EVERYTHING YOU NEED TO KNOW ABOUT SFCR
AS A FOOD IMPORTER / EXPORTER (ALMOST!)
PART TWO OF TWO:
Licensing, Traceability, Preventive Controls,
and Food Sector-Specific Changes
The
Safe Foods for Canadians Regulation
(SFCR)
EVERYTHING YOU NEED TO KNOW ABOUT SFCR
AS A FOOD IMPORTER / EXPORTER (ALMOST!)
PART TWO OF TWO:
Licensing, Traceability, Preventive Controls,
and Food Sector-Specific Changes
The
Safe Foods for Canadians Regulation
(SFCR)
1
Click here to view Everything You Need to Know About SFCR As a Food Importer (Almost!):
Part One: Safe Foods for Canadians 101: The Basics
3 Things to Know About
CFIA, SFCR,
Licensing
1
2
3
CFIA Process
The process for moving shipments across the border will be similar to pre-SFCR;
Other than the SFCR import licence number, information required pre-SFCR with each shipment will be the same
CFIA Inspections
The new licence requirement is not expected to increase the number of shipments stopped for inspection
CFIA Focus
Inspection activity pre- and post-border will focus on highest-risk areas
and the
Import
Process
Canada Border Services Agency and CFIA will continue to be close partners.
Together, they'll keep using CFIA's
National Import Service Centre to process data and documentation and communicate release decisions on food shipments
CBSA + CFIA
+ National Import Service Centre
Just like today, you and your
customs broker should use AIRS
to figure out CFIA's specific
import requirements for
regulated commodities
Automated Import Reference System (AIRS)
What's AIRS? Click this block to explore!
You will need a licence if you/your food business:
You will NOT need a licence if you/your food business:
Licensing
Already Have
a CFIA Licence?
Your existing CFIA registration or licence is valid with SFCR;
If it expires before January 15, 2019, renew as normal, and you'll be transitioned fully once SFCR comes into force
For domestic food businesses:
One licence per establishment
For importers:
Flexibility for single or multiple licences, based on food commodity or number of establishments identified in the licence
How Many
Licences Required?
Your current licence / registration (e.g., for meat) can be used as your import licence until it expires; you must replace it with an SFCR licence going forward
Already Have a
Different Licence?
CFIA will monitor licensing starting January 15, 2019, but otherwise safe and compliant shipments without a valid SFCR licence will not be rejected during the transition period
What Happens as Businesses Transition?
Licensing
Under the Safe Foods for Canadians Regulation, all licence holders will need to be able to track the movement of a food product through the supply chain:
Traceability
One
step forward...
...and
one step
back
Exceptions:
If you're a grocery store, bakery, butchery, or other food retailer, you're only responsible for tracing food one step back to your suppliers—not forward to the consumer
Retailers
If you're a restaurant or similar enterprise (e.g., a food truck), traceability requirements
do not apply to you
Restaurants
Being able to remove unsafe food from the market quickly isn't just good PR, or simple rule-following under SFCR. When you can trace one step back and one step forward, you could save lives. Literally. How? By being able to access the information you need quickly, and communicate it to those who need to know
Why trace?
(Other than because
it's the new rule?)
?
Licensing
Your traceability documents must:
Your food business will need to create and keep traceability documents to make the SFCR-required one-step-forward and one-step-back tracking possible.
Whether you keep them in analogue or digital form, they'll need to include the following:
What do you need to track?
Identity of the food
1
2
3
One step back
One step forward
4
Ingredients
5
Food animals
No matter which food sector you're in, where in the world your food product was prepared, or how big your business*, Safe Foods for Canadians Regulation will require your business to have preventive controls in place.
Preventive controls help prevent food safety hazards and lower the chances of contaminated food entering the market. SFCR brings Canada's food safety rules in line with international best practices, and consistent with our major trading partners (which makes importing and exporting easier for everyone!).
Under SFCR, preventive controls are designed to be outcomes-based wherever possible. That means there's room for flexibility and innovation to make them fit your business's operations, while keeping Canadians safe.
Preventive Controls
* Smaller businesses and some food sectors may have more time to prepare for the preventive controls requirement, and some sizes and sectors may not require a documented preventive control plan (PCP).
Keep scrolling to learn more about phased implementation and how it applies to your business!
See:
Canadian Food Inspection Agency, "Industry Resource: Key Preventive Safety Controls Infographic" for more details
Best practices for preventive controls cover:
In general, preventive controls apply to three key areas of your business:
your people, your premises (a.k.a., your facility, or your establishment),
and your procedures.
Preventive Controls 101
People
Premises
Procedures
Food hazard categories you'll need to control include:
Your food business will also need to identify food hazards—anything present
in food with the potential to harm someone by illness or injury—as part of
your preventive controls. And you'll need control measures to address
all hazards associated with your food product, process, and facility.
Biological Hazards
See:
Canadian Food Inspection Agency, "Industry Resource: Keeping Food Safe Infographic" for more details
Physical Hazards
Chemical Hazards
Because every food business—and every food facility—is unique, be sure to
check with CFIA for specific preventive control requirements as they apply to you:
inspection.gc.ca/safefood
click the link to go directly to the CFIA page about preventive controls
Most food businesses, no matter what their size, already have some level of preventive controls in place, and address food hazards as part of responsible business practices (and to comply with pre-SFCR regulations, too).
With SFCR, a documented Preventive Control Plan will be required for most food sectors and most food businesses (with some exceptions).
If you've already got a system for food safety and preventive controls, complying with the Preventive Control Plan requirement shouldn't be too big a leap.
Check with CFIA for specifics on what you may need to add to your plan, or to find a PCP template for documenting your preventive controls in line with SFCR.
Preventive Control Plans (PCP)
What's Changed?
(And What Stays the Same?)
Key Requirements by Food Sector:
How Do They Compare?
Importing
Before SFCR
vs
Importing
After SFCR
Meat Products
change
Inspections
CFIA will determine inspection frequency based on risk; inspections of every shipment of meat are no longer required
If inspection is required:
Food must be sent to a licence holder's establishment / an establishment that has a licence to store and handle meat for the purposes of inspection
(The process for identifying shipments for inspection and facility locations will stay the same)
Inspections
Every shipment of meat must be inspected by CFIA upon import
same
Approved countries
No change to this requirement
with SFCR
Approved countries
Meat products must come from countries with approved meat inspection systems and
approved establishments
same
Official documents
No change to this requirement
with SFCR
Official documents
All shipments of meat products must be accompanied by official documentation from the foreign country (e.g., Official Meat Inspection Certificate)
Fish and Seafood
same
Approved countries
No change to this requirement
with SFCR
Approved countries
Live and raw molluscan shellfish must come from countries with approved inspection systems and approved establishments
change
Importer types
All fish and seafood importers must meet the same Preventive Control Plan (PCP) and food safety requirements of SFCR
Importer types
Two types of fish and seafood importers—QMPi and Basic—have different Preventive Control Plan (PCP) and food safety requirements
change
Import notification
Fish Import Notifications are no longer required with SFCR
Instead:
Import transaction information
must be provided prior to or at the time of import. Importers are no longer allowed 48 hours after import to provide this information
Import notification
Fish and seafood importers required to file a Fish Import Notification
change
Inspection results
Product inspection results lists are no longer required to be sent to CFIA under SFCR
Inspection results
QMPi importers required to
send product inspection
results lists to CFIA
change
CFIA release notification
Unless CFIA identifies a shipment to be held, it can be cleared by CBSA at its final destination and moved into commerce. Importers no longer need to wait for CFIA release notification
CFIA release notification
Basic fish importers required to
wait for CFIA release notification
to clear customs with CBSA
Fresh Fruit and Vegetables
same
No change to this requirement
with SFCR (continue to confirm
with AIRS)
Specific restrictions
and requirements
Leafy greens from California, blackberries from Guatemala,
and cantaloupes from Mexico
have specific restrictions
and requirements
change
Import licence
All importers of fresh fruit and vegetables require an import licence with SFCR
Import licence
Import licence not required
for all importers of
fresh fruit and vegetables
same
Grade certificates
No change to this requirement
with SFCR (see SFCR Part 6)
Grade certificates
Apples, potatoes, and onions
require grade certificates
Specific restrictions
and requirements
Shell and Processed Egg Products
change
DRC membership
Membership with the Dispute Resolution Corporation (DRC)
will be mandatory with SFCR.
Your DRC membership
number must be included
on your declaration
DRC membership
Membership with the Dispute Resolution Corporation (DRC) not required for all importers of fresh fruit and vegetables
change
Import licence
All importers of shell eggs and processed egg products require an import licence with SFCR
Import licence
Import licence not required
for all importers of
shell eggs and processed
egg products
change
CFIA-approved establishments
Importers are responsible for ensuring foreign suppliers have at least the same food safety control levels required in Canada with SFCR. Shell and processed egg products no longer need to come from
CFIA-approved establishments
CFIA-approved establishments
Shell and processed
egg products
must come from
CFIA-approved
establishments
same
Official documents
No change to this requirement
with SFCR
Official documents
Shipments of shell eggs and processed egg products must be accompanied by a certificate issued by the appropriate authority in the country of export
Dairy Products
change
Cheese import licence
Your cheese import licence can be used until it expires. It will be replaced by the SFCR import licence when it's time for you to renew
Cheese import licence
All cheese imports require a
cheese import licence
change
Import declaration
With SFCR, import declarations will be phased out for dairy products. This information will be collected through the Integrated Import Declaration (IID), which is part of the Single Window Initiative (SWI) launching in April 2019
Import declaration
Import declaration required for all imports of dairy products
Easy and secure online access to CFIA services
Pay for your CFIA services
Apply for:
Licences, permits,
registrations and authorizations,
and export certificates
Track and manage your
CFIA service requests
Is your food business ready for SFCR, yet?
Sign up for a MyCFIA account
Remember:
SFCR comes into force
January 15, 2019
To avoid possible delays, we recommend you do NOT wait until January to sign up!
Got those within reach?
To sign up, you'll need:
2
Your Business Number
(or Proof of Business)
A Proof of Authority Form
(signed by the person in your Business Number's ownership information filed with Canada Revenue Agency)
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Still Have Questions?
Of course this two-part infographic can't give you the
exhaustive answers to everything about the
Safe Foods for Canadians Regulation—
that would put it in contention for the longest infographic ever!
has all the official answers...
...Including the entire Safe Foods for Canadians Regulation for your reading pleasure
(Or give your favourite customs broker a call for personalized service tailored to your food business' needs)
Questions?
CONTACT US
SOURCES:
www.aacb.com