Before July 2020, the United States had no dedicated chicken import quota into Canada. Zero. US exporters shared the global WTO quota with everyone else — 39,844 metric tonnes, split among all WTO member countries.
Then CUSMA came into force. And the math changed completely.
What CUSMA Replaced — and Why Poultry Was the Sticking Point
CUSMA — the Canada-United States-Mexico Agreement — replaced NAFTA on July 1, 2020. The negotiations were long. They were ugly. And poultry was one of the hardest sections to close.
Under NAFTA, Canada's supply management system for chicken was largely untouched. US chicken entered Canada through the WTO's global TRQ at zero tariff (a NAFTA preference), but there was no separate US-specific allocation. The volume was capped by what was available under the WTO quota, and that quota was shared.
The US wanted more. Specifically, the US wanted dedicated access to Canada's chicken market — access that wouldn't depend on competing with Thailand, Brazil, and every other WTO member for a slice of the global quota.
Canada gave it to them. Not because anyone in the Canadian poultry sector wanted to. Because trade agreements are package deals. Poultry concessions were the price for keeping auto sector rules of origin, maintaining dairy protections at a level Canada could live with, and getting the whole agreement across the finish line. Supply management survived — but it took a hit.
Here's the thing: the concessions weren't small.
The Numbers: How Much More US Chicken Canada Now Imports
CUSMA created a brand-new, US-specific Tariff Rate Quota on top of the existing WTO commitment. This wasn't a reallocation. It was additional volume.
The phase-in started at 47,000 metric tonnes in Year 1 (2021) and climbs by roughly 2,000 tonnes per year. By 2026 — this year — the CUSMA chicken TRQ sits at 57,570 metric tonnes. After Year 6, it grows at 1% annually through 2036.
Add in the CPTPP (Comprehensive and Progressive Agreement for Trans-Pacific Partnership), which opened another channel starting at 7,833 metric tonnes in 2019 and reaching 24,212 metric tonnes in 2026, and the combined picture looks like this:
- WTO global quota: 39,844 MT (unchanged)
- CUSMA US-specific: 57,570 MT (new since 2020)
- CPTPP: 24,212 MT (ramping up since 2019)
- Total 2026 import access: 121,626 MT
That's a 155% increase from pre-CUSMA levels. In 2019, total chicken import access was 47,677 metric tonnes. Now it's nearly 122,000. All three TRQ allocations for 2026 show zero kilograms remaining — meaning every bit of that quota has been claimed.
Against domestic production of roughly 1.4 billion kilograms, imports now represent about 13% of the Canadian market. Chicken Farmers of Canada puts it plainly: the country's 2,884 chicken producers have lost 11% of the domestic market to trade agreements.
The Spent Fowl Loophole Nobody's Talking About
The TRQ system has a hole in it. A big one.
Spent fowl — retired laying hens that have finished their egg-producing life — is not subject to Canada's chicken TRQ. It's not on the Import Control List. Under CUSMA, spent fowl from the US enters Canada duty-free, no quota required.
The problem? Broiler chicken is being imported and labeled as spent fowl to bypass import controls entirely. Broiler meat and spent fowl are difficult to distinguish visually, and some importers have figured out they can move commodity chicken across the border without touching the TRQ by simply calling it something else.
The scale is staggering. Between January and November 2025, Canada imported 105 million kilograms of chicken designated as "spent fowl" from the United States. Here's why that number doesn't add up: US total spent fowl production is only slightly higher than what Canada alone supposedly imported. Canada was absorbing 93% of America's entire spent fowl output. That's not a market — that's a labeling scheme.
The economic damage: an estimated 3,600 Canadian jobs displaced, $394 million in lost economic activity, and $129 million in lost tax revenue. A DNA test has been developed that can distinguish broiler from spent fowl at the molecular level. The Government of Canada committed to an action plan in March 2025. But enforcement has been slow, testing isn't mandatory at the border, and the loophole remains wide open.
This isn't a fringe issue. It's an enforcement failure that undermines the entire TRQ framework. You can negotiate tariff rates all day long, but they don't matter if product is crossing the border under the wrong label.
For domestic processors like Cheong Hing, this is the part of the trade picture that hits hardest. Not the TRQ volumes — those are known, planned for, baked into the system. It's the uncontrolled, mislabeled imports that undercut pricing without any of the regulatory guardrails.
Why Domestic Processors Adapted — Not Collapsed
The doom predictions haven't played out. Canadian chicken processing didn't collapse when CUSMA volumes ramped up. Here's why.
Most chicken that enters Canada under the TRQ is frozen commodity product — large-scale US broiler operations shipping further-processed or food-service-grade cuts. It competes on price. That's its only advantage.
Canadian processors compete on everything else. Fresh, never-frozen product with same-day or next-day delivery. Full traceability from Ontario farms to Ontario processors — supply management means every bird is tracked. Custom cuts and specifications that a frozen import can't match. CFIA oversight and Canadian food safety standards, including raised-without-certain-antibiotics programs.
The relationship model matters too. Ontario farmers selling to Ontario processors selling to Ontario restaurants and retailers. That's a supply chain you can drive in a morning. Try getting custom-portioned fresh chicken from a US commodity operation with a one-day turnaround. It doesn't work.
Actually, the US maintains over 80% of total Canadian chicken imports by volume. In 2024, Canada imported 208.7 million kilograms of chicken worth $899.5 million — with Thailand and Brazil picking up smaller shares. That import volume sounds enormous, but context matters: domestic production was 1.4 billion kilograms in the same year. The imports supplement the market. They don't dominate it.
The government also stepped in with compensation. The numbers are significant:
- $759 million through the Poultry and Egg On-Farm Investment Program
- $44 million through the Market Development Program for Turkey and Chicken
- $112 million in supplemental CUSMA-specific funding
- $25 million for CFC market development over 10 years
Total: roughly $940 million across poultry and egg sectors. That money went toward farm modernization, efficiency improvements, and market development — investments that made domestic producers more competitive, not less. It wasn't a bailout. It was retooling.
The bottom line: imports took 13% of the market. Domestic producers still hold 87%. And the fresh, local, traceable product that processors like us sell is a fundamentally different offering than frozen commodity imports. When a restaurant in the GTA needs custom-portioned chicken delivered tomorrow morning, they're not calling a US commodity operation. They're calling an Ontario processor.
The 2026 Review — What's at Stake
CUSMA has a built-in expiry mechanism. Article 34.7 requires a formal joint review by all three countries in Year 6 — which means by July 1, 2026. That's three months away.
If all three parties agree the deal is working, it gets extended 16 years to 2042, with the next review in 2032. If any party objects, the agreement enters annual reviews for the rest of its term and expires in 2036 if never extended. It's a sunset clause designed to force periodic renegotiation.
For poultry, the stakes are straightforward. The United States wants expanded agricultural market access — specifically, more room in supply-managed sectors. The US has pushed this position in every trade negotiation with Canada for decades. CUSMA got them a dedicated chicken quota where none existed before. They want more.
Canada's position, under Prime Minister Carney, is that supply management is "off the table." And that position now has legal teeth. Bill C-202, which received royal assent on June 26, 2025, legally prohibits the trade minister from increasing TRQs for dairy, poultry, or eggs in future negotiations. It also bars any reduction to over-quota tariffs. This was the successor to Bill C-282, which died when Parliament was prorogued in January 2025 — the government brought it back and got it passed within months.
But legislation can be repealed. And trade negotiations are about leverage.
The risks are real. The spent fowl loophole could become a US bargaining chip — either fix it (which tightens enforcement against US exports) or we want concessions elsewhere. Broader US-Canada trade tensions over tariffs, auto sector rules, and cultural protections complicate the picture. Farm groups themselves are divided: supply-managed sectors support Bill C-202 absolutely, while export-oriented agriculture worries about US retaliation.
Canada's chicken export profile adds context. In 2024, Canada exported 119.9 million kilograms of chicken worth $883.9 million to over 45 countries — the US, Philippines, and Ghana being the top markets. Canada runs a slight trade deficit on chicken (imports of $899.5 million versus exports of $883.9 million). The country isn't a major chicken exporter. The system was designed for domestic sufficiency, and that's what it delivers.
The July 2026 review won't happen in a vacuum. It'll happen alongside every other trade friction point between the two countries. Chicken is a small line item in a massive agreement, but for the 2,884 Canadian chicken producers, 191 processors, and over 112,000 workers across the supply chain, it's the line item that determines whether the domestic pricing mechanism stays intact.
The review won't be simple. It won't be quick. And the outcome will shape the Canadian chicken industry for the next decade or more.
Three months. That's what we're watching.