Notice to Industry - Undeclared Egg in Imported Surimi and Surimi-based Products

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June 27, 2016 – Ottawa, ON – Canadian Food Inspection Agency:

The Canadian Food Inspection Agency (CFIA) is finding a high number of surimi and surimi-based products imported into Canada containing undeclared egg protein. Egg is considered a priority allergen in Canada and can pose serious health problems for some consumers.

It is the responsibility of fish processors and fish importers to ensure that the products they process or import comply with Canadian regulations. This includes labelling requirements such as those under the Consumer Packaging and Labelling Act, the Food and Drugs Act and its regulations, and the Fish Inspection Regulations. Allergens present in food must be declared and cross-contamination of allergens should be controlled throughout production.

The CFIA continues to monitor fish products for the presence of undeclared allergens. Imported products that contain undeclared allergens, including egg, are not allowed on the Canadian marketplace and are subject to control actions, including seizure and recall. Importers who import non-compliant fish products are in violation of the Food and Drugs Act and the Fish Inspection Regulations. Recurring non-compliance may lead to enforcement actions such as import license suspension, revocation or non-renewal, or prosecution.

Control measures that industry can use to help ensure that their products are in compliance with allergen labelling requirements include but are not limited to the following:

  • conduct label, formulation and ingredient verifications on your products to ensure all allergens present are declared;
  • verify supplier-based controls to ensure they are properly preventing cross-contamination and are labelling products to reflect the presence of allergens;
  • establish supplier quality assurance agreements that include controls as noted above.

Testing of products at a CFIA recognized accredited laboratory (Standards Council of Canada or Canadian Association for Laboratory Accreditation) may be used to verify that the implemented control measures are effective.

In cases where the unintentional presence of an allergen is unavoidable despite having taken all reasonable preventive and control measures, the CFIA strongly encourages that a precautionary statement, such as "May contain egg", be added to the label after the list of ingredients to warn allergic consumers.

By demonstrating that products meet Canadian labelling requirements, importers can help ensure their products reach the Canadian marketplace.

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