Guide to Importing Food Products Commercially
Section E - Summary of Import Requirements for Food Commodities
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This section contains a summary of commodities that are subject to specific import requirements for commercial shipments or have specific compositional requirements.
As outlined in Section A, all foods sold in Canada are subject to the Food and Drugs Act and Regulations, which contain health and safety requirements, labelling requirements and provisions preventing deception and fraud. However, many agricultural and fish products are also subject to other legislation. Consequently, the need for licensing, permits and certificates varies depending upon the type of food being imported and, in some cases, on the country or area from which the food is imported.
In certain circumstances the importer is required to be licensed with the Canadian Food Inspection Agency. This applies, for example, to importers of fish products. In other cases, each shipment of a specific commodity must be accompanied by an official certificate from the authorities of the exporting country and/or an approval or permit from the appropriate Canadian federal department. For some products, such as dairy products, the importer is required to provide an Import Declaration to the effect that the product is sound and fit for human consumption.
The Canadian Food Inspection Agency's Automated Import Reference System contains detailed information on the federal import requirements for all foods.
It should be noted that in some provinces there are additional requirements for certain foods, such as dairy products, margarine, bottled water, and maple syrup.
A Note on TRQs
Certain agricultural goods are subject to Tariff Rate Quotas (TRQs) and some require an import permit issued by the Department of Foreign Affairs, Trade and Development. TRQs and the presence or absence of import permits may drastically affect the rate of tariff charged for a commodity. Please note that firms importing restricted goods without a specific import permit will automatically be charged the high tariff rate by Canada Border Services Agency. At this point, specific import permits will not normally be issued. (For more information regarding TRQs and Import Permits, see Section G).
The Importation of Intoxicating Liquors Act, a federal statute, gives the provinces and territories full control over the importation of intoxicating liquor into their jurisdictions. (Note: there are certain exceptions, such as bulk importations by licensed distillers and brewers for blending purposes). Consequently, importers should consult the appropriate provincial or territorial liquor authority before considering the importation or interprovincial trade of intoxicating liquor. (See Appendix II for contact information).
Standards of identity and labelling requirements for alcoholic beverages exist in the Food and Drugs Act and Regulations, the Consumer Packaging and Labelling Act and Regulations and the Excise Act and Regulations. Standardized container size requirements for wine exist in the Consumer Packaging and Labelling Regulations.
In addition to the basic food labelling provisions, alcoholic beverages are subject to further requirements, such as the declaration of alcohol content by volume.
Butter, cheddar cheese, dry milk products and variety cheeses are regulated by the Dairy Products Regulations under the Canada Agricultural Products Act. Imported dairy products must comply with these regulations, which cover quality, labelling, packaging and grading, as well as health and safety. In addition, the Health of Animals Act restricts the importation of certain dairy products from countries where the presence of animal diseases poses a threat to Canadian agriculture and health. Most dairy products also require an import permit issued by the Department of Foreign Affairs, Trade and Development. (Please see Section G for further information).
An Import Declaration, completed in duplicate, must accompany each dairy product shipment, indicating that the products were manufactured from sound raw materials and prepared under sanitary conditions, and that the products were sound and fit for human consumption at the time of shipment.
All cheese importers must hold a valid cheese import licence issued by the Canadian Food Inspection Agency in order to import cheese. At present, there is no federal requirement for importers of other dairy products to be licensed. Product inspection may take place at the product's entry point or at its destination point, at the discretion of the Canadian Food Inspection Agency.
Eggs and Processed Eggs
Both shell and processed chicken eggs must meet the requirements set out in the Egg Regulations and Processed Egg Regulations, respectively, of the Canadian Agricultural Products Act. Shell eggs are destined for either the table market or breaking stock. Processed eggs are frozen egg, frozen egg mix, liquid egg, liquid egg mix, dried egg, dried egg mix and egg product, including all products consisting of 50 percent or more of egg.
These products may only be imported from a country with an inspection program and grade standards equivalent to Canada's. Shipments will be inspected upon entry into Canada and must be accompanied by inspection documentation issued by officials of the exporting country, certifying that the products conform to Canadian standards.
Both shell eggs and processed eggs require an import permit issued by the Department of Foreign Affairs, Trade and Development. (Please see Section G for further information). In addition, the Health of Animals Act restricts the importation of eggs and processed eggs from countries where the presence of animal diseases pose a threat to Canadian agriculture and health.
Eggs from different species of birds, balut eggs, and preserved duck eggs, are not subject to the Egg Regulations. However, eggs and egg shells from birds and reptiles listed under the Convention on International Trade in Endangered Species (CITES) require export permits from the country of origin and, in some cases, import permits issued by Environment Canada under the Wild Animal and Plant Protection and Regulation of International and Interprovincial Trade Act (WAPPRIITA). (See Section B: Environment Canada; Section E: Wildlife; and Section F: Import Procedures and Documents).
Fish and Fish Products
Fish and fish products are subject to the Fish Inspection Act and Regulations, which contain requirements for wholesomeness, labelling, packaging, grading, and health and safety.
Importers of fish and fish products must have an Import Licence issued by the Canadian Food Inspection Agency and must notify the closest Canadian Food Inspection Agency fish inspection office in writing each time they import fish.
Restrictions apply to the importation of aquatic animals. Import permits are required for susceptible species of finfish, molluscs, and crustaceans. These animals must meet the import requirements to enter Canada.
All sturgeons are regulated by the Convention on International Trade in Endangered Species (CITES). This means that all sturgeon, including their meat and caviar, require a CITES export permit from the exporting country. Some species also require a CITES import permit issued by Environment Canada.
In the absence of specifications under the Food and Drug Regulations, food additives must conform to specifications in the Food Chemicals Codex, Fourth Edition, 1996 (as required by Section B.01.045 of the Food and Drug Regulations).
The labels on food additive preparations must include either a quantitative statement of the amount of each additive present, or directions for use which, if followed, will produce a food that does not contain additives in excess of the maximum levels as prescribed in Division 16 of the Food and Drug Regulations.
Synthetic food colours are unique because they are the only additives that must be certified by the Health Products and Food Branch, Health Canada before being used in foods. Regulations concerning food colours are listed in Division 6, and Table III of Division 16 of the Food and Drug Regulations.
Before a colour destined for use in food may enter the country or be distributed for use, it must be certified. Health Products and Food Branch officials both administer and audit a certification program for manufacturers of food colour. Manufacturers who participate in this program can obtain "self-certification status".
If the request for certification is approved, a certificate number (CN) is issued, and the Canadian importer is supplied with a letter indicating that the specific lot of dye (identified by lot number and quantity) has been assigned a specific CN. This number covers only the colour and shipment identified in the letter.
A copy of the letter must be presented by the importer to Canada Border Services Agency before the dye is released from Customs. At present, certificates issued by the United States Food and Drug Administration (FDA) are also acceptable in Canada.
Procedures for Food Colour Lakes are somewhat similar, except that they must be manufactured from a certified colour. Identification Numbers (IN) are issued instead of CN numbers.
Further information on the certification program can be obtained from the Health Products and Food Branch, Health Canada, (see Appendix II for contact information).
Foods for Special Dietary Use, including Weight Loss
The composition and labelling of foods for special dietary use are regulated under Division 24 of the Food and Drug Regulations and include: formulated liquid diets, meal replacements, carbohydrate-reduced foods, sodium reduced foods, low calorie foods, etc.
It is important to note that the only food products that may be promoted for use in a weight reduction diet are meal replacements, foods for very low calorie diets, prepackaged meals that meet the requirements of Division 24 of the Regulations and foods sold in weight loss clinics to clients for use in their programs. No other foods may be promoted for weight loss.
Fresh Fruits and Vegetables
Fresh fruits and vegetables, including nuts and edible fungi, are regulated by the Fresh Fruit and Vegetable Regulations under the Canada Agricultural Products Act. These regulations cover quality, labelling, packaging, grading, and health and safety requirements.
Commercial importers of fresh fruits and vegetables must have a Produce Licence issued by the Canadian Food Inspection Agency or be a member of the Dispute Resolution Corporation (DRC). Each shipment of fresh produce must be accompanied by a Confirmation of Sale form in triplicate, which is the importer's evidence that there is a firm purchase agreement. This form is reviewed by a Customs officer at the products' point of entry, and relayed to the Canadian Food Inspection Agency.
To ensure compliance with Canadian standards for safety, quality, labelling, packaging and grading, all shipments of fresh produce are subject to examination upon entry into Canada by an inspector of the Canadian Food Inspection Agency.
Special requirements also exist for the importation of products shipped in bulk.
To prevent the introduction and spread of plant diseases and pests, fresh fruits and vegetables are subject to the Plant Protection Act and Regulations. Consequently, the Canadian Food Inspection Agency requires import permits and/or phytosanitary certificates for certain fresh fruits and vegetables from specific countries or states.
For detailed information regarding Canadian import requirements for fresh fruit and vegetables, refer to the Canadian Food Inspection Agency's Overview - Import and Interprovincial Requirements for Fresh Fruit and Vegetables page.
Information on Canadian plant protection requirements may be found at the Automated Import Reference System (AIRS).
Fresh fruit and vegetables derived from a plant with a novel trait (i.e., derived from biotechnology) are considered novel foods (see section on novel foods).
Fruit and Vegetable Products - Processed
Processed fruit and vegetable products include canned and frozen fruits and vegetables as well as some other fruit and vegetable products (vegetable soup, prepared mustard, spaghetti in tomato sauce, etc.)
Imported product must comply with the Processed Products Regulations under the Canada Agricultural Products Act. These regulations cover quality, labelling, packaging (including standardized sizes), grading, and health and safety requirements.
Each shipment must be accompanied by an Import Declaration form in duplicate, which indicates that the products meet the requirements of the Processed Products Regulations and were processed under sanitary conditions, and that they were sound, wholesome and fit for human consumption at time of shipment. At present, there is no federal requirement for importers of processed fruits and vegetables to be licensed.
All shipments are subject to inspection by the Canadian Food Inspection Agency at their destination point.
The section "Low Acid Foods in Hermetically Sealed Containers" contains further information.
There are Tariff Rate Quotas for wheat, barley and their products. Consequently, an import permit issued by the Department of Foreign Affairs, Trade and Development is required to import these products. (Please see Section G for further information).
Please note that grains derived from a plant with a novel trait (i.e., derived from biotechnology) are considered novel foods.
The Canadian Grain Commission and the Canada Border Services Agency may also have requirements regarding the importation of grains into Canada and should be contacted prior to importation.
Honey and honey products are regulated by the Honey Regulations under the Canada Agricultural Products Act. Imported products must comply with these regulations, which cover quality, labelling, packaging, grading, and health and safety requirements.
Each shipment of honey and honey products must be accompanied by an Import Declaration, Request for Release Approval and Customs Transaction Document. This documentation must be presented to the CFIA National Import Service Centre for clearance before shipments are allowed entry into Canada by CBSA officers. The importer or the importer's authorized agent must declare that the honey meets the requirements of the Honey Regulations. This means that the honey was prepared under sanitary conditions, and is wholesome and fit for human consumption. All shipments of honey are subject to inspection at their destination point, by the Canadian Food Inspection Agency.
The Canadian Food Inspection Agency restricts the importation of honey from countries where the presence of animal diseases poses a threat to Canadian agriculture and health.
Infant Formula (Human Milk Substitutes)
The composition and labelling of foods for infants are regulated under Division 25 of the Food and Drug Regulations. In the case of new infant formulas and those which have undergone a major change, manufacturers and importers are required to notify Health Canada of their intention to market the products. The information to be submitted in this "pre-market notification" is outlined in Division 25 of the Regulations. It permits Health Canada to conduct a thorough safety assessment for the proposed product.
Low Acid Foods in Hermetically Sealed Containers (Canned Foods)
Low acid foods in hermetically sealed containers (LAFHSC) are foods that generally have a pH greater than 4.6, a water activity greater than 0.85 and are packaged in containers that preclude the entrance of microorganisms and air. Traditionally, these products have been limited to canned vegetables, mushrooms, meat, fish and poultry. However, with the recent progress in food technology and packaging techniques (including the tetra-pak container concept), and with the influx of new foods to the Canadian market, the variety of low acid foods in hermetically sealed containers is increasing very rapidly.
These foods, if improperly processed or packaged in damaged, leaky containers, can provide a perfect medium for the growth of bacteria which may cause illness (including botulism, a potentially deadly form of food poisoning). Division 27 of the Food and Drug Regulations contains requirements specific to these products to prevent and control any public health threat.
Food labels or containers must bear a legible and permanent code or lot number that identifies the establishment and the date (day, month and year) the food was processed. The importer must be able to provide the exact meaning of this code or lot number to an inspector upon request.
Knowledge of the production and quality control procedures implemented at the manufacturing plant is important, in order to ensure that the imported food is safe and does not pose a health hazard.
MargarineMargarine is on the Import Control List established under the Export and Import Permits Act. Therefore, an import permit issued by the Department of Foreign Affairs, Trade and Development is required to import margarine. (Please see Section G for further information). The Food and Drug Regulations outline standards of identity and composition for both margarine and calorie-reduced margarine. Certain provinces may also have restrictions on the addition of colour to margarine.
Maple products include maple syrup, maple sugar, soft maple sugar, maple butter and maple taffy that are obtained exclusively from maple sap.
Imported maple products must meet the requirements of the Maple Products Regulations under the Canada Agricultural Products Act. These regulations cover quality, labelling, packaging (including standardized sizes), grading, and health and safety requirements. At present, there is no federal requirement for importers of maple syrup and maple products to be licensed.
All shipments are subject to inspection at their destination point by the Canadian Food Inspection Agency.
Meat and Poultry
Importation of meat and poultry meat products into Canada is regulated by the Meat Inspection Act and Regulations and the Health of Animals Act and Regulations, administered by the CFIA, and the Export and Import Permits Act, administered by the Department of Foreign Affairs, Trade and Development.
Before the products are imported, the exporting country must be evaluated by the Canadian Food Inspection Agency and found to have a national meat inspection system, including a residue monitoring program, equivalent to that of Canada. As well, foreign establishments must be approved by the Canadian Food Inspection Agency before being eligible to export to Canada.
To prevent the introduction of animal diseases, all importations of meat products are subject to the Health of Animals Act and Regulations. Some foreign countries are restricted in the type of product they can export to Canada.
Shipments of poultry (fresh or prepared) and fresh, chilled and frozen beef from non-NAFTA (North American Free Trade Agreement) countries usually require an import permit issued by the Department of Foreign Affairs, Trade and Development. (Please see Section G for further information.)
Novel Foods - Biotechnology
Novel foods include:
- a substance, including a microorganism, that does not have a history of safe use as a food;
- a food that has been manufactured, prepared, preserved, or packaged by a process that
- has not been previously applied to that food, and
- caused the food to undergo a major change; and
- a food that is derived from a plant, animal or microorganism that has been genetically modified such that
- the plant, animal or microorganism exhibits characteristics that were not previously observed in that plant, animal or microorganism,
- the plant, animal or microorganism no longer exhibits characteristics that were previously observed in that plant, animal or microorganism,
- one or more characteristics of the plant, animal or microorganism no longer fall within the anticipated range for that plant, animal or microorganism.
The Novel Food Regulations under the Food and Drugs Act and Regulations (Division 28) establish a clear and stringent process for evaluating the safety of novel foods. Manufacturers and importers of novel foods are required to notify Health Canada of their intention to market a new product in Canada, before sale or advertisement for sale. This pre-market notification permits Health Canada to conduct a thorough safety assessment of the proposed product.
Safety assessment of a novel food includes the following considerations: evaluation of the process used to develop the food product; comparison of its characteristics to those of traditional food counterparts; its nutritional quality; the potential for new toxicants or anti-nutrients; and the potential allergenicity of any proteins that have been introduced into the food by genetic modification techniques. In this way, Health Canada provides assurance that the novel food is safe.
The responsibility for the labelling of novel foods is shared between Health Canada and the Canadian Food Inspection Agency.
Importers are also required to notify the Canadian Food Inspection Agency of their intention to import fruits, vegetables, tubers and grains derived from plants with novel traits, including transgenic plants. Assessments of the proposed products will be conducted to evaluate the risk to the agricultural and forestry environment.
The Organic Products Regulations require mandatory certification to the revised National Organic Standard for agricultural products represented as organic in international and inter-provincial trade, or that bear the federal organic agricultural product legend (or federal logo).
Sports Nutrition Products
Canada has very specific compositional and labelling requirements for foods, and strictly controls the addition of vitamins, minerals and amino acids to foods. (See Section D: Addition of Vitamin and Mineral Nutrients to Food). Many sports nutrition products produced outside the country do not comply with the compositional and labelling requirements contained in the Food and Drug Regulations. They may contain non-permitted ingredients, and/or make unacceptable label claims. Some products, because of their composition or because they bear drug claims, are considered drugs and require a Drug Identification Number (DIN) from the Therapeutic Products Directorate, Health Canada, before they can be sold in Canada.
Importers of certain exotic and rare foods should be aware that Environment Canada administers the Convention on International Trade in Endangered Species of Wild Fauna and Flora, commonly known as CITES. This Convention controls the international movement of designated wildlife through an international permit system. (See Section B: Environment Canada, and Section F: Convention on International Trade in Endangered Species of Wild Fauna and Flora). In Canada, all CITES import permits are issued by the CITES Management Authority of the Canadian Wildlife Service.
All CITES-regulated wild animals and plants, whether alive or dead, are controlled, including their parts or derivatives, and specimens bred in captivity or artificially-propagated.
All endangered wild animals and plants listed in Appendix I of the Convention must receive prior import authorization from the CITES Management Authority in Canada, as well as prior export authorization from the CITES Management Authority for the country of export. Commercial trade in these species is not normally permitted.
Generally, all other CITES-controlled animals and plants listed in Appendices II and III of the Convention can be commercially traded as long as prior export authorization has been obtained from the CITES Management Authority of the country of export. If the import is accompanied by a valid foreign CITES export permit, no Canadian CITES import permit is required.
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