CFIA Continues Hold on CFIA Compliance Requirements
Although the new requirements of the Safe Food for Canadians Regulations (SFCR) took effect on July 15, the Canadian Food Inspection Agency (CFIA) reaffirmed its April 7 statement that, due to COVID 19, compliance actions continue to be on hold for the activities, which include licensing, preventive controls, and traceability, for most “manufactured” products (as specified on the SCFR timelines page).
This means that Canadian food businesses (and U.S. companies doing business in Canada) won’t need to have licences and Preventive Control Plans (PCPs) at this time. CFIA has not provided a date at which enforcement will begin, rather the agency has stated that any change to its prioritization of compliance and enforcement activities with regard to the SFCR “will be announced with adequate lead time once the situation allows.”
Companies do still have to comply with all requirements of the Food and Drugs Act, Food and Drug Regulations, and SFCR requirements that were applicable prior to July 15, 2020, including those related to food safety, exports, packaging, and labelling. CFIA also continues to encourage businesses to apply for a licence under the Safe Food for Canadians Act (SFCA), but has stated that domestic manufacturers can continue to operate while they apply for a licence and importers of manufactured food will generally not encounter delays or disruptions in their imports simply because of not having a licence yet.
Additionally, the CFIA will continue to take action in the event of a food safety issue, including, as applicable, recalling, seizing or detaining food products and enacting other relevant enforcement and control measures.
Although the agency has postponed the compliance requirements – understanding that pandemic-related challenges continue for manufacturers, TAG recommends that businesses continuing preparing for and taking steps toward compliance with the SFCR licensing, preventive control and traceability requirements, as much as possible.
CFIA has provided (and improved) its Toolkit for food businesses and launched a food business requirements virtual assistant to help businesses find key information and resources on its website. Additionally, TAG has Canadian regulatory experts who can assist in helping your company meet these, and all CFIA, regulations. Give TAG a call.