Canada’s labelling approach often reflects a ‘my house is your house’ mindset. For example, a package of cookies imported from the U.S. may bear the name and address of a U.S. company, but there’s no need to declare the product’s country of origin. It is assumed a consumer would recognize the product originated in the U.S. This approach implies a sense of shared identity that may no longer meet consumer demands for transparency and clarity.
Canadian regulations also do not consistently require clear declarations of a food product’s origin. Consumers are often left without predictable or uniform information to make purchasing decisions. Even voluntary claims related to domestic production can be confusing. For instance, what is the difference between “Made in Canada” and “Prepared in Canada”? While a technical distinction exists, it is not always meaningful or intuitive for consumers. In the case of certain retail food commodities (e.g. a bag of cookies), it is sufficient when a Canadian domicile (name and principal place of business) is included on a label of an imported product along with the prefix “Imported by”. Consumers are then left to ponder, but from where?
To be fair, Canada does mandate clear country of origin declarations for certain food categories. For instance, meat and poultry products of foreign origin must display the country of origin on the main panel, next to the product name. Seafood labels must include a foreign state of origin, typically next to the company’s address. Processed fruits and vegetables only require country of origin labelling if a Canadian address is provided for a product of foreign origin. In that case the declaration can be anywhere on the label, but must be 6.4 mm in height if the declaration of net quantity is more than 283.5 g and at least 3.2 mm in height if the declaration of net quantity is 283.5 g or less. If the food is of the same origin as that of the named domicile, no other origin markings are needed. Imagine how confusing this can be for consumers.
In the case of imported prepackaged dairy products, the foreign state of origin must be declared on the label. However, for a consumer prepackaged cheese packaged in Canada from imported bulk cheese that is subject to a standard, the declaration must be on the main panel. Can we make rules that are any more confusing!
Inconsistent and confusing rules
Canadian rules are piecemeal and inconsistent, leaving many consumers frustrated and confused.
Much of this regulatory patchwork is the legacy of older labelling requirements that were effectively inherited under the Safe Food for Canadians Regulations (SFCR), which came into force in 2019. The Canadian Food Inspection Agency (CFIA) initiated efforts to modernize these rules, but the process was shelved due to COVID-19.
Canada has also long maintained voluntary guidance on origin claims. CFIA’s policies, adapted from Innovation, Science and Economic Development Canada, outline criteria for terms such as Product of Canada (all or virtually all major ingredients, processing, and labour must be Canadian, with no more than 2 per cent foreign content) and Made in Canada. The latter claim must be qualified, such as “Made in Canada with domestic and imported ingredients,” if foreign content is used.
Additional phrases like “Prepared in Canada” or “Baked in Canada” do not need to be qualified. Businesses may also identify themselves as Canadian, but this can be misleading if the actual food product is imported, unless the claim is properly qualified. Canadian guidelines may be a bit soft in this regard.
The maple leaf, a powerful national symbol, has also seen a resurgence in marketing. The iconic 11-point maple leaf is a registered trademark of the Government of Canada, and its use in commercial contexts requires authorization from Heritage Canada. This important fact may not be well-known in industry.
Even before recent trade challenges, the need to update Canada’s country of origin labelling rules was widely acknowledged. Today, consumers are increasingly frustrated with the lack of clarity and consistency in food labelling. Updating our origin labelling framework is not just a matter of regulatory housekeeping, but also an achievable and necessary step toward greater transparency and consumer confidence.
Gary Gnirss is president of Legal Suites, specializing in regulatory software and services. His email ID is president@legalsuites.com.
This column was originally published in the Nov./Dec. 2025 issue of Food in Canada.
