November 3, 2025
Global Affairs Canada
Trade Negotiations – North America
John G. Diefenbaker Building
111 Sussex Drive
Ottawa, Ontario
K1N 1J1
Sent via: CUSMA-Consultations-ACEUM@international.gc.ca
RE: Canadian Beverage Association Canada-United States-Mexico Agreement Consultation Submission
Introduction
The Canadian Beverage Association (CBA) welcomes the opportunity to provide input to the Government of Canada as it prepares for the mandated Canada-United States-Mexico Agreement (CUSMA) review. Our industry relies on a stable, rules-based North American trading framework that enables efficient cross-border supply chains, supports domestic production and innovation, and enhances the competitiveness of Canadian food and beverage manufacturing.
About us
The CBA is the trusted and leading voice for Canada’s sustainable, responsible, and competitive non-alcoholic beverage sector. Collectively, the association represents more than 60 brands of non-alcoholic beverages including carbonated soft drinks, juices, bottled waters, sports drinks, functional beverages and ready-to-drink coffees and teas. Most beverages sold by members across the country are made and shipped within Canada. The sector is committed to maintaining and growing their contributions to the Canadian economy and the communities in which they operate.
The non-alcoholic beverage sector is a nationwide economic contributor
The non-alcoholic beverage sector is a significant economic driver across Canada. In 2024, the sector added a total of $5.8 billion to Canada’s GDP, contributing a total of $2.3 billion in tax revenues across all levels of government (Conference Board of Canada, 2025). The sector also delivers positive economic spillovers, generating $0.8 in additional GDP for every $1 of output. The sector also provides good-paying jobs across Canada. In 2024, non-alcoholic beverage producers directly supported 16,376 full-time equivalent jobs and supported 29,329 jobs through indirect and induced impacts. This is equivalent to 1.8 additional jobs for every direct jobs. Total employment supported by the sector spans every province, with the sector primarily located in Ontario, Quebec and British Columbia due to industrial infrastructure, proximity to major markets and efficient transportation activities. Employment also reflects the presence of bottling and processing facilities designed to serve both domestic and critical export markets.
Summary of key recommendations
The CBA strongly supports the renewal and modernization of the CUSMA as an essential foundation for maintaining North American competitiveness and supply chain resilience. To ensure that CUSMA continues to support a competitive and resilient beverage sector, the CBA recommends that the Government of Canada:
- Preserve tariff-free trade for beverage ingredients, packaging materials, and finished goods.
- Strengthen supply chain integration for critical manufacturing inputs such as aluminum and PET plastic.
- Maintain protections for intellectual property and trade secrets in beverage concentrates.
- Ensure regulatory consistency across North America by reviewing domestic measures (e.g., Federal Plastics Registry) for potential trade barriers.
- Commit to a stable, predictable trade environment that supports investment, circular economy goals, and consumer affordability.
The non-alcoholic beverage industry in Canada benefits from North American free trade
The Canadian Beverage Association and its members support free trade between Canada, The United States, and Mexico. We support the Government of Canada’s stated commitment to strengthen and deepen relationships within the North American free trade framework to build North American competitiveness and prosperity. We join others, such as the Canadian Chamber of Commerce, in asking the Government of Canada to prioritize the continuity of the current Agreement and its existing provisions while implementing measures to strengthen the Agreement to enhance economic success. For CBA members, CUSMA supports competitiveness and prosperity in several important categories:
Strategic Ingredients and Intellectual Property
Strategic ingredients for beverages, including beverage concentrates that hold valuable IP and trade secret content, move across the border to be manufactured into finished goods. In this system, small volumes of valuable concentrate are distributed to a larger system of bottler organizations manufacturing and distributing finished product in Canada. This reduces the cost to transport heavy finished goods to market and provides revenue back to the concentrate manufacturer, ensuring consistency of product throughout North America.
We support the continued inclusion of food ingredients in CUSMA as a strong commitment to supporting Canada food production and securing valuable North American supply chains. Without this framework, Canadian manufacturers would seek ingredient inputs outside of North America.
Packaging Material
The non-alcoholic beverage sector is dependent on imported packaging materials, most notably aluminum cans and plastic bottles. In 2024, 93.8 percent of imported bottles and 71.8 percent of imported aluminum beverage cans came from the United States (Conference Board of Canada, 2025).
Aluminum and PET plastic container manufacturing is an integrated supply chain throughout North America, and we recommend that CUSMA reflects this strategic relationship with stronger protections for food manufacturing inputs. For aluminum, US rolling mills rely on a mix of imported and domestic primary and recycled aluminum to manufacture can sheet, which is then used to produce aluminum cans of various sizes for the North American market. While Canada is the world’s fourth-largest primary aluminum producer, most beverage can sheet is imported from the United States. Furthermore, domestic can manufacturers only produce 355ml cans, leaving other sizes, such as the popular 473ml format, unavailable from Canadian sources.
CBA members are invested in increased recycled content in packaging and is reliant on a North American supply chain. For PET plastic, Canadian recovery operations sell material into a North American market where recyclers process recovered PET plastic into recycled food grade PET plastic (rPET). The rPET supply chain for food packaging is dependent on feedstock sourced outside of Canada and supports product packaging for highly circular beverage containers and sustains Canadians year-round access to foods such as fruits and vegetables. Canada has a high ambition to increase recycled content in packaging, however added costs and reduced efficiency in this supply chain would lead to increased reliance on virgin plastic material to mitigate increased food cost pressure.
Finished Goods
We recommend continued inclusion of finished goods in CUSMA as tariff free trade provides predictability and enhances competitiveness in the beverage sector. Manufacturing facilities in Canada and the US benefit from free trade with more efficient line planning and manufacturing to scale which ultimately supplies competitive choice for consumers. For example, certain package sizes or flavours may be optimized in a facility, making it more efficient to incorporate transborder manufacturing in demand planning rather than producing exclusively for domestic consumption.
Canada should limit non-tariff barriers to trade to promote competitiveness and prosperity
We were pleased to see Canada eliminate the regulatory barrier that restricted the manufacturing of product that contains plastic straws in Canada for sale in the US, which hurts Canadian competitiveness in manufacturing. Canada should also review the Zero Plastic Waste initiative, particularly the Federal Plastics Registry (FPR), in the context of a barrier to trade as it represents a burdensome regulatory requirement for domestic and North American food producers. Phase 2 of the FPR should not begin until Phase 1 can demonstrate high quality, reliable data production and success against the policy and regulatory goals. CBA members are actively investing in packaging innovation, collection, and recycling initiatives that contribute to Canada’s circular economy objectives. A harmonized North American regulatory approach would accelerate progress on recycled content targets while maintaining competitiveness.
Conclusion
To recap, CUSMA plays a vital role in supporting the competitiveness, resilience, and sustainability of Canada’s non-alcoholic beverage industry. The CBA urges the Government of Canada to:
- Maintain tariff-free trade in beverage ingredients, packaging materials, and finished goods;
- Bolster supply chain connectivity for critical manufacturing materials like aluminum and PET plastic.
- Promote regulatory alignment and avoid duplicative reporting frameworks;
- Protect intellectual property and innovation within the North American beverage ecosystem; and
- Preserve predictability and stability to attract investment, protect jobs, and enhance consumer affordability.
We look forward to working with Global Affairs Canada and other federal partners to strengthen CUSMA and ensure that Canadian beverage producers remain integral to a thriving North American economy.