Record of Decision - GIP (Good Importing Practices) / Import Inspection activities when imported dairy products are used as an ingredient in other foods

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Question or Description of Problem:

Section 16.6.3 of Chapter 16 (Importing Activities) of the Dairy Products Inspection Manual (DPIM) describes different importer facility types and import inspections or activities required under the Dairy Program. However, inspection activities required when an establishment is importing dairy products solely for use as an ingredient in other foods are not clearly defined. Further interpretation / clarification is needed as to what inspection activities are required when facilities are importing dairy products for use as ingredients in other foods and when these facilities are licensed as cheese importers under the Dairy Products Regulations (DPR).

Background:

In addition to facility inspections, importing activities also include import documentation review, product inspections (can integrity, label and net quantity), lab sampling, and other activities (IREP, CDC).

As per Section 16.6.3 (iv) of the Import Chapter, “establishments importing dairy products for use as an ingredient in other food products (e.g. bakeries, restaurants) are not inspected by the Dairy Program”. These establishments can be further divided into any of the following types of facilities:

  1. Non-Registered establishments that import dairy products, other than cheese, (e.g. butter, milk powders, etc.) for use as an ingredient in other food products (e.g. bakeries, restaurants);
  2. Establishments registered under another Canadian Food Inspection Agency (CFIA) program (e.g. Processed Products, Meat) that import dairy products, other than cheese, (e.g. butter, milk powders, etc.) for use as an ingredient in other food products;
  3. Non-Registered establishments and/or establishments registered under another CFIA program that import dairy products for use as an ingredient in other food products and hold a Cheese Import License under the DPR.

In many cases, these establishments are not registered or licensed under the DPR, thus, the establishment (physical facility) is not inspected by the Dairy Program. Premise Inspections for these facilities would fall under the Imported and Manufactured Food Division (IMFD) of the CFIA, provincial, and/or municipal authorities.

Requirements related to a cheese import license are specified in Sections 26.2 to 26.6 of the DPR. Section 16.5.2 of the Import Chapter states that the conditions for an establishment to maintain a Cheese Import License, will be monitored and evaluated by CFIA Inspectors as per Section 16.6.3.

This is not a new policy but rather a clarification in the interpretation of the dairy product inspection activities to provide for consistency in the delivery of importing activities when dairy products are imported for use as ingredients in other food products.

Decision:

As per Section 16.6.2 and 16.6.3 of the Import Chapter:

  1. Import Declaration reviews must be completed by the dairy inspector for all dairy imports.
  2. Product verification activities (container integrity, label, net quantity) will not be performed in these establishments, unless there has been a complaint or any suspected food safety issues
  3. Product Sampling (micro, composition, chemical residue) may be conducted at any establishment as per annual Sampling Plans and Guidelines of the Dairy Program.
  4. Environmental sampling may be conducted at these establishments as required.
  5. Importer Verifications/Facility Inspections (by using the Importer Verification Worksheet, Appendix 12):
    1. Full Importer verifications are not required at these establishments. Many of these tasks (e.g. water quality, storage conditions, sanitary conditions, etc.) will be covered either by other CFIA programs or Provincial and/or Municipal authorities; however, the fist four tasks of the worksheet (tasks 1.1, 1.2, 1.3, 1.4) must be completed on every visit (e.g. during visits for product sampling).
    2. For establishments that import dairy products and also hold a Cheese Import License, an annual visit is required to ensure conditions for maintaining a Cheese Import License are being met. In addition to the first four tasks of the worksheet, tasks 1.8 Pest Control, 1.9 Complaint Handling, 1.10 Recall Procedures, 1.11 Water Quality, 1.12 Sanitation Program, 2.2 Product Coding must also be completed.
    3. Annual visits are not required for non-registered establishments that import dairy products, other than cheese for use as an ingredient in other food products, and for establishments registered under another CFIA program that import dairy products, other than cheese for use as an ingredient in other food products.

Jennifer Williams
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Recommended by: Program Chief (Acting)

13/11/2012
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Date

Wassim El-Khoury
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Approved by: National Manager

13/11/2012
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Date

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