Regulatory changes which are being implemented under the SFCA and corresponding SFCR focus on 5 core areas: licensing, preventative controls, traceability, labelling & standards of identity/grade and organic certification. The focus of this article is to highlight the main changes associated with these new requirements.
Licensing
Certain food businesses will need to be licensed. Food businesses involved in any of the following activities will be required to have a licence by January 15, 2019 in order to maintain food production/handling activities:
- Importation of food
- Manufacturing, processing, storing, packaging, or labelling food to be exported or sent across provincial or territorial borders
- Exportation of food that requires an export certificate
- Slaughtering of food animals for export or shipment across provincial or territorial borders
- Handling and storage of imported meat products in their imported condition for inspection by the Canadian Food Inspection Agency (CFIA).
Preventative Controls
Preventative control measures will need to be implemented by most businesses by the coming of force of the SFCR. The preventative control measures are to be documented in a Preventive Control Plan (PCP) as outlined in Part 4, Division 6 of the SFCR. However, certain businesses will be exempt from this regulation, including businesses with $100,000 or less in gross annual food sales and exporters of non-meat and non-fish products.
Traceability
Requirements to assist with the traceability of food through the market will come into effect with SFCR. These requirements will affect your business if you are involved in any of the following food-related activities:
- Importation
- Exportation
- Distribution across provincial or territorial borders
- Manufacturing, processing, storing, packaging or labelling food to be exported or sent across provincial or territorial borders
- Growing/harvesting fresh fruits or vegetables which are to be shipped internationally or across provincial or territorial borders
- Slaughtering of food animals for export or shipment across provincial or territorial borders
- Handling and storage of an imported meat product in its imported condition for inspection by the CFIA
- Selling food to consumers at the retail level
As a note, restaurants and other similar businesses are not subject to the traceability requirements.
Labelling, Standards of Identity and Grades
Food labelling requirements, standards of identity and grades requirements from the former Consumer Packaging and Labelling Act, Canada Agricultural Products Act, Meat Inspection Act, Fish Inspection Act, and their respective regulations and been consolidated into the SFCA and SFCR. Furthermore, the CFIA has published documents outlining specific requirements on standards of identity and grades for certain types of foods.
Organic Products
As per section 13 of the SFCR, organic products must be certified organic according to the Canadian Organic Standards. More specifically, compliance with section 13 of the SFCR is required for imported or nationally distributed products which are making an organic claim or products which bear the Canada Organic Logo, regardless of shipping destination.
Most companies have until January 15, 2019 to bring their business practises in line with the SFCR for most food-related practises. Quality Smart Solutions has a team of regulatory specialists who can assist with the assessment of your food-related activities. Contact us today to discuss how we can be your solution for your Canada food safety and label compliance needs!
Quality Smart Solutions is an end-to-end compliance solutions expert which has been assisting clients for over 10 years in the areas of Dietary Supplements/NHPs, Foods, Cosmetics, Canna, Medical Devices and OTC drugs. Ask us for details or visit our website at www.qualitysmartsolutions.com.
