Selling maple syrup in Quebec

Three layers. (1) MAPAQ permit: Quebec's Food Products Act requires a permit to operate a place where food is prepared for retail sale (P-29, s. 9(m)), but the Regulation respecting food exempts "the agricultural producer ... who prepares maple products ... exclusively from his operation and sells them at retail on the site of his operation" (P-29, r. 1, s. 1.3.5.B.5, translated); Québec.ca says a business holding a ministerial identification number (NIM) as an agricultural operator "can sell its pure maple products ... without holding a permit", while processed maple products (maple-sugar pies, maple caramels) need the retail sale permit. (2) Quota: the Plan conjoint des producteurs acéricoles du Québec (M-35.1, r. 19) covers maple water, concentrate and syrup produced in Quebec but "does not apply to maple syrup produced in a producer's sugarbush and sold by that producer directly to the consumer" (s. 3); anyone covered must hold a quota issued by the Producteurs et productrices acéricoles du Québec (PPAQ) under the quota regulation in force since September 15, 2021 (M-35.1, r. 8.1, s. 2), and nothing in that regulation stops a quota holder from selling syrup from its own sugarbush "in small containers directly to a consumer" — small meaning at most 5 litres and at most 5 kg (s. 3). PPAQ states plainly: a producer who sells all of his or her syrup directly to consumers "does not need to hold maple quota"; sales through an intermediary — grocery, convenience store, market stall reseller, restaurant, bakery, institution, corporate gifts — require quota, even in small containers. (3) Bulk: syrup marketed in containers over 5 litres or 5 kg must be sold through PPAQ, "the exclusive sales agent of producers" (M-35.1, r. 7, ss. 1–3), to PPAQ or an authorized buyer, after independent inspection and grading. Shipping out of Quebec also requires the federal SFC licence (see the national notes).

Quebec's food regulation defines a sugarbush operator as someone who makes maple products "either on the site of the sugarbush or in the premises of his residence, farm buildings or their outbuildings" (P-29, r. 1, s. 8.1.1(c)), so producing at home is contemplated — but concentration of sap must take place inside a "cabane à sucre", the workshop where the operator concentrates sap or syrup (s. 8.2.1), and the operator's staff, premises and equipment must be clean (s. 8.2.2). Equipment for collecting, transporting and storing sap must be clean, free of corrosion, residue and mould and made of non-toxic materials (s. 8.2.3). The MAPAQ permit exemption for registered farms described above applies to pure maple products; value-added products take you into permit territory.

Grading is mandatory. Quebec recognizes two categories: "Catégorie A" (Grade A) — made exclusively by concentrating maple sap, clean and edible, free of off-odours, bud taste, fermentation and mould, with 66% to 68.9% soluble solids at 20 °C — and "Catégorie de transformation" (Processing Grade) at 66% or more (P-29, r. 1, ss. 8.4.0.1–8.4.1.1). Grade A syrup is also classed by colour by light transmission measured with a spectrophotometer at 560 nm (Schedule 8.B): Doré, goût délicat (Golden, Delicate) at 75.0% light transmission or more; Ambré, goût riche (Amber, Rich) 50.0–74.9%; Foncé, goût robuste (Dark, Robust) 25.0–49.9%; Très foncé, goût prononcé (Very Dark, Strong) under 25.0% (Schedules 8.A and 8.B). Syrup is classified by the sugarbush operator or manufacturer (s. 8.5.1). Only Grade A syrup may be sold at retail, and retail maple products must be in small containers of at most 5 litres or 5 kg (s. 8.6.1); Processing Grade must be kept in large containers marked "sirop d'érable — Catégorie de transformation" (ss. 8.6.5.1, 8.6.6). The 2016 amendments (O.C. 643-2016) aligned these classes with the federal and U.S. systems.

Syrup grades explained · check your density

• ✓On the main panel of every small container over 60 mL or 60 g: the product name ("sirop d'érable"), followed for syrup by its category designation and its colour class (P-29, r. 1, s. 8.7.1(a))
• ✓The exact net quantity in litres or kilograms — or in millilitres or grams if under 1 L or 1 kg (s. 8.7.1(b))
• ✓An indication of origin (s. 8.7.1(c))
• ✓The name and address of the sugarbush operator, manufacturer, preparer, packager, supplier or distributor (s. 8.7.1(d)); the origin and name/address may appear on a panel other than the main one
• ✓The colour class printed must match the class measured by spectrophotometer (s. 8.7.2); lettering must be indelible, legible and conspicuous per Schedule 8.C
• ✓Bulk syrup drawn into a consumer's own container may be sold from a large container that carries, or is accompanied by a document with, the product name, category, colour class and the operator's name and address (s. 8.6.1)
• ✓Federal Food and Drugs Act labelling (bilingual common name, metric net quantity, name and principal place of business) also applies in Quebec — see the national notes

Direct to consumers in containers of 5 L / 5 kg or less — from the sugarbush, at a public market, online, or served at your own sugar shack or restaurant — is outside the Plan conjoint and needs no quota; PPAQ's guidelines treat a producer's own commercial sugar shack and web or market sales as direct sales, as long as the syrup is for personal use and not resale. Quota holders who sell in small containers must file a register of those sales with PPAQ by January 15 each year (quota regulation, M-35.1, r. 8.1). Selling to anyone who resells, processes or distributes — stores, restaurants, bakeries, fundraisers, institutions, corporate gifts, even promotional giveaways — is a sale through an intermediary and requires quota. All syrup in containers over 5 L must be marketed through PPAQ's sales agency to PPAQ or an authorized buyer, under the marketing agreement approved by the Régie des marchés agricoles et alimentaires du Québec. The Régie, created by the Act respecting the marketing of agricultural, food and fish products (M-35.1, ss. 4–5), approves and can amend the Plan conjoint and the PPAQ's regulations (its Decision 12062 enacted the current quota regulation), and its mandate is "to promote efficient and orderly marketing" and resolve disputes; PPAQ administers the plan, quota, sales agency, inspection and the strategic reserve.

Sap must be concentrated inside a sugar shack; staff, premises and equipment must be clean; sap collection, transport and storage equipment must be clean, corrosion- and mould-free and made of non-toxic material; tools and utensils must be clean and in good condition (P-29, r. 1, ss. 8.2.1–8.2.4). Syrup must be filtered during preparation, and potable water may be added but no decolourizing, bleaching or refining process may be used (ss. 8.4.5–8.4.6). Small containers must be new and made of non-toxic materials and be filled to at least 90% of capacity (ss. 8.6.2–8.6.3); large containers must be clean, dry and hermetically closed, washed with hot water or steam and dried (s. 8.6.6). MAPAQ inspects under the Food Products Act, and PPAQ's bulk syrup is graded and checked for adulteration by an independent firm before sale.