The new "Product of Canada" guidelines came into
effect on December 31, 2008, and were published as the new
paragraph 4.19 in the Guide to Food Labelling: "a
food product may claim 'Product of Canada' when all or
virtually all major ingredients, processing and labour used to
make the food product are Canadian." The Guide
defines the standard as 98%. It became clear within a matter of
months that the standard was too restrictive and that the former
producer and processor consensus of 85% would be more workable.
At a meeting of more than 50 representatives of the Canadian
food processing industry on April 19, 2010, Minister of State for
Agriculture the Honourable Jean-Pierre Blackburn announced new
consultations on the issue but limited the exercise to a
consideration of "exempting specific ingredients which are
difficult to source in Canada", i.e., sugar, vinegar and
Who were the interests pushing for these three exemptions? Why
not simply lower the threshold to 85%? Emails to officials to get
some clarity on these questions remain unanswered.
By selecting without explanation three ingredients, officials
have managed to create a minefield when an easy solution was there
for the taking. This clumsy consultation, compounded by resort to
an awkward computer questionnaire technique, is picking winners and
losers while doing nothing to enlighten the consumer.
For example, products sweetened with imported raw cane sugar
would be eligible for Product of Canada but products using domestic
corn sweeteners that cannot quite meet 98% could not. Why would we
want to benefit imported cane sugar over Canadian sugar
beets? Why would we want to provide a benefit to foreign
vinegar producers over Canadian produced vinegar? What Canadian
food products require more than 15% salt? Doesn't this
exemption idea simply invite all kinds of other commodities to
argue for an exemption too?
A little history here is helpful. In 2005 the Canadian
Federation of Agriculture (CFA) issued a paper that argued for a
"Canadian" label to promote Canadian fruits, vegetables,
poultry, beef, pork and grain products. CFA accepted the 51%
"Product of Canada" claim but it also wanted a
"Grown in Canada" claim, and, of course, this being CFA,
money from Agriculture Canada to promote it. Then Wendy
Mesley's book club and CBC highlighted the
"misleading" nature of Industry Canada's 51% rule as
applied to food and this engendered a media frenzy full of
misinformation which brought great pressure on the government. The
Standing Committee held hearings for many months, became very
partisan, and a couple of weeks before its Report was issued,
the government announced the new 98% policy in spite of the fact
that by this time the CFA, most producers and the food processors
agreed that 85% was about right.
The failure of the current policy is pretty clear. Try finding
"Product of Canada" claims on Canadian processed food.
The government should be commended for recognizing the need for
speedy reform but the "consultation" seems to be going in
the wrong direction. Moreover, the current consultation
also suggests that the qualifiers on "Made in Canada"
could be dropped. This would only cause more confusion for the poor
The solution is clear. Adopt the 85% rule for "Product of
Canada", leave "Made in Canada" with qualifiers
alone (a good innovation) and adopt a process to recognize
"Grown in Canada" to help local farmers. This would
be an easy win for Minister Blackburn who deserves credit for his
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