How do I know if organic products I import will have retaliatory tariff measures?  

• The Department of Finance Canada published a list of products from the United States that are subject to 25 per cent tariffs effective March 4, 2025, which can be found HERE. This is often referred to as the initial or first list, equalling $30 billion of imports. 

• COTA has confirmed with Government that the HS code that will be tariffed will be based on 8-digits. With the new Organic OGD codes, it appears that many organic products may be exempt (unless an organic-specific HS code exists and is on the list). We are awaiting final confirmation in writing. 

• For those not sure if their products will be subject to reciprocal tariffs, Agriculture and Agri-food Canada has been advising industry to consult with their import and customs brokers as they are used to reviewing customs schedules, etc. 

 

Will the 25% tariffs apply if I am importing a product from another country to Canada via the U.S.?   

Both Canada and the U.S. have indicated that they will follow the CUSMA rules of origin. If a product originating from another country is shipped via the U.S., but does not undergo transformation or enter U.S. commerce (e.g. it is in transit via the USA or warehoused in the U.S but with no changes), the product would still be considered from the origin country. The reciprocal Canadian tariffs would not apply in this case.   

 

What is on Canada's second list of reciprocal tariffs? 

Government of Canada has launched a consultation for Canadians to weigh in on the additional $125 billion worth of goods (see second list) imported from the U.S. that would face tariffs. COTA’s analysis is that there are no additional products added in which there is an organic specific HS code. The deadline for comments to be sent into the government is March 28, 2025. COTA will be submitting comments to the consultation on behalf of the organic sector. Please forward comments to mbosch@canada-organic.ca by March 11 if you have thoughts on the retaliatory tariff list or the scope of tariff countermeasures. (The Government has indicated the earlier to receive input on this list, the better, as the situation is evolving quickly).   

 

I sell small value goods (<$800) online to U.S. customers. Would the 25% tariffs on exports apply? 

On March 2, 2025, the President updated an executive order to allow certain goods from Canada to be exempt from tariffs (duty-free) under the "de minimis" rule, which means smaller shipments (<800 USD) can be imported without tariffs. This exemption is temporary and will end once the U.S. Secretary of Commerce confirms that the system to collect tariffs on these numerous smaller shipments is ready. See the US Government’s executive order. 

 

What is the government doing to mitigate the impacts of the tariffs to my business? 

When Canada’s reciprocal tariffs were announced, the federal government alluded to launching a remission process for Canadian businesses to request exceptional relief from the tariffs that are imposed as part of Canada’s response to the U.S. applying unjustified tariffs on Canada. All levels of government have been discussing potential relief packages. Industry groups have recommended AgriStability and COVID-like relief like the Canadian Emergency Response Benefit (CERB). 

COTA continues to advocate for tools to diversify markets (e.g. AgriMarketing) and support organic businesses that may have income loss as a result of the tariffs.  

Please submit any inquiries or remission requests to remissions-remises@fin.gc.ca, including “U.S. Remission” in the subject line. 

What programs does COTA have to support the diversification of my market? 

Organic Promotion Fund:

A dedicated pool of resources designed to boost sales of organic within our domestic market.

Learn more

Organic Export Support Fund: 

A grant to COTA members to help cover the cost of shipping samples to international buyers.

Learn more

 

What is the difference between “Made in Canada” and “Product of Canada”? 

Goods that are a “Product of Canada” must have at least 98% Canadian content. Goods “Made in Canada” are subject to a 51% threshold of Canadian content but should be accompanied by a qualifying statement indicating that the product contains imported content. 

 

What can my business do to prepare for potential tariffs? 

Despite the uncertainty, preparation rather than panic is key. Some of the things that businesses can do include: 

• Stay informed. This includes keeping current on the issue and what supports and opportunities are available. COTA is your committed partner to navigate through this. 

• Review contract clauses (e.g., change of law, force majeure) to assess tariff risk. 

• Evaluate and consider the country of origin of your goods. 

• Diversify supply chains and explore alternative sources. 

• Leverage Canada’s 9 organic equivalency arrangements for new export markets. In addition to the U.S., Canada has organic equivalency arrangements with the European Union, Switzerland, the United Kingdom, Costa Rica, Japan, Taiwan, Mexico and South Korea.  

• Leverage the “buy Canada” sentiment if your products are “made in Canada” or a “product of Canada” to grow your domestic market.  

• Look for opportunities in new product offerings, partners, and markets. 

• Communicate with suppliers and customers so that you can all prepare.  

• Engage with COTA and let us know your needs and challenges as we advocate on your behalf.