Policy for cold storages and export certification

Under the Safe Food for Canadians Regulations (SFCR) the licensing of cold storages is voluntary. However, should a cold storage be part of a production chain with food products destined for international export, an SFCR licence may be needed to meet importing country requirements. As such, the Canadian Food Inspection Agency (CFIA) will not list any unlicensed cold storages, nor certify product stored in an unlicensed cold storage, if being federally licensed is a condition of trade agreements or export certificate attestations.

With the exception of meat and meat products, whose requirements for cold storages are found below, food must be stored at a licensed cold store if there are requirements for cold storages to be on export lists prior to product being eligible for export. This is primarily the case for products of animal origin, including meat, fish, and dairy.

All meat and meat products for export must be stored only in licenced storage facilities, and furthermore, these facilities are not permitted to store meat from non-licenced establishments on site.

In the case of export certification of meat products, the CFIA will only certify meat for export, from any point of production, if all establishments identified on the certificate are federally licensed. If a particular product has been identified as being stored in an unlicensed cold storage, the CFIA cannot demonstrate there was continuous federal oversight over the production chain and as such, cannot certify this meat product for export.

Storage of food from licensed and unlicensed food businesses

Please note that under the SFCR, federally licensed cold storage operations may store:

• food product, except meat (see Meat establishment licensing and registration requirements), that is non-eligible for export from unlicensed sources;
• and, food product that is eligible for export obtained from federally licensed sources.

When products from multiple production chains are housed in the same storage facility the cold store operator must develop, implement and maintain effective and verifiable segregation controls in their preventive control plan (PCP) for ensuring compliance with all applicable food export requirements.

This means that when eligible and non-eligible products are stored at the establishment, the controls must ensure that non-eligible products can be distinguished from those that are eligible, from receiving, through to shipping and distribution. The control programs must include monitoring, verification and deviation procedures. The controls implemented by the cold storage operator to comply with applicable export requirements will be reviewed by the CFIA through usual inspection activities.

Please note that some trading partners require additional segregation for food products produced solely for their markets. Exporters are expected to understand the foreign country requirements found in the Export requirements library and ensure that all conditions are met.