Country of Origin on Fish with Substantial Transformation

Hello everyone 

Good Day 

We are fish processing industry. In smelt case,I am looking for updated guidance and insight for  following conditions: In all the scenarios mentioned below, the smelt is caught in Canadian waters, beheaded and dressed in China and brought back to Canada. Also, all battering mentioned  in Scenarios 5,6, 7 & 8 is done in Canada.

Scenario 1: H & D bulk smelt ( intended for Canadian sales) 

Scenario 2: H & D retail smelt ( intended for Canadian sales) 

Scenario 3: H & D bulk smelt ( intended for US sales) 

Scenario 4: H & D retail smelt ( intended for US sales)

Scenario 5: H & D battered bulk smelt ( intended for Canadian sales) 

Scenario 6: H & D battered retail smelt ( intended for Canadian sales) 

Scenario 7: H & D battered bulk smelt ( intended for US sales) 

Scenario 8: H & D battered retail smelt ( intended for US sales)

I want to know country of origin in above condition.

please share if you have any link.

Thank you.

I doubt very much just battering would be considered a "substantive transformation" as per CFIA

"A substantial transformation occurs when a food product undergoes processing which changes its nature and becomes a new product bearing a new name commonly understood by the consumer.May 28, 2019"

https://inspection.c...by the consumer.

P.S.: the large national brand has recently starting putting product of china on some boxes

P.P.S:  there are a lot of us who will not buy food from China, particularly not when it's our fish, caught here, and then travels across the pacific twice 

I used to eat smelt by the handful in port Stanley Ontario when caught fresh out of lake erie..............i miss that

Thank you Scampi

Smelt is popular here too. country of origin is voluntary in some of above mentioned cases, so little confused. 

The reference to "voluntarily"  is for DOMESTIC fish only

For prepackaged fish (definition) imported into Canada, the name of the country of origin must be clearly identified on the label [266, SFCR]. The wording "Product of" / "produit de" is recommended to help clearly identify the name of the country of origin.

For imported prepackaged fish, the country of origin is the country where the last substantial transformation occurred.

For domestic products, a country of origin declaration is not required but may be provided voluntarily.