If you are involved in the food business in Canada or exporting to Canada, then you need to be aware that the Canadian Food Inspection Agency (CFIA) is significantly increasing their inspection activities.
Having increased the use of its Enforcement Escalation Policy for food industry non-compliances and begun a regulatory licence inspection crackdown, the CFIA is ramping up further in a six-step action plan focused on increasing the effectiveness of risk management controls for manufactured foods. The actions will impact both Canadian food establishments as well as those which do business in or with Canada.
The actions are CFIA’s response to the 2024 Inspector General Review, conducted in follow up to the deadly Listeria outbreak at the now-closed plant-based milk facility which caused 20 confirmed illnesses and three deaths. With post-outbreak findings that CFIA’s risk-based inspection algorithm was faulty, allowing some plants to go without inspection for long periods based on self-calculated risk – including the Joriki plant that was associated with the Listeria outbreak which had not been visited by a CFIA inspector for five years, the CFIA action plan is intended to verify food facility regulatory compliance and also strengthen facility’s complaint review processes.
Following are the six action steps included in the plan:
- Inspect manufactured food establishments. The CFIA will conduct risk-based inspections of a sampling of the industry, completing inspections of over 2,400 manufactured food establishments by Fall 2026. The selected facilities will be those that are currently licensed but have not been inspected, with the depth of inspection based on facility/product risk. This sampling will also inform the future inspection frequencies for the whole manufactured food sector.
- Strengthen licensing conditions. A Safe Food for Canadians (SFC) licence is required for a food business to operate in, or import food into, Canada. As of October 2025, the previously accepted self-verification of lower-risk establishments is no longer recognized. Rather the CFIA will now review all new, amended, and renewal applications to ensure the information provided is complete, hazards have been identified, a Preventative Control Plan is in place where required, and a food safety culture is demonstrated by the applicant.
- Enhance risk intelligence. Similarly, the provision of certain information that was previously voluntary (i.e., the Additional Establishment Information questionnaire) is now mandatory for a business to be licensed. This is intended to ensure CFIA has all the needed information to conduct a comprehensive risk assessment and make more effective risk management decisions.
- Strengthen risk modelling. CFIA’s previous risk calculations that included only biological hazards now also include chemical hazards (e.g., pesticide, heavy metals, etc.). Additionally, complaint information will now be factored in, including data that indicates potential food safety concerns, historical and/or trend information. If you’ve not previously considered chemical hazards, or had an actionable complaint review system, now is the time to implement these.
- Increase stakeholder engagement and communications. To ensure the food industry understands and can meet the Safe Food for Canadians Regulations (SFCR), the CFIA will provide clear guidance and communications on the above points and its use of stronger enforcement action where warranted.
- Strengthen enforcement action. With the manufactured food sector brought in under the SFCR in 2021, with an initial emphasis on compliance promotion, the CFIA is escalating enforcement of the rules, including detention of product, licence suspension and cancellation, and the use of Administrative Monetary Penalties (AMPs) when warranted for regulatory violations.
TAG sees the takeaway as three-fold:
- Whether you are an existing facility or are submitting a new, amended, or renewal licence application – as a business in or doing business with Canada, ensure you are compliant with all licensing requirements, including hazard identification and mitigation, a Preventive Control Plan (if required), and demonstrated food safety culture.
- Be prepared to be intensively inspected. The longer it has been since your last inspection, the more likely it is that you are on the list.
- CFIA will take enforcement action. As the agency specifically states: “The stronger enforcement action sends a clear message to industry that the CFIA is serious about food safety and expects food businesses to meet the regulatory requirements of the SFCR.”
If CFIA has the resources to increase activity in the six ways described above the impact on the regulated industry in Canada or exporting to Canada is going to be significant. So step 1 is to check you are compliant with all the regulations pertaining to your organization as it relates to Canada.
TAG has resident food industry and regulatory experts in Canada to help you assess your compliance; implement food safety practices for mitigation; and protect your consumers, product, and brand. Contact us!
