• The Acheson Group

SFCR Requirements Now Due for Fresh Fruit and Vegetable Businesses

One year ago, Canadian businesses that import or prepare fresh fruits or vegetables for export or interprovincial trade were required to obtain a Safe Food for Canadians (SFC) licence from the Canadian Food Inspection Agency (CFIA) to meet the new requirement of the Safe Food for Canadians Regulations (SFCR). Most businesses (except growers and harvesters) also had to meet traceability requirements by the January 15, 2019, compliance date.

On January 15 of this year, additional requirements for preventive controls, preventive control plans and traceability came due for compliance by this fresh fruit and vegetable (FFV) segment — defined in the SCFR as "any fresh plant or any fresh edible fungus, or any part of such a plant or fungus, that is a food" including wild or cultivated fresh herbs, fruits, vegetables, mushrooms or sprouts.

Following is a discussion of the new FFV requirements and what they mean to the FFV segment of the food industry.

Importer Licensing. With FFV importers having been required to have an SFC licence from CFIA by January 15, 2019, CFIA will now be enforcing action against those who don’t. Importers who are not in compliance may experience delays or refusal of entry of their shipment at the border and may be subject to other SFCR enforcement actions.

Preventive Controls. As of the January 15, 2020, compliance date, licensed FFV businesses — and growers and harvesters of FFVs for export or interprovincial trade — must have preventive controls in place. The controls are to address food safety hazards, such as microbiological contamination, that may be introduced during the growing and harvesting of fresh fruits or vegetables, and help prevent contaminated and non-compliant food from entering the marketplace.

Preventive Control Plans (PCP). An SFCR requirement for food businesses in general is that of developing and implementing a preventive control plan — a written document that demonstrates how risks to food are identified and controlled. For the FFV segment, the requirement applies to both FFV businesses and those that grow or harvest fresh fruits or vegetables for interprovincial trade or export that have gross annual food sales of more than $100,000. Additionally, FFV importers must ensure that their PCP addresses the preventive controls for growing and harvesting by their foreign supplier.

CFIA has stated that businesses that have implemented CanadaGAP or HACCP are well positioned for compliance with the PCP food safety requirements. However, these systems may not cover other PCP requirements, so businesses should ensure that all SFCR requirements are addressed in their PCPs.

Traceability. Although the SFCR requiring all food businesses required to track their food one step forward and one step back in the supply chain, that requirement just came due for businesses that grow or harvest fresh fruits or vegetables this year. To be in compliance, businesses must:

  • Prepare and keep traceability documents.

  • Apply, attach or include a label containing the required traceability information to/with fresh fruits or vegetables when provided to another person or business.

  • Have lot-code labelling on consumer prepackaged fresh fruits or vegetables, though businesses have until January 15, 2021, to use up existing packaging.

It also is important to note that CFIA is currently updating its guidance for FFV lot code labelling, so business should keep an eye out for that publication. You can expect lot codes to need to include production date, best before date, establishment number or SFC licence number, as well as the harvest date, grower identification number, growing region or other traceability code for fresh fruits or vegetables.

About The Acheson Group (TAG)

Led by Former FDA Associate Commissioner for Foods Dr. David Acheson, TAG is a food safety consulting group that provides guidance and expertise worldwide for companies throughout the food supply chain. With in-depth industry knowledge combined with real-world experience, TAG's team of food safety experts help companies more effectively mitigate risk, improve operational efficiencies, and ensure regulatory and standards compliance. www.AchesonGroup.com