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Foreign Supplier Verification Program – USA & Canada agreement?

Under the Food Safety Modernization Act (FSMA), the United States (U.S.) started graduated enforcement of the Foreign Supplier Verification Program (FSVP) in May 2017.

FSVP (Foreign Supplier Verification program) requires U.S. importers (regulated by US FDA) to verify that food imported into the United States has been produced in a manner that meets applicable U.S. safety standards. Similar to the Safe Food for Canadian Regulations, Canadian importers will soon have to verify and prove to CFIA the food they are importing meets the regulations and standards.

What does this mean for US Importers of Canadian foods?

Canada and the U.S. have a Food Safety Systems Recognition Arrangement (FSSRA). The FSVP provides modified requirements to U.S. importers when they import food that is covered under the FSSRA from Canadian manufacturers that are in good regulatory standing with the Canadian Food Inspection Agency (CFIA).

Does this mean we can finally see an alliance between the US FDA and CFIA?? That is the intention of the FSSRA and, fingers crossed, this will make it easier for US and Canadian imports and exports.

The FSSRA applies to foods regulated by the US FDA including:

  • fruit and vegetables
  • shelled eggs
  • dairy (except “Grade A” milk and milk products)
  • fish (except farmed catfish, catfish products and molluscan shellfish
  • maple
  • honey
  • processed products; and
  • manufactured foods

What does this mean for the Canadian food industry?

Canadian food manufacturers who process food for export will require a licence under the Safe Food for Canadians Regulations (SFCR). When the SFCR comes into force, the CFIA will publish a listing of SFCR licensed food manufacturers as the method to certify that they are operating in good regulatory standing if they comply with SFCR requirements. To be considered to be operating in good regulatory standing under the SFCR, the federally licensed establishments will need to operate with an acceptable Preventive Control Plan (PCP) and maintain acceptable traceability documents in order to be placed on the listing of SFCR licensed food manufacturers.

If you are currently federally registered and/or licensed with CFIA:

If you operate an establishment that is currently registered with the CFIA, you will need to have an acceptable Preventive Control Plan (PCP) and traceability documentation process in place in order to obtain a license when the SFCR comes into force. Your registration and the federally registered lists currently available may be used by U.S. importers to indicate your good standing until all food manufacturers are licensed and the new list of SFCR licence holders comes into effect.

If your business is already federally registered or licensed at the time that the SFCR comes into force, you can maintain your exporting activities while you make the necessary changes to transition to the SFCR licensing system.

If you are NOT currently federally registered and/or licensed with CFIA:

Businesses in certain food sectors (i.e. manufactured foods, non-federally registered sector, etc.), which have traditionally NOT required federal registration and/or licensing, will now need to be licensed to demonstrate that your company is in good regulatory standing. Like a registered facility, you will need to have an acceptable a PCP and a traceability documentation process in place in order to obtain a licence when the SFCR comes into force.

Food businesses seeking to begin or continue exports to the U.S. will need to be licensed when the SFCR comes into force if they want to be on the Canadian list of licence holders in ‘good standing’ in order for US importers to apply the modified FSVP requirements.

The CFIA encourages all Canadian food businesses exporting to the U.S. to prepare for the SFCR as it comes into force. Being federally licensed and listed with the CFIA will eliminate the burden of documentation for importers and exporters of US FDA regulated foods. Businesses do not need to apply for an SFCR licence at this time, but as the transition to the new regulations takes place, you will be able to apply for the new licence online or access information about the licence and regulations through your My CFIA account.

If you want to be sure your food safety practises are in line with the new SFCR and export requirements, Quality Smart Solutions has a team of specialists who can assist with preparing and implementing a PCP or reviewing your documents and conducting an audit of your facility. Get prepared now and contact us today to discuss how we can be your food safety solution!

Quality Smart Solutions is an end-to-end compliance solutions expert which has been assisting clients for 11 years in the areas of Dietary Supplements/NHPs, Foods, Cosmetics, Canna, Medical Devices, OTC drugs in Canada and the United States. Ask us for details or visit our website at www.qualitysmartsolutions.com.

How We Can Help

Our Experts at Quality Smart Solutions also offer to support your needs for foods, cosmetics, OTC drugs and medical devices for North America.

Contact us today to learn more about how we can support your compliance needs during and after licensing!

30 Minutes Free Consultation
Resources Canadian Food Inspection Agency. Inspection modernization. 2018-01-03. http://inspection.gc.ca/food/sfcr/exports/requirements-library/fsvp/eng/1521203122812/1521203165440
Categories
Blog

Natural Health Product Brand Name Guidance

Natural Health Product Brand Name Guidance

Brand names are an important part of your marketing strategy, but as many of us know firsthand there is a difference between what the marketing team wants to say and what the regulatory authorities will let you get away with. Consideration needs to be taken to ensure your brand name is as compliant as your health claims since a brand name is essentially an extension of your health claims.

As part of the review process, the Natural and Non-precription Health Products Directorate reviews your brand name in addition to your health claims. They expect that the name you choose for your product reflects the approved product claims. For example, if you want to market a product containing vitamin B12 which is licensed for the claim “Helps to maintain the body’s ability to metabolize nutrients” you will not be permitted to use any reference to weight management as part of the brand name. Other brand name challenges we have come across is the use of the term ‘detox’. This term is reserved exclusively for products which support liver function or the elimination of waste from the body.

Another challenge is having a brand name which implies treatment of a condition but only being able to receive a licence for an antioxidant claim. For example, the marketing team wants to call the product “Low Dose Lutein for Eye Health” and market the product to support eye health in conditions such as cataracts and age-related macular degeneration.  However, when we review Health Canada’s monograph for Marigold extracts and isolates (including lutein) we see this eye health claim is based on quantities of at least 6 mg lutein per day.  If the ‘low dose lutein’ product provides less than 6 mg lutein per day, Health Canada will only permit the use of the product for antioxidant purposes. In which case, using a brand name which speaks to the products efficacy for eye health would be considered non-compliant.

If you are looking to appease your marketing department while keeping the product brand name fully compliant, Quality Smart Solutions has a team of specialists who can assist in achieving innovative brand name compliance for your products.  Contact us today to discuss how we can be your solution!

Quality Smart Solutions is an end-to-end compliance solutions expert which has been assisting clients for 11 years in the areas of Dietary Supplements/NHPs, Foods, Cosmetics, Medical Devices, OTC drugs and Canna for Canada and the United States. Ask us for details or visit our website at www.qualitysmartsolutions.com.

How We Can Help

Our Experts at Quality Smart Solutions also offer to support your needs for foods, cosmetics, OTC drugs and medical devices for North America.

Contact us today to learn more about how we can support your compliance needs during and after licensing!

30 Minutes Free Consultation
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News

Amazon.ca removing non-compliant Natural Health Products in October

In September  Amazon.ca notified every Natural Health Product vendor (whether they had an NPN or not) that, effective in October 2018 they will be removing all products that don’t have a Natural Health Product Number.   Here’s the email they sent to sellers:

AMAZON NOTICE TO SELLERS OF NATURAL HEALTH PRODUCTS

Dear Seller,

Pursuant to Canadian laws and regulations, all non-prescription drugs, supplements, and natural health products (“NHPs“) that are sold in Canada must be assigned a registration number by Health Canada.

We are updating our product registration templates to require either a Natural Product Number, Drug Identification Number or a Homeopathic Medicine Number to list these products on our site.

From October 2018, Amazon will remove drugs, supplements, and NHPs that do not have registration numbers associated with them in the catalog from the site. If your product is impacted, you can identify the ASINs and contact Seller Support.

To back-fill the required compliance information for your existing products, you can do so through the single item setup in Seller Central or through an Inventory Template file. More information about listing drugs, supplements and NHPs can be found here: https://sellercentral.amazon.ca/gp/help/external/200164490

Amazon.ca, in recent months, had been taking a proactive approach for new products listed on their site whereby if a brand didn’t have an NPN they couldn’t be listed. However, prior to this policy implementation many products were listed without an NPN.  Clearly there was significant pressure on Amazon from border officials, Health Canada and likely shareholders to tighten up their policy.

For international (ie. outside Canada) companies shipping dietary supplements to Canada there are 3 requirements as summarized on  NHPLicenseExperts.com which includes:

  1. A Natural Product Number
  2. A compliant Natural Health Product label
  3. An importer of record if you are shipping a finished product into Canada.

Some of the biggest brands like Amazing Grass, Dr. Bronner’s Barlean’s, Goddess Garden, SmartyPants and many more rely on our end-to-end NHP License solution.

The good news is that we are your one-stop shop solution for all three of these requirements.  Working with hundreds of clients and brands we offer competitive rates having prepared thousands of NPNs over the last 12 years.   Ask about our new client NPN registration offer to help you continue your business on Amazon.ca and your business in the Canadian marketplace.

Quality Smart Solutions is an end-to-end ompliance solutions expert which has been assisting clients for 11 years in the areas of Dietary Supplements/NHPs, Foods, Cosmetics, Medical Devices, OTC drugs and Canna for Canada and the United States. Ask us for details or visit our website at www.qualitysmartsolutions.com.

How We Can Help

At Quality Smart Solutions, we provide you with the guidance to plan your Veterinary Health Products business, navigate the legal requirements, and acquire the appropriate license for your operations.

Quality Smart Solutions has a team of professionals to offer support from day one of starting your business, including formulation and label reviews, Veterinary Health Product notifications and more.

30 Minutes Free Consultation