by Cameron Prince The big day for the Safe Food for Canadians Regulations (SFCR) has come and gone. With the Safe Food For Canadians Act originating in 2012, and its regulations finalized by the government in June 2018, the SFCR is now in effect — after a very long lead-up time. Under the SFCR, certain businesses must be licenced to operate in, or import food into, Canada. Like the Food Facility Register of the U.S., the licensing is intended to identify food businesses and enable the government to directly communicate food safety information and take responsive action when a business does not comply with the regulations. Food businesses that need a licence include those that: Import food or food products. Manufacture, process, treat, preserve, grade, package, or label food for export or to be sent across provincial or territorial borders. Export food (where an export certificate is requested). Slaughter food animals from which meat products are derived for export or to be sent across provincial or territorial borders Store and handle a meat product in its imported condition for inspection. You can apply for a licence through the Canadian Food Inspection Agency (CFIA) web portal, My CFIA. Once you create a business profile, you can request a licence, export certificate, or other CFIA-issued permission online. So far things seem to be going well. The MyCFIA portal is working and the licences are being issued with no significant problems. That said, MyCFIA is a bit tricky to get registered on, so you will want to allow an hour or so to work your way through the process. To simplify the process, we recommend that you check out the CFIA’s “Before you sign up” webpage and view the CFIA YouTube video, “Requesting a licence Using My CFIA.” We recently worked with an importer client on the licence application. Since the business was already registered with CFIA, the process was fairly easy — but we found the video to be very helpful. Frankly, we would still be trying to get this done if we hadn’t watched the video. Following are some key points to consider before applying: Make sure you really need a licence now. We have found that some companies, particularly importers, think they need an import licence now when in fact, they won’t need one for one or two more years, because of the commodities they deal with. If you plan to export to the U.S., you must have a licence first — no matter what commodity you produce, import, or export. In other words, the one- and two-year extensions for some commodities do not apply if you export to the U.S. When applying for a licence, you must declare that you have a written Preventive Control Plan (PCP). Obviously, the PCP has to be in writing, reasonably complete, organized, and in effect (i.e., records being kept). However, the PCP does not have to be perfect right away. We would not recommend delaying licensing while perfecting a PCP. If CFIA does audit your PCP, it will not be expected to be without some gaps or areas for improvement. Keep in mind, there will be an initial educational phase where industry will not be expected to have perfect PCPs. This is primarily applicable, though, to sectors other than meat, fish, dairy, maple, honey, and processed products which have been expected or mandated by CFIA to have some form of HACCP or PCP for many years. If you are new to PCPs in your business, the main point is to get the licence when needed, and start implementing your PCP as best you can. For more information on the SFCR, see An Overview, What it means for Canadian Industry, and What it means for Import and Export Trade. For more licensing and other SFCR videos, visit CFIA’s video page. And for more information, consultation, or other assistance, contact any of us on the TAG Canada Team. 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
