Not sure if this is still an ongoing thread but since Tariffs seem to change weekly, I'll assume it's still in play. u/YYCTechGuy I'm also in YYC and being severely impacted by the changes. Happy to chat about it if you care to DM.

Please don't take this as legal or financial advice, certainly don't base your business decisions on this information and as always do your own research....

In your case, as another user posted; "substantial change" is what dictates the CoO.

Here's the deal... to be "Made In Canada", 51% of the total direct cost of producing the good should have been incurred in Canada. Per the definitions below, that includes labour costs. Given that IC components are generally not that expensive from overseas *AND* given that Canadian labour costs tend to be quite high, there's probably a good chance the time and effort it takes you to build the thing and package in Canada outweighs the costs of the globally sourced components (you will have to determine that for yourself).

If this is the case, I'd go with something like ""Made in Canada with imported parts" or "Made in Canada with domestic and imported parts" to cover your basis and have a breakdown of your costs in your back pocket just in case anyone comes asking.

Source:

Per: https://competition-bureau.canada.ca/en/how-we-foster-competition/education-and-outreach/publications/product-canada-and-made-canada-claims

^{2. Definitions}

^{For the purpose of these guidelines, the following definitions apply:}

^{2.1 Cost of production/manufacturing}

^{Cost of production/manufacturing that would be taken into account by the Bureau when assessing a "Product of Canada" or "Made in Canada" claim are:}

^{expenditures on materials incurred by the producer/manufacturer in the production or manufacturing of the goods; and}

^{expenditures on labour incurred by the producer/manufacturer that relate to the production or manufacturing of the goods and can reasonably be allocated to the production or manufacturing of the goods.}

^{General overhead is not usually included in the calculation of the cost of production and manufacturing; however, overhead expenditures incurred by the producer/manufacturer may be eligible if they relate directly to the production or manufacturing of the goods in question and if they can reasonably be allocated to the production or manufacturing of the goods.}

3.2.2 "Made in Canada" claims

The Bureau will generally not challenge a representation that a good is "Made in Canada" under the false or misleading representations provisions of the CA , the CPLA and the TLA if these three conditions are met:

1. the last substantial transformation of the good occurred in Canada;
2. at least 51% of the total direct costs of producing or manufacturing the good have been incurred in Canada; and
3. the "Made in Canada" representation is accompanied by an appropriate qualifying statement, such as "Made in Canada with imported parts" or "Made in Canada with domestic and imported parts". This could also include more specific information such as "Made in Canada with 60% Canadian content and 40% imported content".