Frequently Asked Questions

• A. The Non-Food Chemicals Program
• B. Non-Food Chemicals
• C. Food Packaging Materials
• D. Construction Materials
• E. Reference Listing of Accepted Construction Materials, Packaging Materials and Non-Food Chemical Products
• F. Equipment

A. The Non-Food Chemicals Program

Q A1. What are the objectives of this program?

The Canadian Food Inspection Agency's (CFIA) Non-Food Chemical and Container Integrity Programs deals with the safe use of non-food chemical products (e.g., cleaners, disinfectants, sanitizers, etc.), food packaging materials and construction materials in federally registered food establishments. Among the responsibilities of this program is the evaluation of submissions for CFIA acceptance of these products for their use in food establishments.

Evaluation of these products by the CFIA consists of not only evaluating each chemical ingredient of a particular product individually but also as a whole to ensure their use will not present a food safety concern for the food products in a food establishment. Please refer to the section Guidelines for Submission of the CFIA web site for more information on the criteria used in product evaluation.

Once the product has been accepted for use in a food establishment, a letter of acceptance is issued to the applicant and the reference listing of accepted product on the CFIA web site is updated.

Q A2. Who are typical applicants and who consults the reference listing?

Typical applicants are manufacturers or distributors wishing to sell their products to federally registered food establishments. Those consulting the reference listing include food establishments wishing to use a particular non-food chemical product or CFIA inspectors verifying that products used in a federally registered establishment are CFIA accepted.

Q A3. What is an "Acceptance Letter"?

An "Acceptance Letter" is an opinion expressed by the CFIA (and when applicable in concert with Health Canada) that either a construction material or a packaging material (when food contact application occurs) or a non-food chemical product is found suitable for use in food establishments. A product's suitability is determined by evaluating its chemical composition, proposed use(s) and, when applicable the label content. This evaluation is based on the information submitted by either the manufacturer and/or his supplier(s). Following this evaluation and when deemed suitable for food plant use an "acceptance letter" is issued which serves as confirmation to an applicant that their product is registered in the Reference Listing of Acceptable Construction Materials, Packaging Materials and Non-Food Chemical Products, also known as the Register. The information appearing on the letter of acceptance includes the name of the official contact for the company (if applicable), the name and address of the manufacturer or the distributor, the CFIA's file number, the issuance date, the sub-category code(s) under which the product is classified, conditions of use and the signature of the CFIA's official representative

Please note that the registration of a product by way of inscription in the Register, shall not be interpreted as having neither approval of use nor has it been evaluated for efficacy by CFIA.

Q A4. What is the expected turnaround time for the issuance of an acceptance letter?

A submission is given a preliminary review on a first come, first served basis. The expected turnaround time for the issuance of a letter of acceptance is determined by the following;

• The number of submissions received and pending review by our office at the time of application;
• The pertinency and the adequacy of the information provided by the applicant at the time of application;
• For security purposes an applicant must supply to the CFIA, along with the application form, the name of an Official Contact along with its coordinates (mailing address, phone, fax and email) on company letterhead. Without the Official Contact we are unable to communicate our requests/decisions to the applicant;
• The nature and complexity of the product submitted for evaluation;
• The intended use of the product as well the product's potential risk to the consumer;
• Communication time between the CFIA and the Official Contact for more information;
• The pertinency and adequacy of the information provided by the supplier(s) concerning the applicant's request;
• Advices or recommendations of other government officials such as Health Canada or other CFIA technical experts.

Q A5. How long is an "Acceptance Letter" valid?

At present an "Acceptance Letter" for a non-food chemical is valid as long as the chemical composition, the product's name, the name of the manufacturer or the name of the registrant, the intended use and, when applicable it's labelling content, on which was based its evaluation remain identical to that which was registered.

In the event of a difference between the acceptance letter and the Register, the latter shall prevail.

Also, the CFIA reserves the right to rescind a product's registration should new regulations, scientific advances or if it is demonstrated that the use of the product may potentially pose a health risk to consumers.

When a product is de-registered, either at the request of the registrant or at the prerogative of the CFIA, then the acceptance letter shall be considered Null. Should the de-registration occur on the initiative of the CFIA then the registrant or their representative will be officially advised of the reason(s) for this decision.

Q A6. What is the protocol in the event that the formulation, the intended use or the direction for use shown on the label of an accepted product changes?

In the event that the formulation is changed or when a change to the registered use of an accepted product is requested, the product will have to be re-evaluated in order to update its registered status. Once found acceptable, a new acceptance letter will be issued.

Please note that for a non-food chemical product, a draft label reflecting the necessary changes must also be submitted.

Applicants are reminded that they are responsible for notifying the CFIA of any changes that may affect the registration status of their product.

Considering that the CFIA performs an evaluation of a non-food chemical product on the review of it's chemical composition, the concentration of it's components and the suggested amount when used and not on it's efficacy, we do not object if an establishment wishes to use a product with a different water temperature range then that of the suggested temperature range appearing on the label of a registered product, conditionally to the satisfaction of all interested parties.

Q A7. Is an acceptance letter required for a non-food chemical product destined for the retail market?

Products destined for sale at retail such as food packaging materials or cleaning products for household use do not fall under the jurisdiction of the CFIA, but under the jurisdiction of Health Canada and, therefore, a letter of acceptance from the CFIA is neither required nor applicable.

Products destined for the retail market for food contact application should meet Division 23 of the Food and Drug Regulations. To determine if a product is in compliance with Division 23, an opinion may be requested from Consumer Product Bureau.

This request may be sent to the Consumer Product Safety Bureau. By clicking on the Province where you live, you can reach the office by filling out their feedback form.

http://www.hc-sc.gc.ca/contact/cps-spc/hecs-dgsesc/pso-bsp-eng.php

Telephone: 1-866-662-0666

Q A8. Does the non-food chemical program deal with food additives or food processing aids which are intended to be used in the manufacturing of food products?

The CFIA's non-food chemical program does not include the evaluation of food additives intended to become part of the manufacturing of food products. However, few processing aids such as bleaches/scalding/compound, filters and filtration agents or antifoam agents with food contact and descaling are evaluated by CFIA. For more details concerning the definition of a food additive versus a processing aid, see the following Health Canada website at: http://www.hc-sc.gc.ca/fn-an/pubs/policy_fa-pa-eng.php.

In order to determine if a food additive and its intended use do not contravene the Food and Drugs Act, you may wish to obtain a non objection opinion from the following address:

Bureau of Chemical Safety
Food Directorate
Health Products and Food Branch
Health Canada
Frederick G. Banting Building - Floor: 1
Tunney's Pasture
Address Locator 2201B1
Ottawa, Ontario, Canada
K1A 0K9

Fax: 613-990-1543
E-mail: bcs-bipc@hc-sc.gc.ca

Q A9. Does the CFIA issue registration numbers for accepted products?

No, the CFIA will only issue letters of acceptance for those products that have been found acceptable. Upon the issuance of the letter of acceptance, the product will then be listed, in its appropriate category, on the CFIA web site "Reference Listing of Accepted Construction Materials, Packaging Materials and Non-Food Chemical Products".

Q A10. Does the CFIA maintain a public listing of ingredients/components which are permitted to be present in non-food chemical products used in federally registered food establishments?

No. Each formulated product's list of ingredients/components is evaluated on an individual basis according to its intended use. Only a list of accepted formulated products is maintained by the CFIA.

Q A11. What is a federally registered establishment?

A federally registered establishment is an establishment registered under either the Meat Inspection Act, Fish Inspection Act or the Canada Agricultural Products Act and which are permitted to ship food products from province to province as well as out of Canada.

Q A12. In what manner is confidential information protected by the CFIA?

The CFIA's confidentiality policy is in compliance with the Access to Information and Privacy Acts. You may wish to consult these acts for further information. These acts can be found on the Justice Canada web site at the following addresses:

• Access to Information Act
• Privacy Act

Q A13. Is compliance with the United States' Food and Drugs Act recognized by the CFIA?

Although compliancy with the United States' Food and Drugs Act is to the advantage of a manufacturer wishing to export their products to the United States, this act is a foreign piece of legislation and compliancy with this act does not necessarily imply compliance with Canada's own acts and regulations.

Q A14. Who is responsible to ensure that products used in federally registered food establishments are compliant with respect to the various Canadian Acts and regulations, such as the Food and Drugs Act and Regulations?

Compliance of accepted products with the various Canadian acts and regulations is solely the responsibility of the food packer/manufacturer.

Q A15. How do I find a product or company on the CFIA Reference Listing of Accepted Construction Materials and Packaging Materials and Non -Food Chemicals?

Please consult the Using the Reference Listing Database Guide at the following internet address: http://www.inspection.gc.ca/english/fssa/reference/helaide.shtml

Q A16. How do I obtain Material Safety Data Sheets (MSDS) or Workplace Hazardous Materials Information System (WHMIS) data sheets for accepted products listed on the CFIA web site?

CFIA is not responsible for the issuance of MSDS or WHMIS data sheets for accepted products. To obtain MSDS or WHMIS data sheets, please contact the company manufacturing the accepted product to request copies of the above or you may obtain a copy from Canadian Centre for Occupational Health and Safety at the following internet address: http://www.ccohs.ca

Q A17. What is meant by "incidental contact" with food?

Incidental contact is described as the limited contact of food products with products not destined for direct contact with food. This incidental contact of the product with food products will not pose a health risk to the consumer.

Q A18. Who do I contact for more information?

Regular mail may be sent to the following address:

Chemical Evaluation
Canadian Food Inspection Agency
1400 Merivale Road
Postal Locator: T2-4G
Ottawa, Ontario, Canada
K1A 0Y9

Telephone: 613-773-5842
Fax: 613-773-5642
E-mail: reflist@inspection.gc.ca

B. Non-Food Chemicals

Q B1. What is a non-food chemical?

A non-food chemical is a product used in a food preparation environment and its intended use is not to become part of the food product (e.g. cleaners, disinfectants, sanitizers, etc.)

Q B2. What is a food additive?

A food additive is any chemical substance that is added to food during preparation or storage and either becomes a part of the food or affects its characteristics for the purpose of achieving a particular technical effect. For example, substances that are used to enhance the appearance, texture or keeping qualities of a food or serve as essential aids in the processing of food are all considered to be additives. Antioxidants, preservatives, colouring agents and enzymes are all examples of food additives.

Q B3. What is a maintenance aid product?

Any product used in the maintenance of a food establishment, such as wall and floor repair materials, de-icing compounds and floor drying compounds.

Q B4. What is a processing aid?

For CFIA's purposes, a processing aid is considered to be a product that is used in the manufacture of food products but is not present in the finished food product.

Q B5. What is a barrier cream?

A cosmetic cream applied to the skin as a protective measure against irritants and may require a Cosmetic Notification. See question no. 25.

Q B6. What is a pest control product?

To determine what a pest control product is, please consult Pest Management Regulatory Agency (PMRA) website at the following address: http://www.pmra-arla.gc.ca/english/legis/pcpa-e.html

All pest control products (e.g., pesticides) imported into, sold or used in Canada must be registered in accordance with the Pest Control Products Act and Regulations. All applications for registration must be submitted to the Minister of Health through the Pest Management Regulatory Agency (PMRA). Regular mail may be sent to the PMRA at the following address:

Pest Management Regulatory Agency
Health Canada
Tupper Building - Floor: 7
2720 Riverside Drive
Address Locator 6606D2
Ottawa, Ontario, Canada
K1A 0K9

The PMRA may also be reached either by telephone at 1-800-267-6315 or by fax at 613-736-3798 (for those outside of Canada, please call 1-613-736-3799. Please note that long distance charges will apply). Once an application has been reviewed and accepted, the Minister will issue a pest control product (PCP) registration number. For more information concerning PMRA, see the following internet addresses:

• Application or registration: http://www.hc-sc.gc.ca/cps-spc/pest/registrant-titulaire/index-eng.php

You may wish to consult the Pest Control Products Act and Regulations. The are available on-line from the Justice Canada web site at the following addresses:

• Pest Control website;
• Pest Control Products Act; and
• Pest Control Products Regulations.

Q B7. What is a cosmetic notification?

Sections 10 and 30 of the Cosmetic Regulations of the Food and Drugs Act requires that a cosmetic manufacturer submit a Cosmetic Notification Form to Health Protection Branch (Health Canada) prior to importation of a cosmetic product, or within 10 days of its first sale, if the product is manufactured in Canada. A cosmetic notification is a means of disclosing all ingredients (and their concentrations) in a cosmetic product. Health Canada will review the ingredient makeup of the product to ensure that all ingredients are safe for human and animal use. All information contained on Cosmetic Notification Form submitted to the Microbiology and Cosmetics Section, Product Safety Bureau is entered into the Cosmetic Notification System (CNS), an Oracle-based database. Cosmetic Notification Form Numbers (CNF No.) are assigned by the system to each notification form. For further information on the sale of cosmetic products in Canada, please consult the Health Canada web site at the following addresses:

General Information on the Sale of Cosmetics in Canada: http://www.hc-sc.gc.ca/cps-spc/person/cosmet/ info-ind-prof/_notification/guide-eng.php

Guide for Completing Cosmetic Notification Forms: http://www.hc-sc.gc.ca/cps-spc/person/cosmet/info-ind-prof/_notification/guide-eng.php

May we suggest contacting directly the Consumer Safety Branch for additional information at the following address:

Cosmetics Program
Consumer Safety Branch
Health Canada
123 Slater Street - Floor: 4
MacDonald Bldg,
Address Locator 3504D
Ottawa, Ontario, Canada
K1A 0K9

Telephone: 613-957-4467
Fax: 613-952-3039
E-mail: CPS-SPC@hc-sc.gc.ca

You may also wish to consult the Food and Drugs Act and the Cosmetic Regulations. Both the Food and Drugs Act and the Cosmetic Regulations are available from the Justice Canada web site at the following addresses:

Food and Drugs Act: http://laws.justice.gc.ca/en/F-27/index.html

Cosmetic Regulations: http://laws.justice.gc.ca/en/F-27/c.r.c.-c.869/122960.html

Q B8. Do any non-food chemicals require a Cosmetic Notification Form?

Any non-food chemical which may be considered to be a cosmetic must be submitted for a Cosmetic Notification Form. Health Canada defines a cosmetic product as: "Any substance or mixture of substances, manufactured, sold or represented for use in cleansing, improving or altering the complexion, skin, hair or teeth and includes deodorants and perfumes". Non-food chemicals that may require to submit such a form include hand cleaners, cleaners for personal hygiene and barrier creams.

Q B9. What is the submission protocol for non-food chemicals?

For the evaluation of acceptability, the following CFIA Form must be completed in duplicate: CFIA/ACIA 4031

The form requires the following information:

• The entire chemical composition of the product. This listing will include each ingredient's manufacturer trade name, chemical name, C.A.S. number (Chemical Abstract Service), when applicable, as well as its percentage by weight (or other quantitative measure) in the finished product;
• A draft label of the product;
• Further to the above, additional information may be required, such as toxicity studies or exposure data for certain types of applications.

Q B10. What products are exempted from review by the CFIA?

Non-food chemicals to be used in areas where food is neither prepared, handled nor processed, are considered as exempted products:

See list of products exempt from evaluation by CFIA.

Although these exempted products are not subject to our review, it is expected that these products bare a label which outlines their intended use.

Q B11. What information is required to be included on the label of non-food chemical products?

Every label shall show the following basic information:

• Name and address of manufacturing or distributing firm. The address may be that of the head office of the firm;
• Descriptive name of the product. This is required to be displayed prominently and immediately adjacent to the brand name, to denote the function. A statement on the specific intended use in food establishments must also be included;
• A list of all major ingredients. Should there be a list of active ingredients on the label and major ingredients of product are considered to be non-active, a second list with these major ingredients should be included on the label;
• Direction for use in a food plant, to include any precautionary statements necessary to avoid contamination of food such as "Rinse with potable water", including all necessary information to achieve its technical effect;
• A net content statement;
• Where applicable, the words "Product of…" indicating the country of origin. This statement shall be placed below the descriptive name of the product.

Q B12. Which non-food chemical products require a label?

The following non-food chemical products are required to be labelled: barrier creams, cleaners, decharacterizing agents, denaturing agents, deodorizers, disinfectants, egg treatment compounds, inks, lubricants, maintenance aid products, microbial control agents, pesticides, processing aids, refrigerants/heat exchanger agents, release agents, sanitizers and water treatment compounds.

Q B13. What is the procedure for private labelling of a previously accepted product?

A company wishing to privately label an accepted product must provide the CFIA with a letter from the manufacturer/supplier of accepted product indicating that they will be supplying the company with their product. The company must also submit a draft label for evaluation by CFIA.

Q B14. What is the procedure for submitting an updated label to CFIA concerning a previously accepted product?

The manufacturer (or their representative) should inform CFIA in writing of their intention and supply a copy of the proposed label along with a copy of the official acceptance letter issue by CFIA. Following reception a verification of the amended label and pertinent information by the CFIA, if the amended label is found acceptable an acknowledgement letter is issued to the manufacturer and if applicable, the Register will be amended.

This mandatory procedure is for any company wishing to maintain their appropriate status in the Register.

Q B15. What is the procedure for submitting an additional function to CFIA concerning a previously accepted product?

A manufacturer (or their representative) of a previously accepted non-food chemical, Ex: a Cleaner for food contact surface application registered in the sub-category C1, requesting to have their product accepted as a Sanitizer under the sub-category V1, must provide the CFIA with a completed CFIA 4031 form indicating the product and its function (s) they are referring to with the date of the official acceptance and the new function (s) they which to register their product. Please note that the chemical formulation is not mandatory if it remains the same as previously accepted.

Also, the manufacturer must submit a draft label for evaluation to the CFIA which must include the following: The product's function(s), which must appear in proximity to the product name as outlined on page 2 item (b) of the application form CFIA 4031 as well as appropriate directions for use of this product intended function(s) in food plants. A verification of the amended label and pertinent information will be performed by the CFIA and if the new function (s) and the amended label are found acceptable, a new acceptance letter will be issued to the manufacturer and the Register will be amended accordingly.

Q B16. What is a Drug Identification Number (DIN)?

A DIN is assigned by the Therapeutic Products Programme (Health Canada) to each drug approved for use in Canada in accordance with the Food and Drug Regulations.

Q B17. Do any non-food chemical products require to have a DIN previously assigned to them before being accepted by the CFIA?

The only category of non-food chemicals that require a DIN prior to being accepted by the CFIA are disinfectants used in food handling areas of a food establishment or any other product with having a disinfectant claim on its label.

Q B18. How do I register my product for a DIN?

Submissions for DIN registration should be made to the following address:

Health Product and Food Branch
Therapeutic Products Directorate
Submission and Information Policy Division
101, Tunney's Pasture Driveway, A.L. 0201A1
Ottawa, Ontario Canada
K1A 0K9

Telephone: 613-957-3123
Fax: 613-941-0825
E-mail: SIPDMail@hc-sc.gc.ca

C. Food Packaging Materials

Q C1. What types of packaging material are to be submitted for evaluation?

Any packaging material for use in a registered food establishment which is intended to come in direct or indirect contact with food products should be submitted for evaluation by the CFIA. Such materials include, but are not limited to, the following: paper wraps, wrapping materials, films, synthetic casings, nettings, trays, pouches and bags.

Q C2. Can we use recycled materials in food packaging material?

Recycled materials may be used in the manufacture of food packaging materials.  Recycled materials such as glass, metal and aluminium have historically been used for food packaging applications. However, due to the permeable nature of plastics, the possibility that chemical contaminants (resulting from post-consumer misuse or abuse) remaining in the recycled materials and migrating into food is one of the major concerns regarding the safe use of recycled plastics as food packaging materials. Other issues of plastics recycling also include microbial contamination and structural integrity. As such, the Health Canada has developed a set of guidelines for determining the acceptability of a recycled plastic for use as a food packaging material. These guidelines may be found on the Health Canada web site at the following address: http://www.hc-sc.gc.ca/fn-an/securit/packag-emball/index-eng.php

Q C3. Should we also submit for evaluation those packaging materials which are not intended to be direct or indirect contact with foods?

No. Those packaging materials which are not intended for indirect or direct food contact applications are exempted from evaluation and will not be listed in the reference listing by the CFIA.

Q C4. What is the submission protocol for food packaging materials?

For the evaluation of acceptability, the following CFIA Form must be completed in duplicate: CFIA/ACIA 3826

The form requires the following information:

• Identification of the material;
• Details in regard to the proposed use (i.e. type of food to be packaged, temperatures at which food will be packaged, stored and reconstituted, etc.)
• Additional information, such as migration studies or extraction data, may be required under certain circumstances;
• Complete chemical composition of the packaging material. This listing will include the each chemical/ingredient's manufacturer, trade name, chemical name, C.A.S. number (Chemical Abstract Service), when applicable, as well as its percentage by weight (or other quantitative measure) in the finished product;
• Identification of all chemical agents which are used during the manufacturing process as processing aids but are not components of the finished product;
• A sample of the material. The sample should be adequately identified with all the other information provided. These are to be forwarded to this office freight included (freight, custom duties, brokerage and delivery costs prepaid).

D. Construction Materials

Q D1. Which construction materials are required to be CFIA accepted prior to their use in federally registered food establishments?

Materials used for the construction of interior floors, walls and ceilings surfaces as well as coatings and joint sealants to be used in federally registered food establishments areas where foods are prepared or stored, must be submitted for evaluation by the CFIA.

Q D2. What is the submission protocol for construction materials?

For the evaluation of acceptability, the following CFIA form must be completed in duplicate: CFIA/ACIA 4032

The form requires the following information:

• Identification of the material;
• Complete chemical composition of the construction material. This listing will include each chemical/ingredient's manufacturer, trade name, chemical name, grade, C.A.S. number (Chemical Abstract Service), when applicable, as well as its percentage by weight (or other quantitative measure) in the finished product;
• Complete data on physical characteristics, including resistance to adverse conditions and recommendations for use and application;
• A small representative sample of the finished application including, where applicable, a sealed joint. These are to be forwarded to this office F.O.B. (freight, custom duties, brokerage and delivery costs prepaid).

E. Reference Listing of Accepted Construction Materials, Packaging Materials and Non-Food Chemical Products

Q E1. How often is the reference listing updated?

The reference listing is updated twice monthly.

Q E2. How often does the CFIA publish hard copies of the reference listing of accepted materials?

The CFIA does not provide hard copies of the reference listing of accepted products. The listing on the web site is provided in a downloadable, print-ready format.

F. Equipment

Q F1. Who do I contact concerning the use of equipment (which includes conveyor belts and food transfer hoses) in a meat establishment?

Legislated requirements for equipment intended for slaughtering of food animals and for inspection, handling and storing of edible meat products are outlined in subsection 28.(1)(q) and 28.(1)®) of the Meat Inspection Regulations, 1990.

The CFIA no longer requires prior-to-use acceptance of equipment. Operators of registered establishments will be able to use equipment based on their own evaluation of the equipment for suitability and sanitation.

Equipment intended for use in our Federally Registered Meat Establishments must comply with Section 3.7 of the Manual of Procedures as published by the Meat Hygiene Division. Please see the following link:

http://www.inspection.gc.ca/english/fssa/meavia/man/ch3/table3e.shtml

Q F2. Who do I contact to obtain advice on equipment which is to be used in other food processing establishments?

For food processing establishments such producers of dairy, egg, fruits and vegetables, fish products, please contact your local CFIA Officer at the following internet address:

http://www.inspection.gc.ca/english/directory/offbure.shtml