The Canada Mutual Recognition Agreement – A two-way street to the market

The signing of the Canadian Mutual Recognition Agreement on the Sale of Goods (the CMRA) marked an important day for federal and provincial trade within Canada. 

The CMRA was signed on November 19, 2025, by the Government of Canada, all 10 provinces and the Northwest Territories. (Due to territorial elections, the governments of Nunavut and Yukon territories have not yet signed on.) Having come into force in some jurisdictions on January 1, 2026, broad implications for commerce and trade between provinces are in effect. 

The CMRA reduces barriers to the sale of goods across Canada by ensuring that a product that may be sold lawfully in one province or territory can be sold across Canada without having to meet further requirements.

Although identified government exceptions apply, the expectation is that there will be more frictionless trade within Canada, which should unlock billions of additional dollars of trade. The CMRA aims to streamline supply chains and unlock up to $200 billion in annual GDP.

The Benefits of the CMRA

Above all, the CMRA’s value lies in its ability to treat Canada as a single, unified market rather than 14 distinct regulatory zones.

For example, manufacturers will see the primary benefit in production efficiency: companies will no longer need to maintain separate assembly lines or product formulations to satisfy minor regulatory variations between provinces unless there is a provincial carve-out. This one-product, one-country approach allows for greater economies of scale, particularly in sectors like health technology and industrial machinery.

Small businesses will also benefit. Most small businesses do not have specialized legal and compliance departments to navigate Canada’s various jurisdictions. By unifying the market, the CMRA lowers the barrier to entry for scaling operations across the country.

Consumers also stand to benefit from increased competition and choice.

Québec’s Bill 96 (and Other Exceptions) Remain Unaffected

Although the thrust of the CMRA is to create a single market, businesses must understand that it does not create a regulatory vacuum unaffected by federal or provincial laws.

Technical product standards, like safety specifications or chemical compositions, are being unified in some cases, but the CMRA does not override provincial powers related to legitimate public policy objectives. Further, the CMRA does not affect rules on how a good may be sold or the conduct of the sellers. That exception includes rules in Québec regarding the protection of the French language.

Consequently, Québec’s Bill 96 (the Act respecting French, the official and common language of Québec) remains a separate and mandatory compliance track for any company entering that market.

The impact of this divergence is very visible in trademark requirements. Since June 1, 2025, the recognized trademark exception in Québec has been significantly tightened. There are substantial obligations to properly use an English-language trademark on a product in Québec.

Even if a product meets all federal safety standards under the CMRA, any English-language trademark that includes descriptive or generic terms (e.g., "Superb Blend" or "Max Strength"), must now feature a French translation of those specific terms on the packaging. See examples of this and other requirements in our article here.

Furthermore, the CMRA does not shield businesses from the rigorous signage and digital requirements mandated by Bill 96. Public posters, commercial advertising, and even websites directed at the Québec public must ensure that French is extensively and sufficiently displayed.

Given that these rules govern the manner of sale and vendor conduct as opposed to technical specifications, they fall outside the current scope of the CMRA’s mutual recognition protections.

2026 and Beyond: The Roadmap for Expansion

The January 1, 2026, commencement of the CMRA is the first phase of a broader multi-year strategy to integrate the Canadian internal market. The Committee on Internal Trade has already set an ambitious schedule for May 2026, which includes the anticipated entry into force of new chapters governing financial services.

At the same time, another Memorandum of Understanding among 11 jurisdictions is slated for operationalization in May, which will allow direct-to-consumer alcohol sales, enabling producers to ship wine, spirits, and beer for personal consumption across provincial and territorial lines.

The focus will shift toward the agri-food sector later this year and over the years to come. Food products are excluded from the CMRA as it exists today because of complex health and safety variations, but work has begun to align the provinces and territories in this area. Other notable exclusions are live animals, cannabis, tobacco, and plants.

Finally, the federal government is moving to harmonize building codes and professional certifications for tradespeople, aiming to foster a Canadian economy that is resilient against global economic shifts and less dependent on international supply chains.

A Dual-Track Compliance Strategy

The CMRA brings a significant competitive advantage for businesses looking to scale nationally by reducing compliance and administrative expenses. That said, Canada will still be, in part, a dual-track regulatory environment. Failing to distinguish between technical standards covered by the CMRA and "how the product is sold" as governed by Québec’s Bill 96 could lead to issues. Avoiding pitfalls and optimizing your operations can be as simple as starting with an audit of your trademark portfolio.

In sum, businesses can leverage CMRA’s streamlining in manufacturing and its removal of red tape but can’t turn a blind eye to the exceptions like Bill 96. 

Fillmore Riley's Business Practice

If you have questions about how the Canadian Mutual Recognition Agreement on the Sale of Goods may impact your business, please contact a member of our Business practice.