Does accepting donations make me a manufacturer?

No, receiving donations does not make you a manufacturer, as long as those donations cover your actual costs rather than generate profit.

The CRA clarifies that "accepting donations without the intention of making a profit should not be considered to be a commercial activity" (Recital 15). This includes reasonable compensation or living expenses for individual developers.

When assessing whether donations exceed your costs, consider all revenue related to the project, not just one income stream. If total project-related income significantly exceeds the costs of designing, developing, and maintaining the software, this could indicate an intention to profit, which may bring you into scope. Since donations naturally fluctuate over time, a degree of flexibility applies—including considering the developer's broader financial situation.

Note that donations clearly linked to a service or benefit of equivalent value may not qualify as true donations—such arrangements could be viewed as commercial transactions.

For more on what counts as actual costs, see What does 'actual costs' mean under the CRA?. For how living expenses factor in, see Can a natural person's living expenses count as 'costs' or is that profit?. For broader monetisation questions, see Am I subject to the CRA if I earn a living from the open source project I maintain?.