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Safe Foods for Canadians Regulation: Infographic: Everything You Need to Know About SFCR as a Food Importer/Exporter (Almost!)

Canada's food safety system levels up January 15, 2019. Will your food business be ready?

Rolling 14 regulations into one is no small feat.

Figuring out how all those changes will impact your food business on your own?
That’s the stuff epic tales of labyrinthine misadventure are made from.

Your business doesn’t have that kind of time to spare. That’s why we’ve distilled the need-to-know essentials of the Safe Foods For Canadians Regulation into an easy-to-read, two-part infographic. It translates all that complexity into knowledge your food business can use.

  • For a high-level, guided tour of the 101-level basics of the Safe Foods for Canadians Regulation (SFCR), check out Part One of our infographic.
  • To start navigating your food import / export business through SFCR’s three pillars of licensing, traceability, and preventive controls—and explore food sector-specific changes—read Part Two.
  • To download a PDF of our all-in-one Everything You Need to Know About SFCR as a Food Importer/Exporter (Almost) infographic, head to the bottom of this page.

Part One of Two

Part Two of Two

All-in-One PDF (with BONUS timeline) – (14MB)

EVERYTHING YOU NEED TO KNOW AS A FOOD IMPORTER / EXPORTER (ALMOST) The Safe Foods for Canadians Regulation (SFCR) What is the Safe Foods for Canadians Regulation? Canada's food safety system is getting a 21st century upgrade. Safe Foods for Canadians Regulation (SFCR) is a science-based improvement that modernizes how we approach and regulate food safety.   SFCR gives Canadians a strong, world-class regulatory foundation that's focused on risk management through three pillars: licensing, traceability, and preventive controls. SFCR Fun Facts: 14 The number of other food regulations SFCR will replace 1 - 2.5 The range of years phased implementation may apply, based on food sector and business size CODEX The International Food Standard SFCR will apply to all food imported, exported, or traded interprovincially Does SFCR Apply to You? If you're a food business that imports or prepares food for export, or ships food across provincial or territorial borders, YES! ...but when? January 15, 2019 That's when the Safe Foods for Canadians Act (SFCA) and Safe Foods for Canadians Regulation (SFCR) come into effect for food businesses in the following sectors: - Meat Products Including beef, pork, poultry, and other meat products, as well as hunted game meat - Fish & Seafood Including fish, crustaceans, molluscs, and other aquatic invertebrates - Shell Eggs & Processed Egg Products Including birds' eggs in shell, as well as liquid whole eggs, egg whites, and egg yolks - Dairy Products Including milk, cream, cheese, curds, whey, butter, and yogurt - Processed Fruit or Vegetable Products Including dried, canned, juiced, cooked, pre-cut, and otherwise processed - Honey & Maple Products Including liquid, creamed, and comb honey, as well as maple syrup and maple sugar - Fresh Fruit & Vegetables Including all fresh fruit and fresh vegetables (not processed) Wait! What if your food business isn't on that list? Don't feel left out--non-registered food sectors have an extra year before SFCR applies! July 15, 2020 Safe Foods for Canadians Regulations come into effect for all remaining food business sectors: - Unprocessed food used as a grain, oil, pulse, sugar, or beverages - Food additives and alcoholic beverages - All other food What if you're a Non-Resident Importer? How will the Safe Foods for Canadians Regulation impact your food business? Non-Resident Importers (NRIs; importers who do not have a registered business in Canada) will be allowed to import under specific conditions: CFIA-Recognized Countries As an NRI, your business must be located in a country with a food safety system that Canadian Food Inspection Agency (CFIA) recognizes as equally protective of public health as food prepared in Canada. (For example, the USA, where the US Food and Drug Administration (FDA) and CFIA have a Food Safety System Recognition Arrangement) CFIA-Recognized Foods The specific food/s you're importing as an NRI are foods recognized by CFIA as safe. (Even if a food comes from a CFIA-recognized country, not all foods from that country will be CFIA-recognized) NRI-Responsible SFCR Compliance As an NRI, you hold a licence, and are responsible for making sure the food/s you're importing meet all the SFCR requirements that apply. (Even if those requirements don't apply in the country you're importing the food into Canada from) Visit http://www.inspection.gc.ca/safefood for more information on countries and foods CFIA recognizes as eligible to hold an import licence as an NRI. 3 Key Elements of SFCR The three-part path to stronger, more consistent and outcomes-based rules - Licensing Makes it possible to identify and oversee food businesses across all regulated food sectors - Traceability Improves ability to trace unsafe food back to the source and remove it from shelves faster - Preventive Controls Helps prevent food safety hazards and keep contaminated or otherwise unsafe food out of the market Licensing You will need a licence if you/your food business: - Processes, preserves, manufactures, treats, grades, packages, labels a food, or slaughters food animals for interprovincial trade or export - Imports a food - Exports a food that requires an export certificate Stores and handles imported meat products You will NOT need a licence if you/your food business: - Only manufactures or conducts other processing activities on food to be sold and consumed within your province - Only conducts activities associated with growing and harvesting fresh fruits or vegetables - Only handles fish on a conveyance and associated activities - Are / is a retail grocery store conducting food handling activities where the food is handled and sold on-site (e.g., packaging / labelling food for sale to consumers; rinsing fresh fruits or vegetables that are on display) 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 Already Have a Different Licence? 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 How Many Licences are Required? - 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 What Happens to Businesses in Transition? CFIA will monitor licencing starting January 15, 2019, but otherwise safe and compliant shipments without a valid SFCR licence will not be rejected during the transition period Traceability 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: - ONE STEP FORWARD and - ONE STEP BACK Exceptions: - Retailers 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 - Restaurants If you're a restaurant or similar enterprise (e.g., a food truck), traceability requirements do not apply to you Why trace? (Other than "because it's the new rule?") 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 What do you need to track? Your food business will need to create and keep traceability documents to make 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: 1. Identity of the food - Common name of the food - Name and address of person / company who manufactured, prepared, produced, stored, packaged, or labelled the food - Unique identifier (e.g., a lot code) 2. One step back - Name of person bought the food from - The date it was delivered to you 3. One step forward - Name of person you sold the food to - The date you delivered it to the person you sold the food to 4. Ingredients - If / when applicable, identify and trace the ingredients you use to make the food, using the standards in 1 and 2  5. Food animals - If applicable, identify and trace the food animals you slaughter Your traceability documents must: Be clear, readable, and if electronically stored, provided in a single file, in a format easily opened by standard commercial software Be kept and accessible in Canada for two years, and provided to CFIA upon request  Preventive Controls 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. * 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! Preventive Controls 101 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. Best practices for preventive controls cover: People - Food Handling and Safety Training  - Hygiene Practices - Health on the Job - Commitment to Food Safety Premises - Handling and Storage - Facility Maintenance - Equipment and Workflow - Sanitation and Pest Control Procedures - Complaint Investigation and Response Procedures - Recall Procedures See: Canadian Food Inspection Agency, "Industry Resource: Key Preventive Safety Controls Infographic" for more details: http://www.inspection.gc.ca/DAM/DAM-aboutcfia-sujetacia/STAGING/text-texte/regs_safe_food_inforgraphic_prevent_1431108931648_eng.pdf 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. Food hazard categories you'll need to control include: Biological Hazards - Bacteria - Viruses - Parasites - Anything that can cause foodborne illness Chemical Hazards - Food Allergens  - Cleaning Chemicals - Food Additives - Anything that can introduce an unwanted chemical to food Physical Hazards - Shells or Pits - Bone Chips - Personal Objects - Any unintentional or dangerous material that can end up in food See:  Canadian Food Inspection Agency, "Industry Resource: Keeping Food Safe Infographic" for more details http://www.inspection.gc.ca/DAM/DAM-aboutcfia-sujetacia/STAGING/text-texte/regs_safe_food_inforgraphic_hazards_1431107723281_eng.pdf 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: http://www.inspection.gc.ca/food/sfcr/general-food-requirements-and-guidance/preventive-controls-food-businesses/eng/1526472289805/1526472290070 Preventive Control Plans (PCP) 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.   http://www.inspection.gc.ca/food/sfcr/general-food-requirements-and-guidance/preventive-control-plans/eng/1512152894577/1512152952810 What if your food business is small?   Worried about how you'll navigate not just the licensing, but the traceability and preventive controls the way bigger businesses do? Don't panic!   Even if you fall into one of the January 2019 food sectors, smaller food businesses—as well as growers and harvesters of fresh fruits and vegetables—will have a little more time to comply with some of the more complex elements of SFCR. Check out this Phased Implementation chart to see if this applies to you:   ALL OTHER FOODS   Element Meat, Fish, Eggs, Processed Egg, Dairy, Processed Fruit or Vegetable Products, Honey, Maple Products Fresh Fruit and Vegetables >$100K and >5 employees >$100K and <5 employees =$100K  Licence Immediately Immediately +1.5 years +1.5 years +1.5 years Traceability Immediately   (+1 year for growers and harvesters of fresh fruits and vegetables)   +1.5 years +1.5 years +1.5 years   Preventive Controls   Immediately +1 year +1.5 years +2.5 years +2.5 years   Written Preventive Control Plan   Immediately +1 year +1.5 years +2.5 years Not required  Source:    Canadian Food Inspection Agency, "Phased Implementation by Sector and Business Size: Presentation to Canadian Society of Customs Brokers" August 23, 2018 3 Things to Know About CFIA, SFCR, Licensing and the Import Process 1. CFIA Inspections The new licence requirement is not expected to increase the number of shipments stopped for inspection 2. CFIA Focus Inspection activity pre- and post-border will focus on highest-risk areas 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 Automated Import Reference System (AIRS) Just like today, you and your customs broker should use AIRS to figure out CFIA's specific import requirements for regulated commodities http://airs-sari.inspection.gc.ca/airs_external/english/decisions-eng.aspx CBSA + CFIA + National Import Service Centre 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 Key Requirements by Food Sector: What's Changed? (And What Stays the Same?) Importing Before SFCR vs Importing After SFCR How Do They Compare? 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) Same: - Approved countries Meat products must come from countries with approved meat inspection systems and approved establishments - 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 Changes: - 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 - Importer types All fish and seafood importers must meet the same Preventive Control Plan  (PCP) and food safety requirements of SFCR - Inspection results Product inspection results lists are no longer required to be sent to CFIA under SFCR - 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 Same: - Approved countries Live and raw molluscan shellfish must come from countries with approved inspection systems and approved establishments Fresh Fruit and Vegetables Changes: - Import licence All importers of fresh fruit and vegetables require an import licence with SFCR - DRC membership Membership with the Dispute Resolution Corporation (DRC) will be mandatory with SFCR. Your DRC membership number must be included on your declaration Same: - Specific restrictions and requirements Leafy greens from California, blackberries from Guatemala, and cantaloupes from Mexico have specific restrictions and requirements (continue to confirm with AIRS) - Grade certificates Apples, potatoes, and onions require grade certificates Shell and Processed Egg Products Changes: - Import licence All importers of shell eggs and processed egg products require an import licence with SFCR - 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 Same: - 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 Changes: - 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 - 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 Your first step to getting your food business ready for SFCR? Sign up for a MyCFIA account. Sign up today for MyCFIA at http://www.inspection.gc.ca/about-the-cfia/my-cfia/eng/1482204298243/1482204318353 : - Easy and secure online access to CFIA services - Apply for licences, permits, registrations and authorizations, and export certificates - Track and manage your CFIA service requests - Pay for your CFIA services REMEMBER: SFCR COMES INTO FORCE JANUARY 15, 2019. To avoid possible delays, we recommend you DO NOT WAIT UNTIL JANUARY to sign up! To sign up, you'll need: 1. Your Business Number (or Proof of Business) 2. A Proof of Authority Form (signed by the person in your Business Number's ownership information filed with Canada Revenue Agency) Got those within reach? Click here to sign up for your MyCFIA account! http://www.inspection.gc.ca/about-the-cfia/my-cfia/eng/1482204298243/1482204318353 Of course, this infographic can't give you the exhaustive answer to everything about the Safe Foods for Canada Regulation--that would put it in contention for the longest infographic ever! Still have questions? inspection.gc.ca/safefood 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) A & A Contract Customs Brokers Questions? Contact Us: 120 176th Street, Surrey BC  Phone: 1.800.663.4270 Fax: 604.538.3994 aacb.com Sources: - Canadian Food Inspection Agency, "Safe Food For Canadians Regulations: Presentation to Canadian Society of Customs Brokers" August 23, 2018  - World Health Organization, Food and Agricultural Organizations of the United Nations, "CODEX Alimentarius: International Food Standards" sourced http://www.fao.org/fao-who-codexalimentarius/codex-texts/guidelines/en/ on September 21, 2018  - Canadian Food Inspection Agency, "Phased Implementation by Sector and Business Size: Safe Food For Canadians Regulations: Presentation to Canadian Society of Customs Brokers" August 23, 2018  - Canadian Food Inspection Agency, "Safe Food for Canadians Regulations: Main Page" sourced from inspection.gc.ca/safefood on September 18, 2018 - Canadian Food Inspection Agency, "The case for change: Safe Food for Canadians Regulations" sourced from http://www.inspection.gc.ca/food/sfcr/information-for-media-and-consumers/the-case-for-change/eng/1528486475315/1528825326618 on September 20, 2018 - Canadian Food Inspection Agency, "Traceability Fact Sheet" sourced from http://www.inspection.gc.ca/food/sfcr/toolkit-for-businesses/traceability/eng/1427310329573/1427310330167 on September 24, 2018 - Canadian Food Inspection Agency, "Industry Resource: Key Preventive Safety Controls Infographic" sourced from http://www.inspection.gc.ca/DAM/DAM-aboutcfia-sujetacia/STAGING/text-texte/regs_safe_food_inforgraphic_prevent_1431108931648_eng.pdf on September 24, 2018 - Canadian Food Inspection Agency, "Industry Resource: Categories of Hazards Infographic" sourced from http://www.inspection.gc.ca/DAM/DAM-aboutcfia-sujetacia/STAGING/text-texte/regs_safe_food_inforgraphic_hazards_1431107723281_eng.pdf on September 24, 2018  - Canadian Food Inspection Agency, "Industry Resource: Your Preventive Control Plan Infographic" sourced from http://www.inspection.gc.ca/DAM/DAM-aboutcfia-sujetacia/STAGING/text-texte/regs_safe_food_inforgraphic_plan_1431108346112_eng.pdf on September 27, 2018

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