If your business deals with products for human consumption, you may have new regulatory requirements!
New Safe Food for Canadians Regulations (SFCR) came into effect on January 15, 2019, including licencing, traceability, Preventive Controls, and Preventive Control Plans. Here’s how to make sure your business is prepared.
Do these new rules impact me?
These new rules apply to any business that conducts certain ‘activities’ across provincial or international borders. These activities include importing, exporting, inter-provincially traded foods and also some activities for foods that stay in-province.
The Canadian Food Inspection Agency (CFIA) has created tools to help you figure out if the new rules apply to your business:
If you are still unsure if you have to comply with the new regulations, you can reach out to the CFIA at one of the numbers below.
What are the new requirements?
There are three new requirements under the SFCRs.
This is a new license and can be obtained online, through My CFIA.
Note: If your business has multiple operations or food activities you may decide you want multiple licenses. It is your choice to hold one or multiple licences for your business. You can find out more here, regarding why you may or may not want multiple licenses.
Preventive Control Plan
A document that outlines your business’s food safety protocols, so that when inspectors come to your business they can review the Plan and assess that it is sufficient and being met. You can find guides for developing Preventive Control Plans in CFIA’s Toolkit for Businesses.
For many businesses, these will be new requirements that demand businesses document both where they received food from (suppliers) and who they have then sold their products to. This is considered a one step forward and one step back approach.
Note: Traceability requirements are intended for business-to-business, not business-to-consumer, so you do not need to record sales to consumers.
When do I have to comply?
Your business may need to comply as of January 15, 2019, but CFIB successfully pushed for additional time for small businesses to comply. These extensions are based on the size of your business (if you have less than four employees) and amount of gross annual food sales. To find out exactly when your business needs to comply, check CFIA’s links:
- Dairy products, eggs, processed egg products, processed fruit or vegetable products
- 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 food
Are there any exemptions?
Yes! Through our fighting for small business owners, CFIB was able to secure an exemption for businesses making less than $100,000 in food sales. These businesses are exempt from having to write Preventive Control Plans. (If you match this criteria, you still need Preventive Controls, which inspectors will look for in any inspection they conduct). CFIA estimates that this exemption will save small businesses over $6,000 to write the Plans and $500 a year in to maintain them thereafter.
General exemptions from the Safe Food for Canadians Regulations are:
- food for personal use, when the food is not intended for commercial use, and
- the quantity of food is equal to or under the maximum quantity limits, found in the document "Maximum Quantity Limits for Personal Use Exemption," and
- the food is imported, exported, sent or conveyed from one province to another by an individual other than in the course of business; or
- the food is imported or exported as part of the personal effects of an immigrant or emigrant
- food that is carried on any conveyance that is intended for the crew or passengers
- food that is intended and used for analysis, evaluation, research, or a trade show provided that the food is part of a shipment that weighs 100 kg or less or, in the case of eggs, is part of a shipment of five or fewer cases
- food that is not intended or sold for human consumption
- food that is imported from the United States onto the Akwesasne Reserve by a permanent resident of the Reserve for their use
- food that is imported in bond (in transit) for use by crew or passengers of a cruise ship or military ship in Canada
- food that is traded between federal penitentiaries
- transporting a food commodity, if that is the sole activity of a person