Review method
How every check is done.
This is the written method every check follows. We check the cost breakdown the manufacturer provides against the Competition Bureau thresholds. We do not decide where the last substantial transformation happened, and we do not audit whether the documents are genuine. The manufacturer pays a flat fee for the review. The fee is the same whatever the outcome, and no payment changes the result.
Method version 1, 26 September 2026.
1. Documents required
- One representative product line per check.
- A cost breakdown for one unit: total direct production cost and the part incurred in Canada, split into materials, labour and production overhead.
- Supporting documents: supplier invoices for the main inputs, a bill of materials, and a payroll or labour summary. Where overhead is included, the basis for allocating it to the product.
- Where the manufacturer states the last substantial transformation happens, and what that step is.
- For "Made in Canada", the exact qualifying statement printed on the label (for example "with imported parts").
- A signed attestation by the manufacturer that the figures and documents are complete and accurate.
2. How direct costs are computed
- Following the Competition Bureau guidance, direct costs are the costs directly tied to making the product: materials, labour and production overhead that relates directly to production and can reasonably be allocated to it. General overhead that is not tied to production (sales, marketing, head office, profit) is excluded.
- Canadian share = Canadian direct cost ÷ total direct cost, rounded to one decimal place. Imported inputs count as non-Canadian even if bought from a Canadian distributor.
3. Thresholds
- "Made in Canada": at least 51% of total direct cost incurred in Canada, last substantial transformation stated as in Canada, and a qualifying statement on the label.
- "Product of Canada": at least 98% of total direct cost incurred in Canada and last substantial transformation stated as in Canada.
- Non-food goods only. Food claims belong to the Canadian Food Inspection Agency and are refused at submission.
4. What the reviewer checks
- That the cost breakdown adds up and the Canadian share clears the threshold claimed.
- That the supporting documents support the main lines of the breakdown (the reviewer samples the largest cost lines against the invoices, bill of materials and labour summary).
- That the manufacturer has stated where the last substantial transformation happens, and that the stated place is in Canada.
- For "Made in Canada", that a qualifying statement is present.
5. What is not checked
- We do not decide whether an activity is legally a "last substantial transformation"; we record what the manufacturer states.
- We do not audit whether documents are genuine, contact suppliers, visit facilities or test products.
- A check is not a certification, an audit, a legal opinion or a guarantee. The manufacturer stays responsible for its own claims.
6. Automated pre-screen and the human reviewer
- At submission, the system refuses an application that is incomplete (no cost figures, no stated place of transformation, no signed attestation), a "Made in Canada" claim with no qualifier, or a food product.
- The system computes the Canadian share and blocks an approval that the numbers do not support, an unpaid request, or a request with no documents on file.
- The pre-screen can refuse but never approves. Every outcome is decided by a human reviewer, who records the reason for any Needs information or Not met decision. Every status change is logged with its date and the person who made it.
7. Possible outcomes
- Checked: the documents are consistent with the threshold. The mark and a public record are published.
- Needs information: something specific is missing. The manufacturer can add it and the same review continues at no charge.
- Not met: the documents do not support the claim. The manufacturer receives the reason in writing. Nothing is published as a pass. Re-check terms are on the pricing page.
- The fee is the same whatever the outcome, and no payment changes the result. Free checks (first 15 manufacturers) are reviewed the same way and can end as Not met.
8. Records, dating and expiry
- A Checked record shows the product line, the claim level, the review date and the expiry date: 12 months after the review date.
- A daily job removes the mark from any listing whose record has expired. Renewal is a new review with updated figures.
- A record can be revoked if we learn the documents were false or misleading. Revocations are shown on the public record page.
- Uploaded cost documents are deleted 12 months after the outcome by an automatic daily job. The decision, its date and the reason are kept.
9. Who reviews
- Until a CPA reviewer is added, the business owner reviews each check. See the conflict of interest policy.
Conflict of interest policy · Scope of review · How checks work · Pricing