Good Importing Practices for Food
1.0 Control of Imported Product
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1.1 Product and Shipment Information / Specification
1.1.1 Shipment Information
The importer has controls in place to ensure that a current written description is available for each imported product and each imported shipment.
The importer requires basic written information to identify each imported product in order to ensure that the finished product meets the requirements of Canadian legislation.
Commodity Specific Regulatory Requirements
- Importers obtain and maintain current licences, permits and other specified documentation as evidence of compliance with commodity specific regulatory requirements.
- Where required the importer provides suppliers/shippers with written specifications of commodity specific regulatory requirements with which they are expected to comply.
NOTE: Certain agricultural commodities are subject to additional regulatory requirements, such as import documentation, licensing, etc. The following are some of the pertinent regulations: Processed Products Regulations, Fresh Fruit and Vegetable Regulations, Licensing and Arbitration Regulations, etc.,
A written product description is available and current for each product. The following information may apply:
- common name of the product,
- brand name,
- net quantity declaration,
- product variety,
- product specifications and characteristics,
- container size,
- copy of the Canadian label,
- list of ingredients,
- packaging material,
- final use of the product,
- origin of the product,
- labelling instructions when further labelling is required,
- handling and storage instructions when special requirements exist. (Examples include the following: do not store with non-food items; keep refrigerated; keep frozen; store at room temperature; etc.)
NOTE: When an imported product regulated under the Food and Drugs Act and Regulations does not meet Canadian requirements, importers may avail themselves of Section A.01.044 of the Regulations which permits the importation of a product that violates the Act or Regulations provided that the product may be brought into compliance after its relabelling or modification. Two conditions apply: the importer must notify a CFIA inspector prior to importation, and the product must be corrected before sale.
Tracing Products and Shipments
- A product code and/or lot code is available for each product. (For products such as low acid canned foods, this is a regulatory requirement.)
- The total net quantity of the shipment is available (the number of units times the unit weight).
- Written flow documentation is available for each imported product. This is necessary to trace products and shipments, and to identify and locate the points where control measures and monitoring procedures are required. The importer requires knowledge of the following:
- the controls to which the product has been subjected,
- the product flow (i.e., the port of entry, the carrier, and (if applicable) the import broker),
- the supplier list and relevant supplier information,
- purchase records (the quantity, the product code, the date, the buyer),
- the adequacy of the conditions of transportation and storage to which the product has been exposed.
- The importer is able to obtain the above information upon request.
- Not all the requirements listed above apply to all food commodities. However, Canadian food legislation may specify further requirements for some products. When different lots of bulk product have been blended and it is not possible to trace specific lots, all product involved is treated as a single product.
- For information about downstream traceability (tracing a product's record of sale and distribution), see Section 7.6.2, Distribution Records, in this document. Downstream traceability is necessary in cases where product is recalled.
1.1.2 Assessment of Foreign Manufacturers/Suppliers
Prior to importation, the importer verifies that the manufacturers/suppliers are capable of providing food products that comply with Canadian legislation.
The safety of food products and their compliance with Canadian regulatory requirements is dependent upon the processing procedures and controls in place at the manufacturing facility. Manufacturing facilities should comply with good manufacturing practices (GMP) equivalent to the Codex Alimentarius General Principles of Food Hygiene, and where required, the manufacturer should have a HACCP (Hazard Analysis Critical Control Points) system in place. These controls are necessary to prevent such problems as microbiological, physical and chemical contamination (including contamination with undeclared allergens), and to prevent misrepresentation and fraud.
- The importer can obtain information on request to demonstrate that the critical steps of the manufacturing process are adequately controlled to ensure safety and quality, and to prevent misrepresentation and fraud.
- Evaluation of foreign manufacturers/suppliers is conducted by technically competent personnel.
- In the absence of these controls, the importer conducts increased product control (e.g., sampling, product and laboratory evaluation, third party review) to ensure risks are controlled.
1.1.3 Product Labelling and Composition
The importer has controls in place to ensure compliance with the composition, labelling, nutritional labelling and claims provisions of the Food and Drugs Act and Regulations, the Consumer Packaging and Labelling Act and Regulations and other commodity specific legislation, such as the Canada Agricultural Products Act and Regulations.
Compliance with Canadian food safety standards and compositional requirements promotes a safe food supply and helps ensure that consumers' expectations are met with respect to food composition and quality. The declared composition, compositional standards, nutrition information and claims must be adequately controlled to prevent misrepresentation and fraud, and to prevent such health hazards as the presence of undeclared food allergens.
Mandatory information on food labels allows consumers to make informed choices by:
- providing basic product information (e.g., the product's common name, its list of ingredients, its net quantity, its durable life date and country of origin, as well as the name and address of the manufacturer, dealer or importer), and
- providing health, safety and nutrition information (e.g., instructions for safe storage and handling, nutrition information in the Nutrition Facts table, and specific information on products for special dietary use).
NOTE: "Mandatory information" is determined by the commodity and its regulatory requirements.
- Control factors that are critical to the safety and integrity of the product are identified. (This includes microbiological, chemical or physical concerns, as well as concerns related to allergens, extraneous matter, etc.) Their specifications and limits are identified (e.g., thermal process, pH and water activity for ready-to-eat fermented meats, salt content for brined mushrooms, sulphur content on dried fruit, freedom from Salmonella, etc.)
- Procedures are in place to ensure that imported food which is sold in Canada complies with Canadian nutrient composition and nutrition labelling requirements. This may concern the following:
- added nutrients (i.e., vitamins and minerals) permitted in the specific foods are added at appropriate levels as set out in the Food and Drug Regulations;
- foods for which there are nutrient composition requirements (e.g., meal replacements, nutritional supplements, flour, etc.) meet these requirements;
- the nutrient content of the product is accurately reflected on the label and in compliance with the Food and Drug Regulations (i.e., the list of ingredients and Canadian Nutrition Facts table);
- products for which there are nutrient content claims and/or diet-related health claims meet the Canadian compositional and labelling requirements under the Food and Drug Regulations. (See Section 7, Nutrient Content Claims, and Section 8, Diet-Related Health Claims, in the Guide to Food Labelling and Advertising.)
- Procedures are in place to enable the verification of a product's formulation, its list of ingredients, its nutrient content and nutrient values as stated on the label. These procedures may include, but are not limited to:
- a documented communication system with suppliers which permits access to product specific information (e.g., names and amounts of ingredients, components, additives, and if applicable, added nutrients);
- an overview of the method(s) used to determine nutrient values (e.g., laboratory analysis, the use of a database for finished foods, the use of an ingredient/recipe data base, published values, the use of a consultant or other technical expertise, etc.);
- the name and address of the person responsible for the values;
- possession of, or ability to obtain, complete and current written specification sheets detailing product ingredient and nutrient information;
- product testing and/or information linkages with suppliers of products that are sole sources of nutrients (such as baby formula) and foods for special dietary use (such as meal replacements and nutrition supplements).
- Products are periodically reviewed against the Nutrition Labelling Compliance Test to assess the accuracy of nutrient values.
- Controls are in place to ensure that standardized products meet labelling and/or legislative compositional requirements (e.g., Brix for jam). These controls may include, but are not limited to:
- vendor certification,
- product testing (including testing some products to Canadian and/or international standards).
- For products that are subject to intentional adulteration, such as olive oil, the importer has more stringent verification controls in place. This should include testing for authenticity at a Canadian laboratory certified with the Canadian Standards Board for testing of the specific food, or another scientific organization, such as AOAC, etc.
- The importer has procedures in place to ensure that all mandatory information is properly declared on food labels in compliance with Canadian food labelling requirements, and that all label claims are accurate and not misleading. Examples of such procedures are listed below.
- Labels are reviewed both for compliance with Canadian legislation (e.g., presence of mandatory labelling), and for accuracy and correctness of information. This assessment includes, but is not limited to:
- mandatory information, quality claims (e.g., organic, natural, fresh, Kosher, etc.), compositional claims (e.g., no preservatives, etc.), nutrition claims, and standards of identity.
- Any changes to labels (e.g., changes to artwork, text and layout) and packaging (e.g., changes in the size of the principle display surface, available display surface or the location of the principle display panel) are reviewed, in conjunction with suppliers, for compliance with Canadian legislation.
- Any changes in formulations are assessed, in conjunction with suppliers, for their impact on product labelling. This includes any changes in suppliers or brands of ingredients, which can have an impact on labelling, composition, or claims (for all formats of the specific product).
- In the case of corrective labels applied in Canada, incoming labels from labelling and/or printing companies are reviewed against signed-off proofs.
- All pamphlets, posters, handouts and other Canadian advertising materials developed and/or distributed by the importer are reviewed and verified for accuracy and compliance with Canadian legislation. (See Section 3 of the Guide to Food Labelling and Advertising.)
- The importers have obtained allergy-related information from their suppliers and manufacturers. This information can be used to conduct hazard analysis and assess the need for label changes, including the need for any precautionary statements on the label (e.g., "may contain peanuts").
i. Labelling requirements are set out in the Guide to Food Labelling and Advertising. The above is not a complete listing of all labelling requirements.
ii. The following guidance documents provide further direction on compositional and labelling issues and are available on the CFIA Web site.
- For information on Canada's priority allergens, see Food Allergens, Gluten and Added Sulphites.
- For the labelling requirements for nutrition labelling, see the CFIA document Evaluation Standard for Nutrition Labelling.
1.1.4 Food Additives
With respect to the use of food additives, the importer ensures that all imported food meets the requirements of the Food and Drug Regulations as well all other applicable regulatory requirements.
Inadequate control of food additives could result in chemical/biological hazards and violation of Canadian regulations.
- The importer ensures that all food additives contained in an imported food product are permitted for use in the particular food and meet the requirements of the Food and Drug Regulations (Division 16) and other applicable regulations.
- The importer has access to specifications for all food additives.
- Where there are no specifications in the Food and Drug Regulations, the importer requires that all food additives meet the specifications of the Food Chemical Codex (FCC) or equivalent. For example, suppliers may use specification sheets or blanket guarantees.
- The importer can demonstrate that any food additive which is used is within the maximum level specified in the Food and Drug Regulations.
1.1.5 Net Quantity
The importer ensures that net quantity declarations are accurate and comply with the Consumer Packaging and Labelling Act and Regulations (CPLA/R) and other commodity specific legislation, such as the Canada Agricultural Products Act and Regulations.
The net quantity declaration provides important information which consumers use in making their purchasing decisions. Since the declaration helps consumers to know how much food is in a container, it enables them to compare prices. Consumers rely on net quantity declarations, trusting importers to provide the quantity declared on a product's label. Companies that do not declare accurate net quantities for their products have an unfair competitive advantage within their market sector, and do not contribute to the fair and effective operation of the marketplace.
Canada, as a member of Organisation Internationale de Métrologie Légale (OIML), uses an international measurement standard as its method of determining the accuracy of net quantity declarations. The Average System is set out in Section 39 of the Consumer Packaging and Labelling Regulations.
- The importer has procedures in place to ensure that the product's net quantity is in compliance with the Average System of Net Quantity Determination as outlined in Section 39 of the Consumer Packaging and Labelling Regulations. These procedures may include, but are not limited to:
- documented communication systems with suppliers, from which the importers can obtain, upon request, detailed net quantity verification information (e.g., results of net quantity verifications, sample scheduling and protocol, corrective actions on failed lots, etc.);
- in-house net quantity verifications of imported products. The frequency of these verifications is determined by several factors, such as the type of product, its packaging technology and its source. (For example, has the supplier a track record for reliability?)
The importer has controls in place to ensure that products comply with the applicable grade standards prescribed by Canadian legislation.
Inadequate control of grade may result in misrepresentation of the product. It may also may lead to the increased importation of sub-standard product. Grades exist under the Canada Agricultural Products Act and Regulations.
- Controls are in place to ensure that imported products meet the grade requirements prescribed by the pertinent Canadian regulations. These control mechanisms may include the following:
- the importer has written purchasing specifications to ensure product meets the prescribed grade;
- the importer retains copies of written grade specifications for shipments of product purchased;
- where required, the importer ensures that each shipment is accompanied by a valid foreign grade certificate from sources prescribed by the regulations;
- where applicable, the importer obtains the appropriate Canadian grade inspection certificate to verify compliance with the legislated requirements;
- where grade certificates are not available from foreign or local inspection services, the importer has a system to monitor the grade and/or quality requirements of arriving product;
- the importer has access to trained personnel (such as graders and quality control personnel) to assess the grade of incoming product.
- For imported products arriving in damaged or deteriorated condition, the importer follows procedures to ensure that products or commodities are brought into compliance by:
- re-grading the produce and providing evidence that the re-graded lot meets the specified grade (by providing a valid CFIA grade inspection certificate, for example);
- providing evidence of the disposal or dumping of deteriorated product which does not meet grade (by providing a CFIA dump certificate, for example);
- providing evidence of the use of the shipments for processing (by providing an invoice from the processor indicating the quantity used for processing, and a letter on company letterhead confirming the use of the product for processing);
- providing evidence of disposition of the products for charitable use (by providing a letter on the letterhead of a charitable organization acknowledging the disposition of the shipment to charity).
- For other graded product, the importer employs qualified graders and/or inspectors to sample and grade the contents of each shipment, and retains a copy of the Grade Inspection report for each shipment.
1.2 Receiving of Imported Product
1.2.1 Incoming Food Product Control
The importer controls incoming products so that foods are not exposed to safety hazards (biological, physical or chemical) and labelling inaccuracies are prevented.
Importers are responsible for ensuring that imported products meet the specifications set out in the Section 1.1 of this document, Product Information/Specification. Prevention of health hazards and fraud begins with control of incoming materials. Inadequate incoming product controls (e.g., lack of appropriate product testing and sorting, lack of verification of labels, etc.) could result in the sale of contaminated products, misrepresented products or products that do not meet grade, composition or quality standards.
NOTE: Not all Incoming Food Products require the same degree of control. The degree of control exercised should be appropriate to the level of risk posed by the food product.
- All incoming product is visually inspected to ensure each product meets specifications and Canadian requirements.
- The importer has identified, for each product, the specific concerns that apply, considering various types of hazards (microbiological, chemical and physical hazards, and extraneous matter) and issues such as fraud, grade, etc.
- The importer has set "Acceptance/Rejection" criteria for each product.
- Personnel involved in the inspection of incoming material have adequate technical knowledge and understanding of the significance of the concerns.
- Packaging material is appropriate for the intended use and is used in accordance with the packaging manufacturer's instructions. The appropriateness of packaging will vary with the product and process and the associated contamination risks.
- The importer controls incoming products through one of the following programs or equivalent, listed as Options 1 - 4 below.
- The above controls may be carried out by the importer or by a designate, e.g., a public warehouse representative, a client or a third party.
- The nutrition information may be conveyed on an accompanying hard copy document with the delivery of the food.
- In the case of foods that are shipped to a purchaser on a continual basis, with no change to the formulation, documentation may be provided on the basis of the first shipment. The purchaser should be advised of any change to the nutrition information as a result of formulation changes or other influences.
Controlling Incoming Products: Options 1 - 4
The first three options apply to products where the risks to safety are high. The fourth option applies only to food products which are not likely to pose a safety risk, but may require controls of quality and composition.
OPTION 1: Periodic Evaluation of Incoming Products
- The importer obtains a certificate of analysis (in English or French) for each lot ,which includes the following:
- the sampling procedure(s) and analytical method(s) used to ensure the lots are acceptable by the CFIA;
- the date, the type of determination to which the food was submitted, the individuals/organizations conducting the analysis, product identification (including the brand and lot number), and the name and signature of the analyst;
- a verification that the lot was recently sampled and was stored under appropriate conditions to prevent any changes which may render the product unacceptable for sale.
- A representative sample is regularly taken and analysed to verify the accuracy of the certificates of analysis. Samples are taken at a scheduled frequency (e.g., monthly).
- The importer maintains a documented history for each supplier, indicating the supplier's adherence to specifications (e.g., documenting analytical results).
- A new history of adherence to specifications is established when a firm changes suppliers, purchases product from a new supplier, purchases a new product from an existing supplier or when the importer's sample results do not agree with the certificate of analysis.
OPTION 2: 100% Lots Inspected
- Each incoming lot is sampled according to a pre-determined sampling plan and analysed for adherence to specifications.
OPTION 3: Vendor Certification
- When the importer relies on vendor certification, the importer has data to demonstrate the capability of the supplier's process to consistently manufacture within specifications. This may include process capability studies. Statistical process control charts for each critical control point must be available upon request from each supplier.
- Prior to implementing a periodic monitoring program, the importer has analyzed an appropriate number of consecutive lots to establish an historical data base to confirm adherence to specifications.
- The importer conducts periodic monitoring to verify adherence to specifications (e.g., annually).
- The importer conducts vendor audits to validate the status of the vendor certification program.
OPTION 4: Specification Requirements (to be utilized only when food safety risks are unlikely)
- Where incoming products are not likely to have an impact on the food safety, the importer conducts periodic monitoring to verify adherence to specifications (e.g., annually), or obtains a certificate of analysis.
NOTE: For certain products (i.e., some fresh fruit and vegetables), the frequency of monitoring to verify adherence is mandated by regulation.
Non-Conforming Incoming Products
- When products fail to meet specifications, the importer investigates and identifies the root cause. Procedures are in place to ensure that non-conforming products are not sold in Canada, or that the non-conformance is corrected prior to sale. (See Section 1.4 of this document, Deviations and Corrective Action.)
1.3 Product Coding Control
1.3.1 Product Code
Each package of food is identified with code marks, lot numbers and expiration dates or best before dates (when applicable) on the label or container.
Coding permits products to be traced through the distribution chain and facilitates recalls. Where the code is also a best before date or an expiry date, it provides information on shelf life and safe consumption of the product.
NOTE: Mandatory coding requirements vary between commodities, and are specified in appropriate legislation. To confirm specific requirements governing various food products, importers should consult with inspection authorities.
- The importer ensures that, where required or applicable, imported food has been permanently marked with a legible code or lot identification. The coding system:
- identifies the establishment, as well as the day, month and year in which the food was produced.
- The importer ensures that the code marks used and the exact meaning of the code (e.g., colour codes) are available.
- Where used, case codes are legible and represent the container code within.
- Where applicable, the code accurately reflects the best before date, expiration date, or shelf life of the food.
- Where applicable, the manufacturer controls the application of codes to ensure that the integrity of the container is not compromised.
1.4 Deviation and Corrective Action
1.4.1 Deviation Control
When critical limits are exceeded or defects occur which could affect product safety, composition or net quantity, procedures are in place to identify, isolate and evaluate products.
Inadequate deviation procedures or non-adherence to procedures could result in the sale of unsafe products, misrepresented products or products of inferior grade.
NOTE: Deviation procedures apply to all sections of this standard, where appropriate.
- The importer has a pre-determined and documented deviation procedure to identify deviations in products and procedures, to isolate affected products, and to evaluate them. Criteria are described below.
Identification of Deviation
- The importer has a system in place to identify deviations when they occur.
Isolation of Affected Product
- The importer has effective procedures in place to isolate all product manufactured during the deviation period. All unsatisfactory product is isolated back to the point where the process was last in control. This could be beyond the last satisfactory record.
- Isolated product is clearly marked (e.g., firmly attached tags contain the following information: hold number, product, the amount, the date held, the reason for the hold, and the name of the person holding the product).
- The importer maintains control of all product manufactured during the deviation period (i.e., from the time the product was first put on hold until final disposition).
Evaluation of Affected Product
- Product evaluation is conducted by a qualified person.
- Disposition of affected product (e.g., sorting of suspect lots, disposal, etc.) is conducted in an appropriate manner by adequately trained personnel.
- Evaluation is adequate to detect potential health hazards, or to identify misrepresentation or product that does not meet quality or grade requirements. For example:
- sampling is adequate to identify the extent of the problem, the tests are appropriate, the judgement is based on sound science and the product is not released until the evaluation has determined that the product is in compliance with appropriate legislation.
1.4.2 Corrective Action
Corrective action taken following any deviation is effective to rectify the problem and to prevent recurrence of the deviation.
Corrective action procedures are necessary to determine the cause of the problem and to take action to prevent recurrence. It is essential to follow-up any corrective action with monitoring and reassessment, to ensure that the correction has been effective. Appropriate corrective action will address the root cause of any deviations of critical control points, thereby minimizing health risks and product misrepresentation.
- As part of the deviation procedure, the importer has a set of documented corrective actions that include:
- an investigation to determine the cause of the deviation;
- effective measures taken to prevent recurrence of the deviation;
- verification by the importer of the effectiveness of the corrective action taken.
See Section 7.2.3, Deviations and Corrective Action Records.
1.5.1 Verification Procedures
The importer uses supplementary methods of evaluation to verify the effectiveness of controls affecting product safety, composition, representation, quality and compliance with Canadian legislation.
The purpose of verification is to assess the effectiveness of existing controls in preventing health hazards, economic fraud and deviations from Canadian regulatory requirements, and to indicate areas where improvements are required.
- The importer verifies the effectiveness of controls affecting product safety, misrepresentation and other concerns.
NOTE: The verification methods will vary with the product and process, since the methods must be appropriate to the specific hazards and risks which may be encountered. Verification applies to all sections of this standard (e.g., from receiving product to training personnel), where appropriate.
Examples of Verification Methods
- Verification methods may include the following:
- sampling and analysis of finished product for the appropriate chemical, microbiological or physical hazards;
- sampling and analysis of finished product for composition and net quantity;
- independent, external audits;
- internal audits;
- incubation testing to confirm commercial sterility/hermetic seal;
- visual/mechanical/electronic screening;
- analysis of consumer complaint trends;
- vendor audits.
Frequency of Verification
- The importer conducts verification to validate the effectiveness of the manufacturing controls at a frequency appropriate to the hazards associated with the product and process.
Responsibility for Verification
- Individuals or organizations responsible for verification are identified. These individuals or organizations are suitably qualified.
See Section 7.2.4, Verification Records.
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