Blog Post, Regulatory
FAQ’s – Ready for Regs
Let our experts tailor-make a food safety program that meets new regulations and fits your business” – and mention some food commodity categories, particularly those in the previously non-registered sector, as those importers will have the most questions.
July 2020 is the date when Canada’s new Safe Food for Canadians Regulations come fully into force.
- Have questions? Here are some that are most commonly asked.
- Need more? [email protected] can help you.
FAQ’s – Importers
I have seen different words for licences in Canada, including CFIA licence, SFCR licence, Registration, and SFC licence. Are these different licences that I must apply for?
No – they are different names for the same requirement. These names emerged as the licence process developed – the final official name is now “SFC Licence” where SFC stands for Safe Food for Canadians.
Need more? [email protected] can help you with this.
I import food in packaging ready for sale to consumers. Do I need a licence?
Yes
I import food in bulk quantities for packaging into consumer packages for consumers in Canada. Do I need a licence?
No
I import food for further processing, and it is clearly labelled, “For Further Preparation”. Do I need a licence?
No
Do I need to include what kinds of food I am importing under my import licence to import that food?
Yes
I would like to start importing a new food under my import licence. Can I change/update my licence to include the new food?
Yes, as long as the new food supplier meets Canada’s food safety requirements, and you have documentation/evidence that shows this to be true.
I import food additives. Is there anything I need to do to meet the new regulations?
Yes – you must have a working traceability system in place by July 2020, that includes written records of where the food additives were purchased, and where the food additives were sold/shipped in Canada, as well as a lot code identifier.
BUT:
- You do not require a licence.
- You do not require a preventive control program or preventive controls in place.
My import office is physically located in the United States. Can my US import office get an SFC licence?
Yes, because Canada and the US have an official mutually recognized comparable food safety program.
My import office is not in Canada nor is it in the USA. Can I get a SFC licence so that I can import food into Canada?
No. Importers must have an office in either Canada or the USA.
Why can’t the factory in a country other than Canada or the USA, where I get my goods from, get an SFC licence?
Currently only Canada and the USA have a mutually recognized comparable food safety systems requirements. This means that factories in any other country cannot act as a non-resident importer, nor can they get a SFC licence. This will change over time as Canada is likely to have such agreements in place with other countries.
How do I properly declare a Safe Food for Canadians licence number on food import declarations?
Enter your Importer’s Safe Food for Canadians (SFC) licence number in the Registration Number field of the import declaration exactly as was issued by the CFIA
- SFC licence numbers issued by the CFIA consist of a combination of eight (8) numbers and letters
- The licence number you enter must cover the activity of “Importing Food”, as well as the food commodity or commodities you are importing.
As a food importer, I understand that I need a licence. What do I need to have in place to get that licence?
- Written, effective preventive controls plan:
- Demonstrate how the foods you import meet Canada’s food safety requirements;
- Documents,
- Complaints and Recalls,
- Monitor, verify.
- Demonstrate how the foods you import meet Canada’s food safety requirements;
- Traceability records:
- Who you purchase from,
- Who you sell to,
- My CFIA account
I have applied for my licence; how long before I get it?
Usually licences are issued within 15 days, although some businesses have printable versions of their licence on the day of application. For some very new, novel, or high risk businesses, the Canadian Food Inspection Agency may conduct an inspection prior to issuing a licence which could delay obtaining the licence beyond the 15 days.
FAQ’s – Safe Food for Canadians Regulations Compliance
Has the pandemic affected the coming-into-force date for the Safe Food for Canadians Regulations?
The Canadian Food Inspection Agency has announced that the “CFIA will not prioritize compliance activities associated with the July 15, 2020 coming into force of the Safe Food for Canadians Regulations (SFCR) for the manufactured food sector.” And further importers of manufactured food will generally not encounter delays or disruptions in their imports simply because of not having a Safe Food for Canadians licence yet. Domestic manufacturers can continue to operate while they apply for a licence.
Why aren’t food additives regulated under the Safe Food for Canadians Regulations?
Other than traceability requirements, food additives manufacturers are currently exempt from the Preventive Controls Program requirements. The rationale for this exemption was that Health Canada reviews food additives for safety prior to adding a food additive to Canada’s lists of permitted additives.
It is speculated that this exemption may disappear under future phases of regulatory modernisation at the Canadian Food Inspection Agency because of the recognition that while the additive is safe, the premises where the additive is manufactured could have food safety deficiencies. It is also important to note that while not required to have a licence and a Preventive Control Program, it is possible to obtain a licence voluntarily. Some food processors who purchase food additives may make this a requirement for conducting business as an industry best practice.
I own a warehouse that may be used to just store food. Do I need a licence?
No. Stand-alone warehouses where no other activity other than storage takes place, do not need a licence.
Warehouses that are an integral part of a food processing facility would be licensed under the food facility’s licence.
That being said, you could obtain a licence voluntarily, but to do so you would need to meet the requirements under the Safe Food for Canadians Regulations, including a written Preventive Control Plan. Some food processors who use your facilities may make this a requirement for getting their business as an industry best practice.
I own a warehouse where some food may get repackaged to meet Canadian label regulations. This could include binding two cartons into a club pack, or making end displays for retail stores. Do I need a licence?
Yes. Under the new regulations, whenever food packaging changes occur that will affect traceability or could expose the food to chemical, physical, or biological risks, those changes are considered food processing and a licence is required.
How many licences do I need?
Depending on how your business runs, you may wish to have one licence that covers all your activities. The advantage to this – lower cost and less to keep track of. For more complex businesses with many different products or production facilities, the licence structure can be custom-tailored with multiple licences. This gives flexibility for some business units within a company to keep operating as normal, but it does add some cost and complexity to licence management.
July 2020 is the date when Canada’s new Safe Food for Canadians Regulations come fully into force
Have questions? Here are some that are most commonly asked.
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