Made in Canada Claims on a Product Page

A maple leaf beside the price

Product pages in Canadian online stores often carry a small maple leaf, a Made in Canada badge, or a line in the description saying the item is Canadian. Customers notice, and some will pay more because of it.

Those words have specific meanings under federal guidelines. A maple leaf can carry the same meaning without any words at all.

Most businesses that get this wrong are not trying to mislead. They copied a supplier's description, or they make the product here and assume that settles it.

This post is general information, not legal advice. For a particular product or claim, a lawyer who works on advertising and labelling can tell you what it needs.

Two claims with different bars

The Competition Bureau publishes guidelines on how it treats these claims for non-food products, under the Competition Act, the Consumer Packaging and Labelling Act and the Textile Labelling Act.

Under those guidelines, "Product of Canada" calls for the last substantial transformation of the product to happen in Canada, and at least 98 percent of the total direct costs of producing it to be incurred here. In practice, almost everything.

"Made in Canada" needs the last substantial transformation in Canada, at least 51 percent of total direct costs incurred here, and a qualifying statement, such as "Made in Canada with imported parts".

Food is handled separately, under food labelling guidance with its own wording.

The terms in plain words

• Last substantial transformation: the step that turned materials into a new product.
• Total direct costs: materials, labour and overhead tied directly to making it.
• Qualifying statement: words beside the claim saying what was imported.
• Packing and labelling: not a transformation, wherever they happen.
• General impression: what a customer would understand, not only the literal words.

The last is the one that catches websites. The Competition Act judges a representation by its general impression as well as its literal meaning, so a maple leaf can say what the text never does.

Products made here from imported parts

The common case for a small business is a product made here from parts that are not: furniture built with imported hardware, clothing sewn from imported fabric, equipment assembled around an imported motor.

If the work done here is a substantial transformation and enough of the cost is Canadian, "Made in Canada with imported parts", or "with domestic and imported parts", can fit.

If not, describe what actually happened here: designed in Canada, assembled in Canada from imported parts, sewn in Canada from imported fabric. Specific statements like these are accurate, and they tell a customer more than a badge does.

Where claims hide on a website

The product description is the obvious place. It is rarely the only one.

A badge added by the store's theme or a plugin can put a maple leaf beside every product, imported ones included. A category called Canadian Made can collect items of which only some qualify.

Product photographs can carry flags. Page titles written for search can say Made in Canada about products that never were. Supplier descriptions pasted in years ago can describe products whose manufacturing has since moved overseas.

Each of these is a claim, made to every visitor, on every product it touches.

A worked example

A sauna builder in the Fraser Valley sells barrel saunas built in its own shop from western red cedar milled in BC. The heaters, stones, controls and some fittings come from Europe.

Each model's page carried a maple leaf and the heading Product of Canada. The cedar and the building were Canadian; the heater, one of the most expensive single parts, was not.

The owner's own costing put the Canadian share comfortably above half, but nowhere near all of it. Building the sauna was clearly the substantial transformation, and it happened in the shop.

The pages now say "Made in Canada with imported heater and controls", followed by a line naming what is Canadian: BC cedar, built in the shop by the company's own crew.

The maple leaf sits beside that wording rather than standing alone.

The heater's country of origin is listed in each model's specifications as well, which buyers had been asking about anyway.

Ads, feeds and social posts

The guidelines are about the representation, not the medium. A claim in an AdWords ad, a shopping feed, a Facebook post or a printed catalogue is read the same way as one on the product page.

When a page's wording changes, change the ads and posts that repeat it. An ad saying Made in Canada often outlives the page it pointed to.

Keeping claims accurate over time

Origin claims go stale. A supplier moves production, a part changes source, or a new product joins a category already labelled Canadian.

Keep a short record for each product carrying a claim: where it is made, what is imported, and roughly what share of the cost is Canadian. When any of those changes, the page changes.

Ask suppliers in writing about the origin of anything you describe as Canadian, and keep the answers. Supplier wording is a starting point, not evidence.

Canadian-owned is a different claim

Many businesses want to say something true about themselves rather than the product: Canadian-owned, family-run, serving the valley since 1998.

Those statements belong on the about page and in the footer, worded clearly as being about the company. Placed beside a product, a maple leaf meant as a statement about the owners can be read as one about the goods.

The counter-case

Not every mention of Canada needs this scrutiny. A shop's address, a flag in the footer of a site that sells services, or a line about being Canadian-owned on the about page describes the business, not a product.

And a product grown, made and finished here from Canadian materials can say so plainly.

The care belongs where a claim sits next to a product with imported parts. There, use the wording that fits, with a qualifying statement wherever one is needed.

What to check

1. List every product with a Canada claim or symbol.
2. Find site-wide badges added by the theme.
3. Record where each product is made and from what.
4. Match each claim to what the guidelines describe.
5. Add qualifying statements where parts are imported.
6. Move company claims to the about page.
7. Update ads and feeds to match.

Step two finds the claims no one wrote. A badge applied by the theme puts a claim on every product at once, including ones nobody would call Canadian if asked.

The same care with product details applies to size charts shoppers can trust.

Frequently asked questions

West Coast Media Solutions Inc. provides web design, web development, hosting, digital marketing, and business consulting to organisations across Canada, drawing on more than twenty-five years in the field.