In September’s FSMA Friday Webinar, TAG Vice President, Regulatory Affairs Cameron Prince discussed Importer Preventive Controls Under the Safe Food for Canadians Regulations (SFCR) – a critical topic for those who ship to Canada. U.S.-based companies can hold a Canadian SFCR import license, and it is the only country that has that privilege. This means that, as a U.S. food manufacturer or distributor, you can be the importer of record and be the main interface with the Canadian Food Inspection Agency (CFIA). But it is intended only for product manufactured in the U.S., not food you’ve imported from another country. Anyone who imports food to Canada has to have a license for which you must declare that you have an importer Preventer Control Plan (PCP) with a Supplier Approval Program, very similar to those outlined in FSMA and GFSI. Additionally, FDA and CFIA made a recognition agreement, meaning that they recognize each other’s systems; the two systems are considered to be similar enough that product can move across the border mostly unfettered. Like the regulations of FSMA, Canadian importers must have detailed information on all their suppliers, products, processes, and hazards, and a hazard analysis must be conducted to assess any potential hazard associated with the imported products. And, as part of the PCP, you have to have procedures for complaints, traceability and recall procedures. The recall procedures are somewhat more extensive than that of FSMA, but it does similarly include mandatory notifications to the federal agency (CFIA in this case) in potential recall situations. The biggest difference between the SFCR and FSMA regulations is that Canada has taken a very broad approach to preventive controls, including other regulatory requirements beyond food safety, such as labelling, weights/counts, claims, grades, standards of identity, etc. So, these must also be part of the Importer Preventive Control Plan for a U.S. business to hold a Canadian license. Importers have multiple ways to ensure their imported product meets Canadian standards, such as supplier audits, GFSI or other recognized certifications, COAs, foreign government recognition such as FDA/CFIA Recognition Agreement, foreign government product certifications, etc. In some cases, other means of verification, such as inspection and testing of incoming products, are applicable to ensure the supplier approval program is working. There also are some long-standing U.S./Canadian agreements on some products, such as the USDA/CFIA agreement on meat entering Canada. Products must continue to meet these requirements, but they simply become part of the importer preventive controls. Even if you hold an import license you will likely be held to an audit at some point in time. CFIA will audit the importer PCPs based on a Risk-Based Inspection Model which includes both document review and product sampling – with those products which are seen as higher risk more likely to face more frequent audits. But with the new provisions likely to significantly increase the number of licenses, CFIA has more to inspect, so inspections would likely be annual, biannual, or less. CFIA will focus its inspections and audits on a risk basis, so products such as ready to eat, or those with a known food safety concern, will be targeted at greater frequency. The import licensing is being phased in with SFCR a couple of years behind FSMA. However, products that are registered commodities and already had inspection programs in place (such as Importers of meat, fish and seafood, dairy, eggs, and maple) have had to be in compliance since January 2019. But for most other foods, the deadlines are mid-2020 and for very small businesses, it is 2021. But it holds some big changes for some companies, so preparing now is advised. CFIA provides some good resources for additional information, particularly on the CFIA website section on SFCR. There also is a site called My CFIA, with more information, and the ability to apply online for license; the current cost of which is $150 for two years. And TAG also has SCFR experts and is happy to help any companies with detailed or specific questions. About The Acheson Group (TAG) Led by Former FDA Associate Commissioner for Foods Dr. David Acheson, TAG is a food safety consulting group that provides guidance and expertise worldwide for companies throughout the food supply chain. With in-depth industry knowledge combined with real-world experience, TAG’s team of food safety experts help companies more effectively mitigate risk, improve operational efficiencies, and ensure regulatory and standards compliance. www.AchesonGroup.com
