, such provinces, cities, towns, etc.
  • Terms or references that have regulated requirements and are not subject to the guidelines (e.g. grade names, references to Canada Organic or mandatory country of origin labelling).

All ingredients and their components that contribute to the food, regardless of their generation when they were added, must be considered when assessing "Product of Canada" and "Made in Canada" claims.

"Product of Canada" Claims

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:

  1. 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 per cent of the product.
  2. 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.
  3. The use of imported agricultural inputs such as seed, fertilizers, animal feed, and medications.

For example, a cookie that is manufactured in Canada from oatmeal, enriched flour, butter, honey and milk from Canada, and imported vanilla, may use the claim "Product of Canada" even if the vitamins in the flour and the vanilla are not from Canada.

The claim "Canadian" is considered to be the same as a "Product of Canada" claim and any product carrying this claim must meet the criteria for a "Product of Canada" claim described above.

Generally, products that are exported and re-imported into Canada would not be able to make a "Product of Canada" claim.

The only exception would be if the product:

  • meets the "Product of Canada" criteria, and;
  • is ready for sale when it leaves Canada (fully packaged and labelled) and is subsequently returned to Canada without undergoing any processing, repackaging or re-labelling (e.g. perhaps because of an ordering error).

This is because all content, processing and labour still occurred in Canada.

"Made in Canada" Claims with a Qualifying Statement

A "Made in Canada" claim with a qualifying statement can be used on a food product when the last substantial transformation of the product occurred in Canada, even if some ingredients are from other countries. 

Substantial Transformation

A substantial transformation occurs when a food product undergoes processing which changes its nature and becomes a new product bearing a new name commonly understood by the consumer.

For example, the processing of cheese, dough, sauce and other ingredients to create a pizza would be considered a substantial transformation.

Processes which result in a substantial transformation may be outlined in more specific legislation, such as the Meat Inspection Regulations and Processed Products Regulations.

Qualifying Statement

If the "Made in Canada" claim is used, it must also include a qualifying statement to indicate that the food product is made in Canada from imported ingredients or a combination of imported and domestic ingredients. The qualifying statements that can be used include "Made in Canada from domestic and imported ingredients" or "Made in Canada from imported ingredients".

All variations of "Made in Canada" claims must include a qualifying statement.

For example, a claim such as "Proudly Made in Canada" would need a qualifying statement if the product contains imported ingredients as this claim includes the phrase "Made in Canada".

Made in Canada from imported ingredients

When a food is made with ingredients that are all sourced from outside of Canada, the label would state "Made in Canada from imported ingredients".

For example, a cookie manufactured in Canada from imported flour, oatmeal, shortening and sugar may be labelled or advertised with the claim "Made in Canada from imported ingredients".

Made in Canada from domestic and imported ingredients

When a food contains both domestic and imported ingredients, the label would state "Made in Canada from domestic and imported ingredients". This claim may be used on a product that contains a mixture of imported and domestic ingredients, regardless of the level of Canadian content in the product.

For example, a cookie manufactured in Canada using Canadian flour, oatmeal and shortening and imported sugar may be labelled or advertised with the claim "Made in Canada from domestic and imported ingredients".

To provide clarity and consistency for consumers, when a company chooses to use the Made in Canada claim, the qualifying statement should be presented in a standard format: "from domestic and imported ingredients". However, it would be considered acceptable if the order were reversed, if there were a higher proportion of imported ingredients than domestic ingredients.

The claim "Made in Canada from domestic and/or imported ingredients" is not permitted as it does not provide meaningful information to the consumer about the Canadian content.

Other Domestic Content Claims

The use of "Product of Canada" and the qualified "Made in Canada" claims are encouraged to ensure clarity for the consumer and to enhance their ability to identify Canadian made foods. However, other more specific statements or claims that describe the Canadian value added may be used without further qualification, provided they are truthful and not misleading for consumers.

Examples of these types of domestic claims include:

  • "Roasted and blended in Canada" to describe coffee since the coffee beans are always imported;
  • "Distilled in Canada" to describe bottled water that was distilled in Canada;
  • "Canned in Canada" to describe green beans that were canned in Canada;
  • "Refined in Canada" to describe imported cane sugar which has been refined in Canada;
  • "Processed in Canada" to describe a food which has been entirely processed in Canada;
  • "Prepared in Canada" to describe a food which has been entirely prepared in Canada;
  • "Packaged in Canada" to describe a food which is imported in bulk and packaged in Canada.

Guidance on other types of commonly used domestic content claims can be found below:

Claims Identifying a Canadian Food or Canadian Ingredients

The claim "Canadian" is considered to be the same as a "Product of Canada" claim. As such, all or virtually all major ingredients, processing, and labour used to make the food product must be Canadian. For example, the claim "Canadian" on a container of frozen lasagna would mean that the food meets the "Product of Canada" criteria.

This criteria also applies when the claim is used to describe an ingredient within the food. For example, if the claim "Canadian cheddar cheese" is used on a package of cheddar cheese sauce, all or virtually all major ingredients, processing, and labour used to make the cheddar cheese in the sauce must be Canadian.

When this type of claim is used to describe a single component ingredient within the food, all of the ingredient(s) and, if any, derivatives of that ingredient in the food, must be Canadian. For example, if the claim "Contains Canadian blueberries" is used on a prepackaged blueberry pie, all of the blueberries, as well as any blueberry juice concentrate or derivative, must be Canadian.

"100% Canadian" Claims on Foods or Ingredients

When the claim "100% Canadian" is used on a label, the food or ingredient to which the claim applies must be entirely Canadian rather than "all or virtually all" Canadian.

For example, if the claim "100% Canadian" was used on a pot pie, all of the ingredients, processing, and labour used to make that product must be Canadian.

This would be the same case for a food with a claim which refers to the origin of a particular ingredient, whether single or multi-component, as being "100% Canadian".

For example, if the claim "Made with 100% Canadian Wheat" is used on a bag of dry pasta, all of the wheat, and its derivatives, used in that product must be Canadian.

Additional guidance on the use of the claim "100% Canadian Milk" can be found in the Guidelines for the Acceptable Use of "100% Canadian Milk" Claims on Dairy Products.

Multiple Country of Origin Claims That Reference Canada

The use of a voluntary multiple country of origin statement that references Canada (e.g. "Product of Canada and United States") would not be acceptable. Products that contain foreign ingredients, regardless of their source, are not eligible to bear a "Product of Canada" claim.

Declaring multiple countries of origin on the label could result in false information and, as such, could be considered false and misleading.

Although products that contain foreign ingredients are not eligible to bear a Product of Canada claim, they may be eligible to make a qualified Made in Canada claim, provided that the last substantial transformation of the product occurred in Canada.

A blended claim, such as "A blend of Canadian (naming the product) and [Naming the country] (naming the product)", may be considered acceptable (e.g. "A blend of Canadian and American soybean oil").

Separate requirements may exist for commodities that require a country of origin statement. These are summarized in the Food-Specific Labelling Requirements of the Industry Labelling Tool.

Commodity Specific Information

Meat and Poultry

"Product of Canada" claims can be applied to meat from Canadian animals that are slaughtered in Canada. Animals are considered Canadian if they are born or hatched, raised and slaughtered in Canada or, in the case of feeder cattle, if they have spent a period of at least 60 days in Canada prior to slaughter in Canada. The 60-day residency period is based on international animal health standards. Such animals are fed, raised and slaughtered in Canada according to Canadian requirements.

The The Canadian Food Inspection Agency (CFIA) is currently reviewing how these guidelines can be best applied to meat products from live animals imported into Canada. This review will determine how to apply the Product of Canada claim to meat products while respecting the principles of the "Product of Canada" guidelines and not disrupting international commerce or be contrary to trade rules.

Meat from imported hatching eggs, including those hatched in transit, would meet the "Product of Canada" guidelines provided that the chick was raised, slaughtered and processed in Canada.

Fish and Seafood

Wild fish and seafood products can be labelled Product of Canada when caught by vessels in Canadian waters (or adjacent waters as per Canadian regulatory fishing quotas) and the products from the fish and seafood are processed in a Canadian establishment using Canadian ingredients.

In the case of farmed fish and seafood, the farm must be located in Canada, and the processing must occur in a Canadian establishment with the use of Canadian ingredients.

Dairy and Eggs

Eggs from imported hens and milk from imported cows would qualify for the Product of Canada claim provided that the hen laid its eggs in Canada, and the cow is milked in Canada.

National Symbols

The use of the Canadian Coat of Arms and the Canadian Flag are both protected under the Trade-marks Act, subsection 9(1). See Government of Canada trade-marks for more information.

Coat of Arms

The Canadian Coat of Arms cannot be used, unless permission is granted by the Department of Canadian Heritage. Requests for permission may be made to:

Federal Identity Program
Treasury Board of Canada Secretariat
Ottawa, Ontario K1A 0R5
Tel: (613) 957-2533
Fax: (613) 946-5187
information@fip-pcim.gc.ca

National Flag

The national flag with the 11-point maple leaf and one or two bars cannot be used unless permission for its use is granted by the Department of Canadian Heritage. There is however, no objection to the use of an 11-point maple leaf without bars. The maple leaf should not be used on an imported food product since it may give the consumer the false impression that the product is of domestic origin. Requests for permission may be made to:

State Ceremonial and Canadian Symbols
Department of Canadian Heritage
Gatineau, Quebec K1A 0M5
Tel: (819) 934-9048
Fax: (819) 997-8550
CeremonialetSymboles_CeremonialandSymbols@pch.gc.ca

Maple Leaf

The use of the maple leaf or other similar symbol may be used on food products without further permission. The use of these vignettes on their own does not always imply that the product is wholly or partially Canadian (e.g. maple leaves as part of a fall scene on a product's label).

However, depending on how the maple leaf is used, it could imply a "Product of Canada" claim and in such situations, the product must follow the criteria for a "Product of Canada" claim. In order to ensure that the use of the maple leaf or other similar symbol will not mislead the consumer, it is recommended that an accompanying domestic content statement be placed in close proximity to the vignette.

Terms Not Subject to the Guidelines

The following terms or references have regulated requirements and, as such, are not subject to the guidelines for Product of Canada claims:

Grade names incorporating the term Canada (e.g. Canada Fancy)

  1. The guidelines will not affect the regulated Canada grade name requirements or the Meat Inspection Legend.The "Canada Organic" logo or references to Canada Organic
  2. The Canada Organic logo is an indication of certification to the Organic Products Regulations and standards. On imported products that are qualified to use the Canada organic logo, a country of origin statement or the statement "Imported" is required to be in close proximity to the logo, to avoid misleading consumers.
  3. Mandatory Country of Origin Labelling (COOL) Statements
    The guidelines do not apply to mandatory country of origin statements. In addition, the use of a qualified Made in Canada claim or any alternate claim, such as "Packaged in Canada" does not trigger the need for the country of origin declaration unless otherwise specified in regulations. For more information, refer to Country of Origin Labelling.

Additional Information

Consultation on the "Product of Canada" Guidelines

Since the new guidelines came into effect, Canadian consumers have told us that they support the objectives of the "Product of Canada" Guidelines. However, food processors indicated that it may not be easy to find and maintain Canadian sources for some ingredients. For this reason, the Canadian Food Inspection Agency and Agriculture and Agri-Food Canada conducted consultations with approximately 3100 consumers and industry stakeholders through online and telephone surveys. The consultation gathered the opinions on the merit of exempting the imported ingredients sugar, salt and vinegar from disqualifying a product from the use of a "Product of Canada" claim. Almost half of those consulted did not want any exemptions. These consultations did not support such exemptions; therefore, the Government of Canada is maintaining the current guidelines, with no changes to its current policies regarding these claims.

Guidelines Defining "Product of Canada" and "Made in Canada" on food labels and advertising (Letter to Industry)

Canada's food supply is increasingly global in nature and many Canadians are seeking clearer information about the foods they buy. Canadians want credible, meaningful information about the foods they buy. Many want to purchase food products that are made and processed using Canadian standards, which they trust with good reason. Some simply want assurance that a significant amount of the product contains Canadian ingredients.

On July 15, 2008 the Government of Canada announced the new labelling guidelines for the use of these claims. The revised guidelines will help Canadians make informed choices about the products they are purchasing. They were developed to reflect consumer and industry expectations about what constitutes a Canadian product and to promote compliance with subsection 5(1) of the Food and Drugs Act and subsection 7(1) of the Consumer Packaging and Labelling Act.

Product of Canada

Under the guidelines when the label claim Product of Canada is applied, all or virtually all of the significant ingredients, components, processing and labour used in the food product must be Canadian. Food products claiming Product of Canada must contain very little or no foreign content, with the exception of minor food additives, spices, vitamins, minerals and flavouring preparations.

Made in Canada

The Made in Canada claim may be used when the food product is manufactured or processed in Canada regardless of whether the ingredients are imported or domestic or a mix of both. However, this claim must always be qualified with either Made in Canada from domestic and imported ingredients or Made in Canada from imported ingredients. To use these qualified claims, the last substantial transformation of the product must have occurred in Canada. This recognizes the importance of value added by Canadian ingredients and processing.

Other Qualified Claims

Qualified claims for other food products that do not meet the Product of Canada and Made in Canada guidelines may continue to be used. In particular, Roasted in Canada, Packaged in Canada, Distilled in Canada, Processed in Canada, etc. could be used provided that they are not false or misleading. However, use of Product of Canada and the qualified Made in Canada claim is encouraged for those products that meet the guidelines in order to provide consistency and clarity for the consumer.

Enforcement and Compliance

The CFIA enforces the requirements of the Food and Drugs Act and the Consumer Packaging and Labelling Act to protect consumers against product misrepresentation. Consumers expect labelling and advertising information, including claims, to be truthful and not misleading. The use of these claims on most food labels remains voluntary. However, when these claims are applied, they will be assessed based on the established criteria. When non-compliance is identified during inspections and when responding to complaints, appropriate corrective action will be taken.

The guidelines came into effect on December 31, 2008. It is recognized that many products produced or manufactured before this date may already be on store shelves. However, it is expected that all products produced after this date would comply with the guidelines.

For additional information, refer to the History of the Canadian Food Labelling Initiative. A number of Frequently Asked Questions on Product of Canada and Made in Canada Claims provide further detail on the interpretation of these guidelines. Should you require more information or have questions regarding these guidelines, please call the CFIA at 1-800-442-2342/ TTY 1-800-465-7735.

History of the Canadian Food Labelling Initiative

Canada's food supply is increasingly global in nature and many Canadians are seeking clearer information about the foods they buy. Recognizing this, the Government of Canada has taken action to improve the labelling information on food products and to help Canadians make better purchasing decisions.

Following the launch of the Healthy Canadians website on October 24th, 2007, the Prime Minister announced Canada's Food and Consumer Safety Action Plan on December 17th, 2007, with the goal of ensuring Canada's product safety standards are second to none.

As part of the Food and Consumer Safety Action Plan, the Government committed to reviewing the policy on the use of "Product of Canada" and "Made in Canada" claims on food labels and in advertising. Although Product of Canada and Made in Canada claims are not food safety issues, Canadians have indicated that this is an important matter to them.

On May 21, 2008, the Prime Minister unveiled the new Canadian Food Labelling Initiative together with the Honourable Gerry Ritz, Minister of Agriculture and Agri-Food Canada. This initiative improves the definition of "Product of Canada" and "Made in Canada" on food labels and advertising, to ensure that Canadians can have greater certainty about the Canadian content of the food products they purchase.

Following consultation with consumers and stakeholders, the Government of Canada has implemented the modernized guidelines which came into effect on December 31, 2008. It is recognized that many products produced or manufactured before this date may already be on store shelves, and these products will not be recalled. All products produced after December 31, 2008, should comply with the new guidelines.

Frequently Asked Questions

Refer to Frequently Asked Questions on Product of Canada and Made in Canada Claims.

About Shopping for Canadian Food

For more information on food that has been grown or made in Canada, refer to Shopping for Canadian Food.

Local Food Claims Interim Policy

Refer to Local Food Claims.

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