As we’ve mentioned in previous posts, the Safe Food for Canadians Regulations (SFCR) come into effect on January 15, 2019. Now is the time for food manufacturers and importers/exporters to prepare to be compliant by that deadline.

Last week, we watched Livingston‘s in-depth webinar about the SFCR and what the food sector needs to know by January. Two of the biggest topics focused on Licensing and Preventive Control Plans (PCPs), and we have listed the key points here.

Licensing

• Licensing cost will include Goods & Services Tax (GST); the total amount will be approximately CAD $270, and will be valid for a two-year period
• Pet food manufacturers and animal feed manufacturers don’t need a license
• License numbers do not have to be posted on food labels or anywhere else on the product. Manufacturers will, however, be required to give their license number to their broker or distributor who will, in turn, provide it to the Canadian Border Services Agency (who refers it to the Canadian Food Inspection Agency)
• It is recommended that manufacturers have multiple licenses for multiple locations and activities
• Non-residents are eligible to obtain a license
• Food trade shows are exempt from licensing requirements
• It is recommended that businesses register with the CFIA via its web site as soon as possible. Once registered, the business will be notified that licensing application can begin. Don’t wait until the January 15 deadline to be licensed.

Preventive Control Plan (PCP)

• PCPs are also due by January 15, 2019. A PCP is required to be in place in order to be licensed, but does not need to be submitted when applying for a license (more info about a PCP can be found here)
• Written PCPs are not required if gross food sales are $100,000 or less, but your business might still need to comply with the preventive controls requirements in Part 4 of the SFCR
• The content of your company’s PCP depends upon your business’s activities (refer to the PCP interactive tool to determine your plan requirements)
• You may use other PCP approaches that have been developed by other food safety authorities, industry associations, international partners, or academia, as long as it is tailored for your business and meets the requirements of the SFCR (templates can be found here)
• You must have evidence that you have implemented your written PCP (i.e., service contracts, processing records, day-to-day records)
• Written PCPs should include descriptions of critical control points, control measures, measures implemented to meet consumer protection requirements, a hazard analysis, and supporting documents used to develop your PCP.

Allow us to reiterate: don’t wait until January. Visit the My CFIA site and register your business today!

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