Do I require a country of origin declaration?

All wines and brandies not produced entirely in Canada require a country of origin declaration. Note that grappa and marc are considered to be brandy for this requirement.

Country of origin declarations are not required for other products except in the following circumstances:

What is the country of origin for a wine made in one country with grapes or juices from another country?

The country of origin is where the wine is made but the foreign source of grapes or juice must be acknowledged. There are several acceptable ways to phrase this declaration. Example:

What is the country of origin for a blend of wines from different countries?

Use a format “Cellared in Canada from domestic and imported wines”. The word “blended” may be substituted for “cellared” if desired.

What is the country of origin for a product made in one country but bottled in another?

The country of origin is where it is made. No reference to the bottler is required unless the manufacturer or bottler is in Canada. In that case, the name and address or the name and excise number of the bottler is required.

If the name and location of the bottler is given, it should be prefaced “bottled by”.

What formats are acceptable for a country of origin declaration?

The following formats are officially accepted by the Canadian government. They are written here using Canadian wine as an example.

  1. Product of Canada / Produit de Canada
  2. Wine of Canada / vin de Canada
  3. Canadian wine / vin canadien
  4. Statements given in questions above for products of mixed origins

Options 2 and 3 are particularly useful to save space as they combine the common name and country of origin declarations.

Can the dealer address be used as a country of origin declaration?

It is a common to combine dealer information and country of origin declarations for products of mixed origin (e.g. Cellared in Canada by XYZ Winery, town from domestic and foreign grapes). It is not common in other situations. If used, it must be in the same field of vision as the alcohol, net quantity and common name declarations. The dealer name and address must also be prefaced with a declaration that the product was produced there (e.g. Product of XYZ Winery, city, country). “Bottled by” is not a declaration of production.

When this option is used, the dealer information must be that of the manufacturing site.

Why was “Product of Canada” rejected on my label?

Starting January 1, 2009, all food products stating “Product of Canada” must be made in Canada using ingredients grown and processed in Canada. The only exceptions to this requirement are additives, such as preservatives, flavourings and spices totalling less than or equal to 2% of the product by weight. The LCBO will reject the “Product of Canada” claim for any product easily recognised as not meeting these requirements.

LCBO label reviewers can use only the information available to them. If the Canadian content of your product meets the federal requirements for a “Product of Canada” claim, the rejection will be overturned upon proof that at least 98% of the product (excluding water) is from ingredients grown and processed in Canada.

Manufacturers should recognise some common ingredients such as coffee, citrus fruit and exotic fruits as not grown in Canada. Because 90% of sugar in Canada is produced from sugar sources originating outside Canada, sugar as an ingredient is also be an indication of a problem for making a “Product of Canada” claim. When responding to a label rejection, manufacturers should also check the origin of corn derived ingredients as they may be produced from American corn.

Check the Canadian Food Inspection Agency website for more information on this topic. The website also gives information for related claims such as “Made in Canada” and the qualifications required to make them.