In this episode of CMA Connect, Alison Simpson, CEO of the CMA, sits down with Josephine Palumbo, Deputy Commissioner for the Deceptive Marketing Practices Directorate at the Competition Bureau of Canada, to decode Canadian origin claims and emerging fraud threats. Josephine explains the critical distinctions between "Made in Canada" and "Product of Canada," how tariffs impact threshold calculations, and practical guidance for avoiding maple washing. The conversation expands to the Bureau's Fraud Prevention Month focus, including the alarming rise of AI-generated scams using deep fakes to impersonate government officials. 00:00:01.720 — 00:00:20.280 · Presenter Welcome to CMA Connect, Canada's marketing podcast, where industry experts discuss how marketers must manage the tectonic shifts that will change how brands and businesses are built for tomorrow, while also delivering on today's business needs. With your host, CMA CEO Alison Simpson. 00:00:22.880 — 00:02:16.740 · Alison In an era of renewed Canadian patriotism and heightened awareness of global supply chains, consumers are absolutely paying closer attention than ever to where their products are coming from. With ongoing tariff discussions, a growing desire to support domestic industries, Made in Canada and Product of Canada claims have become more than just marketing messages. They are promises that Canadians absolutely expect businesses to keep. For this episode, I'm thrilled to welcome Josephine Palumbo, Deputy Commissioner for the Deceptive Marketing Practices Directorate at the Competition Bureau of Canada. In her pivotal role, Josephine leads efforts to detect, investigate, and deter false or misleading representations and deceptive marketing practices across Canada. With over 25 years of experience at the Department of Justice and Competition Bureau, including significant work as Deputy Executive Director and Senior Litigation Counsel. Josephine has been at the forefront of major enforcement actions involving companies like Amazon, Ticketmaster and Volkswagen. Josephine expertise extends globally. She served as president of the International Consumer Protection and Enforcement Network in 2020, representing Canada among over 65 protection agencies worldwide. Her directorate's mandate includes enforcement under the Competition Act, Consumer Packaging and Labeling Act, the Precious Metals Marketing Act, and Textile Labeling Act, which gives her comprehensive oversight of marketing claims that matter the most to Canadian consumers. So as we navigate an increasingly complex marketplace where maple washing and misleading origin claims can absolutely undermine consumer trust. Josephine's insights into what constitutes truthful advertising, along with the real world consequences of getting it wrong, have never been more relevant for Canadian marketers, so I am absolutely thrilled to welcome Josephine. It is a pleasure to host you on CMA Connect, and I'm really looking forward to our conversation. 00:02:16.780 — 00:02:20.780 · Josephine I'm so glad to be here, Alison. I'm looking forward to our talk. 00:02:20.940 — 00:02:44.220 · Alison We're going to cover a lot of hot topics that are crucial and important to marketers in Canada and also Canadians, so I know we will have a rapt audience. So, Josephine, let's start with why Made in Canada and Product of Canada claims matter so much to both consumers and businesses. Obviously, with renewed Canadian patriotism at the forefront of everyone's mind, how does today's environment compare to what you've seen historically? 00:02:44.260 — 00:03:53.790 · Josephine Well, let me start by saying that in the past, country of origin claims may not have been top of mind for most consumers, but today, Alison, Canadians are far more focused on transparency, on authenticity and knowing where their products truly come from. There are many factors driving this trend today, and I can list some of them, including national pride and that desire to support Canadian made goods. The commitment to support the Canadian job market and local industry's concerns about the economy and environmental impacts of purchasing decisions, and the belief that Canadian made products are held to higher standards of quality for businesses. I would say honesty and clearly representing product origin builds consumer trust and helps them steer clear of legal complications, which is always a good thing. On the other hand, misleading claims risk harming consumers, their fair competitors and the wider market and could result in enforcement under the Competition Act and the other relevant legislation when representations are false or misleading. 00:03:53.830 — 00:04:31.240 · Alison That's very helpful, and it's really rewarding in many ways to hear that Canadians, and we've seen this in other research too, Canadians through the tariffs, through the challenging political and economic times, are really embracing Made in Canada and wanting to give back to the local businesses and brands and support our local economy as well. So there's lots of encouraging reasons for the renewed patriotism that's hopefully having a positive impact on Canada's GDP as well. Josephine: Absolutely. Alison: Now, many people don't realize that there's quite a significant distinction between a Made in Canada claim and a Product of Canada claim. Can you explain the difference and what businesses need to know? 00:04:31.280 — 00:06:27.660 · Josephine Sure. I would say that the distinctions are significant, and they're clearly laid out in the Competition Bureau's guidelines that have been updated in March of 2025, so last year. So let me start. And it's a little technical. So Product of Canada is what I refer to as the gold standard. It means virtually all, at least 98% of the direct production costs, including input or materials and labor, are from Canada. This threshold exists to protect consumers from being misled by claims that imply total Canadian origin. On the other side, we have Made in Canada, which indicates that the majority or 51% or more of the direct costs were Canadian, and this type of claim should be accompanied by a qualifying statement, such as Made in Canada from domestic and imported parts to accurately inform consumers. I should say that both Product of Canada and Made in Canada representations, the product's last substantial transformation occurs in Canada, and that is the product comes into being in Canada. It isn't merely assembled or labeled or packaged here, it is made into something meaningfully new. And here, Alison, let me just say, for businesses, it's essential to review the cost breakdowns regularly to ensure compliance with these thresholds, especially if sourcing changes are occurring. We at the Competition Bureau, we evaluate these claims based not only on the literal meaning of marketing materials, but also on how consumers might interpret such claims. So we would be looking at everything like the words, mix of words, images, illustrations, or even the overall layout. And this is what we call the general impression. So again, it's very important. Clarity and honesty are paramount. 00:06:28.220 — 00:06:39.900 · Alison One of the newer claims I've seen emerging with renewed Canadian patriotism over the last year and a bit is Packaged in Canada. So when might those claims be considered misleading to consumers? 00:06:39.900 — 00:08:17.840 · Josephine So Packaged in Canada for us means like a product arrived mostly finished from another country and only its packaging was added locally. This claim, we would say, could be misleading to consumers if not clearly explained. So the Bureau again encourages the use of qualified claims where the information provided is accurate, relevant and useful. Let me say that the Bureau again, it looks at not only the words, but the whole concept, the general impression created. Sometimes businesses don't realize or understand this and think that as long as they are truthful, that should be good enough and that is not always the case. Again, the general impression has to be taken into consideration. For example, one case that we litigated, well, we didn't litigate, but we settled this case, and that was in 2016. So the Bureau investigated Moose Knuckles for concerns relating to advertising and labeling of some of its parkas as Made in Canada. And here, Alison, the Bureau found some Moose Knuckle parkas were marketed as Canadian- made, despite being mostly manufactured elsewhere, only with the finishing touches to the jackets being made here in Canada, like adding the trim or the zipper and the snaps, those were done in Canada. And with the Competition Bureau, we resolve the matter with the company, who agreed to donate 750,000 over a five year period to Canadian charities, including those providing winter coats to children in need. The company also committed to clearly labeling and advertising, making it explicit when products are made with both Canadian and imported parts. 00:08:17.920 — 00:08:52.770 · Alison That's a great example that speaks to the importance of being fair and truthful to Canadians and how we're marketing, but also the important consequences that businesses will and should pay when they don't follow the letter of the law. Now, for our listeners, we also have an article that we've written around all of the different Made in Canada, Product of Canada claims that elaborates on some of what Josephine has shared. So we will add it into our listener notes for anyone that's listening and wants to read more. We'll have the link in our notes. So, Josephine, what are some of the common mistakes you've seen businesses make when they've made origin claims? 00:08:52.770 — 00:09:46.010 · Josephine So businesses often make mistakes by failing to provide, for example, appropriate qualifying statements using ambiguous