Thank you for the opportunity to appear before you today on behalf of the Canadian Association of Moldmakers and our members.
CAMM represents Canadian mould-makers and a broader network of tooling, machining, automation and advanced manufacturing firms that support production across Canada and North America. I'm here today because the current U.S. tariff environment, particularly section 232, presents a serious and immediate concern for our sector and for Canada's manufacturing competitiveness.
Our industry may not always be visible to the public, but it is foundational to modern manufacturing. Moulds, dies, fixtures and other precision tooling are the production tools required to manufacture products in automotive, aerospace, medical devices, packaging, consumer goods, construction materials and industrial equipment. Without tooling, manufacturing programs do not launch, production lines do not run and supply chains slow down.
This is also an industry of real scale. Canadian mould-making exports approximately $7 billion annually to the United States. Approximately 75% of Canadian mould-making is in Ontario, within which Windsor-Essex is home to the largest cluster of mould-makers in North America, exporting $2.4 billion annually.
This sector is also deeply tied to cross-border trade. When we discuss mould-making and related tooling, we are not discussing a niche issue. We are discussing a critical enabling industry that supports downstream manufacturing on both sides of the border. Our supply chains are deeply integrated and reliant on each other. We are manufacturing partners, and the issue before you today is not theoretical. Commercial decisions are being made now. Projects are being quoted now, and customers are deciding where future tooling programs will go now. Canadian firms are evaluating whether they need a U.S. operating footprint simply to remain competitive, and this is why urgency matters.
A central concern for our members is that current tariff treatment does not reflect the true nature of these products. The value of a mould is not simply the steel it contains. Its value comes from engineering, design, CNC machining, software, polishing, testing, project management and highly skilled tradespeople developed over decades. When tariffs are applied to the full finished product value rather than the steel content alone, they disproportionately penalize value-added manufacturing activity. That creates a structural disadvantage for Canadian firms competing in an integrated North American market.
There is also significant uncertainty in administration and compliance. Even experienced customs brokers are reporting confusion regarding classifications, documentation requirements and treatment of certain products. Many small and medium-sized companies do not have the internal resources to manage rapidly changing and highly technical border requirements. That uncertainty becomes a cost in itself.
I would also note that moulds and dies are closely related industrial tooling categories. They often serve the same customers, use similar materials, rely on the same skilled trades and are manufactured using many of the same advanced processes. Where different treatment exists between closely related tooling sectors, it would be appropriate to review whether policy is aligned with the industrial reality.
At the same time, Canada is not the source of the problem these measures were intended to address. Canada is a trusted ally, a CUSMA partner and part of an integrated manufacturing economy. Many Canadian firms purchase U.S. steel, components, coatings, software and services. Likewise, many U.S. manufacturers rely on Canadian tooling capacity for quality, speed, engineering, expertise and responsiveness. Weakening this relationship does not strengthen North America; it weakens it. It also risks driving sourcing and investment towards offshore competitors outside of our continent.
Our members are looking for continued and urgent engagement with U.S. counterparts regarding section 232 treatment of moulds, tooling and other value-added manufactured products. There is also a strong need to pursue exemptions or revised treatment where products are clearly part of the integrated North American supply chain. It is also important that closely related tooling sectors, including moulds and dies, are treated consistently where their manufacturing processes, materials and end uses substantially overlap.
Finally, if resolution timelines extend, temporary domestic support measures would help viable Canadian firms manage current uncertainty while longer-term solutions are pursued.
Members of the committee, this is about more than tariffs. It is about whether Canada retains specialized industrial capability developed over generations. If capacity leaves, if investment pauses or if skilled people exit the sector, recovery will be difficult, costly and slow. We have the opportunity to respond now, strategically and in partnership with industry.
Thank you.