The Importer Preventive Controls under the Safe Food for Canadians Regulations (SFCR) is of great interest to Canadian importers as well as U.S.-based companies exporting food to Canada. While SFCR is very similar to FSMA, there are some inherent differences.
Differences Between FSMA & SFCR
In general, the Preventive Controls under SFCR are similar to that of the Supplier Approval Programs outlined in FSMA and GFSI. In fact, there is an agreement between the FDA and CFIA to recognize each other’s systems, and aside from inspections performed for products or importers that have been deemed high-risk, products can generally move across the border unfettered.
With that being said, there are several important ways the SFCR Preventive Controls are different from FSMA. First, they cover the “other” regulatory requirements outside of food safety, including labeling, weights or counts, claims, grades, standards of identity, and so forth. Like FSMA, however, SFCR requires importers to have detailed information on all suppliers, products, processes, and hazards. They must also conduct an assessment of potential hazards associated with imported products.
Licensing Requirements for US Manufacturers
Anyone who imports food to Canada must have a license. If you export to Canada and if your products have been manufactured, processed, treated, preserved, graded, packaged or labelled in Canada, then you must ensure those activities were conducted by a license holder. If you only import food additives or alcoholic beverages then you do not need a license. Visit the CFIA's licensing interactive tool to learn more about SFCR licensing requirements.
Timelines & Deadlines
For importers of meat, fish and seafood, dairy, eggs, and maple products, the compliance date for these rules passed in January 2019. For most other foods, the deadline is mid-2020, while very small businesses will have until 2021 to comply. The CFIA website section on SFCR is a useful resource for exporters to find helpful information, and companies can also apply for a license on the “My CFIA” section of the website. The cost is $150 for two years. Please visit the CFIA's SFCR Timelines web page to better understand SFCR timetables.
SFCR Importer Preventive Controls Enforcement
To ensure imported products met Canadian standards, importers have multiple means of assessment, including audits of suppliers, GFSI or other recognized certifications, COAs, and foreign government product certifications. Of course, they may also perform inspections and tests on incoming products to make sure the supplier approval program is working efficiently.
Although the SFCR Preventive Controls will change certain processes for many exporters, it’s important that companies producing products covered under existing agreements continue to meet these requirements. For example, the USDA and CFIA requirements for meat entering Canada still stand, as do similar types of agreements.
In terms of enforcement, the CFIA will audit importer Preventive Controls Plans using a risk-based inspection model. This will include both document review and product sampling. Because the number of licenses is set to increase tremendously, however, the large workflow for the CFIA will likely mean that inspections will be held rather infrequently, i.e., on a one-, two-, or even three-year basis. In particular, they will be checking to make sure Preventive Controls Plans contain sections on complaints, traceability, and recall procedures, including notifications to the CFIA in potential recall situations.
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