Region/Countries: Canada, North America Industry: Food and Beverage Date: November 2018

Why this is important to Wisconsin businesses: Guidance for Wisconsin exporters in complying with these regulations

On Jan. 15, 2019, the Safe Food for Canadians Act (SFCA) and the Safe Food for Canadians Regulations (SFCR) will take effect. The SFCA was passed into law in Canada in 2012 and establishes a modern legislative framework for the safety of food commodities. The SFCR and the SFCA cover imported, exported and inter-provincially traded food products. Similar to the U.S. Food Safety Modernization Act (FSMA), the SFCA modernizes food safety. The SFCR comprises 16 regulations that set the framework for the SFCA.

The three guiding pillars of the regulations include licensing, a preventative control plan (PCP), and traceability requirements.  U.S. food manufacturers can begin the licensing process by creating a "MY CFIA" account, which is a guidance tool to help them determine which of the 16 regulations are applicable to their food activities. Businesses exporting, importing or distributing food products will need a license. Valid for two years, the license will cost approximately $268 Canadian dollars (CAD), including GST. Non-resident importers are eligible for licensing. The Canadian Food Inspection Agency (CFIA) is not requiring manufactures to post license numbers on food labels. The CFIA recommends that food businesses with multiple locations have multiple licenses. U.S. food manufacturers will need to obtain a license even if they are FSMA compliant. Licenses will not lapse due to inactivity.

The preventative controls within the regulations are based on the CODEX Principles of Food Hygiene. The CFIA will consider a Global Food Safety Initiative (GFSI) certification, but by law, manufacturers must comply with the SFCR and have a PCP. The PCP interactive tools and templates will be available via a MY CFIA account. There will be no requirement to submit a PCP at time of license application (but companies must have one in place and meet all requirements).

Manufacturers may use PCP approaches that have been developed by other food safety authorities, industry associations, international partners or academic institutions, and should always ensure that the information in the PCP is tailored for individual business, food and market requirements. Each company is responsible for ensuring that its written PCP meets the requirements of the SFCR.

Traceability requirements include a “one step back and one step forward” approach. Manufacturers will have to maintain clear and complete traceability records that show from whom the food was obtained and to whom it was sent. The traceability requirements will include a mandatory recall plan written in English and French that is made available to CFIA for a period of two to three years.