never mind, I have a much better idea....
I will call NRCAN, and the CFO and get the answer from them and if they don't have the answer, then they can at least give me the place to get the answer from
A couple years ago I had direct correspondence with Chris Watson, Director and Chief Inspector of Explosives, NRCAN. He obtained a legal opinion on behalf of NRCAN.
You can legally GIVE away reloads, provided it is truly giving them away. However any other type of transaction, (they give you the components, etc) reloading for someone is illegal unless you have a manufacturers licence.
Because NRCAN obtained a legal opinion in order to answer my query, I consider this to be the definitive answer. Of course anyone call call around endlessly until they get the answer they want to hear.........
That said, you are legally fully liable for your own reloads that you might give away, or even sell illegally, as you are considered the manufacturer, and PERSONALLY take on full liability/responsibility. Adding to that, if you reload for someone without a manufacturer's licence, then you are committing an illegal act, and as such your personal liability insurance is void (you are committed an illegal act), meaning all your personal assets, (house, car, guns, etc) are on the line.