Interestingly, the term import is not specifically defined in the Safe Food for Canadians Act (SFCA) nor its regulations (SFCR). But that does not mean that imports are not regulated. Rather, in general terms, import simply refers to bringing food into the country from a foreign state – by a domestic or foreign entity. To meet Canada’s requirements for importing food and maintaining licence to do so, the Canadian Food Inspection Agency developed a 10-step guide to importing food.

In this two-part series, TAG Canada provides a synopsis of the 10 steps and some further perspective and recommendations. Following is the first article of the series focused on seven key steps to follow before you can begin to import. The next article will discuss import and post-import guidance.

Before You Import

1. Know your food and its hazards. Knowing everything about the food you are importing is not only necessary to complete the required forms, but to ensure it is safe for Canadians. This means having an understanding of the food itself, the hazards to which can be subject, the supply chain through which it is attained, and the process it will undergo once imported. Understanding the foods enables you to identify the hazards reasonably expected to occur – and to take the necessary actions to prevent, eliminate, or reduce those to a safe level. The hazards may be innate to the food itself or may occur through its supply chain, so it is critical to know the food’s source and the handlers and processes to which it was subject before arriving in Canada, and to work with the foreign supplier to address potential hazards.
   • Knowing the process and labeling the food will undergo once in Canada is also critical, as foods with different post-import processes have different SFCR requirements. Thus, under the SFCR the supply chain includes anyone who manufactures, prepares, stores, packages or labels the food before it comes to Canada, and must consider what is to happen to it afterward.
2. Understand Canada’s Food Import requirements. Canada has three categories of requirements related to food imports (all of which are further detailed in subsequent steps):
   • The Food must meet general food safety requirements such as having been manufactured, prepared, stored, packaged and labelled under sanitary conditions. You also must be familiar with applicable requirements related to standards, grades, net quantity and labelling, along with any other regulations to which the particular food is subject, such as the Food and Drug Regulations, Health of Animals Regulations and the Plant Protection Regulations and other government departments that regulate the import of food.
   • The Importer must create, implement and maintain a PCP, develop recall and complaints procedures, have a licence to import, ensure that the imported food has been prepared under similar conditions as food prepared in Canada, and keep traceability records.
   • The Procedure must follow that which is required to import food into Canada.
3. Select an appropriate foreign supplier. Under the SFCR, you are responsible for ensuring that your foreign supplier is aware of Canadian food safety requirements; is manufacturing, preparing, storing, packaging or labelling the food under the same conditions required in Canada; and is willing and able to provide you with the information you need to demonstrate food safety controls are in place. The information you need will vary based on the food being imported, the types of activities or processes to which the food is subject before import, and whether the foreign supplier is subject to any existing oversight measures.
   • CFIA categorizes three types of foreign supplier and how they affect the documentation you need to include in your PCP:
     • Foreign supplier in a country that CFIA has a recognition arrangement with and the food to be imported is part of the arrangement. That recognition can be a foreign food safety systems recognition; commodity-specific recognition; or recognition of systems of inspection as a pre-requisite to trade; or, for meat or shellfish, an approved establishment in a country with an approved inspection system. For these, the importer must confirm and keep documented evidence that the food is part of the arrangement and that the foreign supplier(s) is subject to the oversight of the foreign government and is in good standing within the recognized system. For meat and shellfish, you must regularly confirm that the country and establishment are still approved and document that verification activity.
     • Foreign supplier that is part of an internationally recognized third-party certification program and the food is subject to the program. For these suppliers, you must ensure that the elements of the food safety recognition program address all the applicable preventive controls or obtain documentation from the supplier on how the preventive controls are addressed, and confirm and keep documented evidence that the foreign supplier is in good standing with the certification program, such as the written results of a recent audit, etc.
     • Foreign supplier that is not subject to either of these oversights, such as suppliers subject to private, company-specific auditing programs or certification standards. For these foods, you will need to identify each of the controls that apply to the food you intend to import and obtain written confirmation that these controls are being implemented effectively. The SFCR does not specify how you must confirm this, but it could be through on-site foreign supplier visits to observe the effectiveness of controls, or by obtaining written documentation that demonstrates that the relevant control measures are being implemented effectively. Documentation is to include: the name, address and contact information of the person who developed the process and implements the preventive controls; a product and process description with technical information demonstrating that the product was adequately processed and that the preventive controls were adequately implemented to address the hazards most likely to occur in the food; and a written statement signed by the process authority or technically competent person attesting that the described process will produce a food that meets Canadian requirements.

4. Create and implement a Preventive Control Plan (PCP). The PCP is a written document that outlines the measures and controls taken to ensure the food you are importing is safe and fit for human consumption and complies with Canadian requirements. It is required to attain an import licence. If you conduct other food-related activities (such as manufacturing, preparing, packaging or labelling food in Canada that will be exported or sent between provinces), your licence and PCP may have to cover these activities as well.
5. Develop complaints and recall procedures before applying for your import licence. The complaints procedure is a written document describing how you receive, investigate and respond to complaints in a timely and consistent manner. It is important because a complaint could indicate an issue with food safety controls applied by the foreign supplier, during distribution or in handling of the food. To prepare for a potential recall, you are required to create a written recall procedure that describes how the recall will be conducted, the name of the person who is responsible for maintaining the procedure, and the name of the person who is responsible for conducting the recall.

Once you have successfully undertaken these five steps, you are ready to apply for your import licence – which we will cover in the next article in this series, along with providing shipment information to CFIA, and maintaining/implementing the post-import traceability records, preventive control plan, and recall and complaints procedure.

Even with a step-by-step plan, importing food into Canada is a complex undertaking. More detailed information and links are available on the CFIA page, but for more customized assistance and recommendations, give TAG Canada a call – We can help!