When Do You Need to Comply with the SFCR Provisions?
As of January 15, 2019, the Safe Food for Canadians Regulations (SFCR) came into force. However, not all the provisions needed to be met immediately. Some are being phased in at various points through 2022 based on food commodity, type of activity and business size.
It would take numerous web pages to detail every aspect of this – and that is exactly what CFIA does at SFCR timelines. Instead, this Insights page is intended to provide a general overview of the timelines, how to know what applies to you, and resources for more information.
The first step in determining where your facility processes fit into the timeline is knowing which requirements apply to you. For that CFIA provides three interactive tools:
· Licensing. Licensing is required for many business activities, but not all. For example, if you import, export, or do business between provinces, you likely need a license – though some exceptions apply. For example, you don’t need a license if the food is for personal consumption, or if it is to be sold or consumed within your province or territory – unless it is required by the province or territory.
· Preventive Control Plan (PCP). Some parts of the business require a PCP that demonstrates how risks to food and food animals are identified and controlled, though you may you may still need to comply with the certain preventive controls requirements. This tool enables you to assess your need for a PCP.
· Traceability. Virtually all food businesses, except those generally exempted from the SFCR, are required to retain documents that, at the very minimum, identify the food and trace it one step forward and/or back. More is required of most.
Once you’ve learned what is required of your business, the next step is to determine when it is required, as compliance dates vary by food, activity and size of the food business. The food categories of the timelines are Dairy products, eggs, processed egg products, processed fruit or vegetable products; Fish; Meat products and food animals; Fresh fruit or vegetables; Honey and maple products; Unprocessed food used as grain, oil, pulse, sugar or beverages; Food additives and alcoholic beverages; All other foods.
The linked page of each category details the licensing, PCP, preventive controls and traceability compliance dates based on the business activity/activities (as determined in step 1). Additionally, all other foods, which includes all those not specified in any of the other timelines, has additional compliance date variance based on the business’ gross annual food sales and number of employees.
In addition to these categories, SFCR calls out organic aquaculture products as not needing to be certified until January 15, 2021; and while specifying new inspection legends for edible meat products, fish and processed egg products, it allows for the use of the former legend through January 15, 2022.
While this vast array of timelines can appear to be complex, following through the steps of identifying your business activities, selecting the correct category, then marrying up the two in the table provided greatly simplifies the process.
But should you have any difficulty or need any assistance in interpreting or complying with SFCR, contact us at TAG Canada.
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