Just an update on my efforts. Canada has declined to respond to any of my e-mail requests on what is required. This is not surprising, considering how much I needed to prod the USDA to get a response. That being said, actions speak louder than words.
I've been shipping to Canada until it got too cold (8 shipments this fall). The last shipment took 12 days, was opened, and was delivered anyway. The custom's form stated clearly what was in the box. The clutches (pure miracle) hatched anyway. Once they saw what was there, they figured it couldn't be worth taxing... You can draw your own conclusions. I don't know why they make it so hard to figure this stuff out.
If any of you can point me to the regs, I'd be gratefull. I'd do it right if there was a right way. Doesn't seem to be one.