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.
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: