Have Canadian import rules or tariffs for dairy changed in 2025?
Executive summary
Canada’s dairy import rules remain tightly controlled in 2025: dairy imports require permits and tariff‑rate quotas (TRQs) with low within‑quota duties and very high over‑quota levies (examples: cheddar 245.5%, butter 298.5% in 2025) [1] [2]. The federal government passed legislation in 2025 to lock in protections for supply management and announced negotiated TRQ administration changes with New Zealand effective for the 2026 quota year; some procedural animal‑health rules (e.g., milk replacer import requirements) changed with implementation dates in 2025 [3] [4] [5].
1. Canada still operates a quota‑and‑permit regime that controls who can import dairy
Imports of dairy into Canada remain governed by the Export and Import Permits Act and Canada’s tariff‑rate quota system: shipments for the Canadian market require import permits issued to quota allocation holders and certain import channels (like the Import for Re‑export Program) have strict rules that bar diversion to the domestic market [1] [6]. General Import Permits exist for small personal‑use thresholds (e.g., $20 CAD per importation) but commercial imports fall under TRQ/SIP frameworks [7] [8].
2. Tariff structure: low within‑quota rates, very high over‑quota levies remain in effect
Canada continues to apply preferential (lower) duty rates inside TRQs and steep “over‑quota” tariffs above those volumes. Reporting and government agencies cite product‑specific over‑quota levies in 2025 — for example, cheddar cheese at about 245.5% and butter near 298.5% — illustrating that the two‑tier system remains the operative mechanism for protection of the domestic sector [2] [9].
3. Did rules or tariffs change in 2025? Mostly procedural updates and legal protections, not wholesale liberalization
Several notable 2025 developments adjusted administration and legal guardrails rather than removing protections. Parliament passed legislation (commonly reported as Bill C‑202 / C‑282 in media summaries) that bars ministers from increasing TRQ quantities or lowering over‑quota tariffs for dairy, eggs and poultry — a statutory reinforcement of supply management protections [3] [10]. Global Affairs Canada also announced a negotiated resolution with New Zealand that will produce minor administrative changes to TRQ administration to be published Oct. 1, 2025 and implemented for 2026 TRQs, not as immediate tariff rate reductions in 2025 [4].
4. Specific 2025 operational changes: animal‑health certification and milk‑replacer rules
Operational import requirements changed in focused ways in 2025. The Canadian Food Inspection Agency published that, effective March 24, 2025, Automated Import Reference System (AIRS) was updated with new animal‑health import requirements for milk replacers from countries other than the United States, including new certification or permit requirements for products containing animal‑origin ingredients [5]. These are sanitary/administrative changes, not direct tariff rate changes.
5. U.S. complaints, U.S. threats and Canadian responses shaped headlines — but did not force immediate tariff cuts in 2025
The U.S. dairy industry and U.S. political actors pressed Canada in 2025 to change import licence allocation and TRQ access; the U.S. also threatened reciprocal tariffs, generating headlines and pressure [11] [12]. Canadian officials and analysts noted that the very high over‑quota rates are on the books but rarely triggered because quota fill rates have been low — independent fact‑checks showed average fill rates well under full quota in early 2025 (around 21–27% depending on calendar) [13]. Ottawa repeatedly defended its supply management approach and moved to legally protect it [3] [2].
6. What this means for importers, retailers and consumers in 2025
Importers still need the right permits, TRQ allocations, or to use specific programs like IREP for re‑exports; eligibility rules (e.g., being an active processor/distributor) determine who can access tariff‑free quota volumes, and newcomers face steep administrative and duty barriers if they fall outside allocations [1] [14] [15]. Trade lawyers and industry commentary in 2025 stressed that procedural TRQ access rules — not a sudden change in headline tariff numbers — are the main barrier to broader import activity [15] [16].
Limitations, caveats and what sources do not say
Sources document legislative protections, announced TRQ administrative changes for 2026, and specific sanitary rule updates in 2025, but available sources do not mention an across‑the‑board lowering of dairy tariff rates in 2025 or a unilateral opening of TRQs to retailers in that year [3] [4] [5]. For granular, shipment‑level tariff calculations, consult the CBSA tariff schedule and specific Notices to Importers cited above [12] [1].