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Global Affairs Canada ("GAC") recently announced it is now accepting applications for the 2026 tariff rate quotas (the "TRQs") for most dairy products (including cheese, butter and ice cream), and poultry (including eggs). Applications opened on October 1, 2025, and the deadline to apply is November 15, 2025.
What is a TRQ?
Canada has a number of supply-managed goods – largely agricultural products such as milk, butter, cheese, poultry, eggs, etc. Imports of these products into Canada are practically prohibited with punitively high tariff rates (i.e., generally over 200%). However, when negotiating free trade agreements such as the Canada-United States-Mexico Agreement ("CUSMA") and the Comprehensive and Progressive Agreement for Trans-Pacific Partnership ("CPTPP"), Canada generally makes market access commitments to its trading partners – agreeing to allow a defined quantity of supply-managed goods to be imported at a lower level of duty. Canada then establishes TRQs to track and enforce those import limits.
Under the TRQ system, GAC establishes a specific quantity of an importable product (the "Available Quantity"), and then allocates that Available Quantity through a TRQ, which is granted to eligible applicants annually using a prescribed allocation method. (For more information, see our prior blog here).
Changes to CPTPP Dairy TRQ
GAC also announced a number of technical policy changes for the CPTPP dairy TRQs, which include the following:
- moving the return date to May 1 (from August 1) for calendar year TRQs and to December 1 (from March 1) for dairy year TRQs;
- establishing a processing timeframe for the reallocation of returns;
- introducing a chronic return penalty;
- undertaking greater scrutiny of certain allocation transfer requests;
- introducing an underfill mechanism for TRQs that exhibit a utilization rate of less than 60% for three consecutive years; and
- publishing additional aggregate TRQ data and TRQ utilization by CPTPP Party.
What to Expect from the TRQ Application Process
The TRQ application process may appear deceptively simple as it involves completing an application form and submitting it to a designated government email address. However, the finer details of a TRQ application reveal potential pitfalls for applicants (in particular new market entrants). For instance, each type of product is subject to unique requirements and limitations, and the applications for an allocation of a product must be made with reference to a particular trade regime (e.g., CPTPP, CETA, CUSMA, etc.).
TRQ applications have a number of complex rules and requirements.
Experienced customs lawyers can help businesses with their 2026 TRQ applications.
Takeaways
Importers of dairy and poultry products should ensure they submit their application for a TRQ allocation prior to the November 15 deadline. As the TRQ application process can be quite complex, legal assistance from experienced customs counsel can help importers secure allocation.
It is also recommended that businesses seeking allocations for the first time (new entrants) consult legal counsel, as the TRQ regime (including the CPTPP dairy TRQ regime) typically favours established Canadian businesses.
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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
