ARCHIVED - Summary of the Joint Canada Border Services Agency - Canadian Food Inspection Agency Customs Self Assessment Pilot Study for Processed Foods
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The Canada Border Services Agency (CBSA) Trusted Trader Customs Self Assessment (CSA) Program facilitates the movement of goods from the United States and Mexico across the Canadian border for trusted businesses, streamlining many of the border requirements so that low-risk shipments can be processed more quickly and efficiently when they enter Canada. This saves businesses time and money, and allows the CBSA to better focus its resources on identifying higher risk shipments that pose a potential threat to the health, safety or economic well-being of Canadians. Under the CSA Program, products with other government department requirements, such as food, are not eligible for clearance.
As part of the 2011 Canada-United States Beyond the Border Action Plan, the CBSA and the Canadian Food Inspection Agency (CFIA) carried out an 18-month pilot project with a major food importing company to test the feasibility of allowing the importation of selected low-risk processed, prepackaged foods from the United States into Canada under the CSA Program, while continuing to meet or exceed CFIA food safety objectives.
The project assessed the effectiveness of established and modified processes, standards and channels of communication aimed at ensuring compliance with CFIA and CBSA rules and regulations. The agencies and importing company also conducted food safety exercises that simulated how the parties would respond to a food safety incident involving foods imported through the program.
Overall, the pilot was useful in identifying key considerations and issues, such as administrative, process and resource requirements, which would need to be addressed if the CSA Program were to be adopted for processed foods on a broader scale. Specifically, it determined that import transaction data can be received after foods are imported into Canada, provided the importer has the necessary processes in place to respond to, manage and mitigate risks in the event of a food safety incident. Under the current commercial import process, importers are required to submit transaction data prior to entry. Over the course of the pilot gaps were identified in the exchange of information between CBSA, CFIA and the importer as they related to party notification and food traceability. The processes put in place by the CBSA and CFIA to address these gaps were effective, but resource intensive. Despite these challenges, the importer was able to benefit from expedited border clearance.
The two Agencies have agreed to further evaluate whether other food importers would be able to participate successfully in the CSA Program while ensuring compliance with Government of Canada requirements.
Initiated in 2001, the CBSA CSA Program is an established mechanism for approved commercial clients to clear low-risk shipments (historically non-food products) originating from the United States and/or Mexico in an expedited fashion. The Program is designed for low-risk, pre-approved importers, carriers and registered drivers. To participate, the importers, carriers and drivers must undergo a risk assessment, and importers must demonstrate that they have systems and processes in place to meet reporting requirements, including providing detailed product descriptions upon request. Benefits for importers include a simplified accounting and payment process for all imported goods and expedited reporting at the border. The standard commercial import process of food products requires importers to submit pre-entry transaction data to obtain CFIA approvals. Unlike the standard commercial import process, the CSA Program does not require importers to submit pre-entry transaction data. Due to the differences in the submission of transaction data, food products have historically not been allowed on the CSA Program.
Seeking to maximize the Program's effectiveness and facilitate trade across the Canada-United States border, the two Agencies committed to a one-year pilot project to test the Program in the processed foods sector as part of the Canada-United States Beyond the Border Action Plan.
The pilot was limited to a large, fully integrated importer and a limited selection of food products (e.g. cake mix, spices, confectionary) originating from the United States.
The Pilot Study
The CBSA, CFIA and an importer collaborated on the pilot that occurred over approximately 18 months between 2011 and 2013. These participants explored whether an importer could properly clear selected low-risk food products from the United States through the CSA process. It was a fundamental principle of the pilot that the food safety of products imported under the pilot would not be compromised.
The objectives of the pilot were to:
- test the feasibility of allowing the importation of processed, prepackaged foods from the United States into Canada under the CSA Program while continuing to meet or exceed CFIA food safety objectives; and
- develop and examine CSA Program modifications where deemed necessary for product tracking and traceability purposes, such as in transactional data reporting and communications.
The pilot was a collaborative project involving the CBSA, the CFIA and a large, fully integrated food company. For the purposes of the pilot, the CSA Program was adapted to include clearance of selected regulated low-risk food products. The participants undertook to enter into an agreement defining the conditions of the pilot and requiring that the importer submit import transaction data after entering the country.
During the pilot the participants explored whether the importer could properly clear a limited selection of low-risk foods from the United States through Canadian customs using the CSA process. Participants also undertook a tabletop exercise to examine the communication and response implications of the CSA Program for the CFIA and its partners in a mock food safety incident scenario. The scenario was an important component of testing the importer's ability to trace and control food products in the event of a food safety incident.
The following criteria were assessed during the CSA pilot:
- the timeliness with which the importer could submit transaction and product data to the CFIA after the shipments were imported into Canada;
- the effectiveness with which the participants could mitigate communication gaps and respond to food safety incidents involving the products being imported; and
- the ability of the importer to comply with the CSA Program modifications imposed during the food CSA pilot.
Results and Key Findings
The pilot provided opportunities to identify and address issues with the existing CSA process, as it would apply to shipments of low-risk, processed, pre-packaged food items. The additional processes put in place by the CBSA and the CFIA during the pilot to address gaps related to information exchange, notification, and traceability were effective but resource-intensive, largely because they depended on a manual, person-to-person communication process. Additionally, the pilot determined that the importer had advanced systems in place in order to manage import processes under CSA and to respond to, mitigate and manage risks in the event of a food safety incident.
Discussion and Policy Implications
Within the environment of the pilot, the results demonstrated that one large importer of selected low-risk processed, prepackaged foods could participate in the CBSA's CSA Program. Further assessment is recommended to determine the transferability of the findings of the pilot to other importer business models.
The pilot identified several issues relating to the requirements, administration and management of the Program that require further evaluation. These include developing:
- food safety criteria for CSA importers to ensure that imported food meets Canadian food safety requirements;
- a process and associated resource requirements to review CSA applications to import food products;
- a process and associated resource requirements to manage CSA participants in order to ensure that the foods imported under this program continue to meet Canadian food safety requirements; and
Other considerations that were not within the scope of the pilot but are important as the next steps are determined, include, but are not limited to:
- how to strike the appropriate balance between food safety and a free flow of cross border commerce given significant recent commitments by the Government of Canada in both areas;
- analyzing comparability and interoperability with major trade partners such as the United States and Mexico;
- consideration for other CFIA regulated food products currently not eligible to be cleared within the CSA Program;
- recognizing potential economic impacts on the food importing industry of unequal access to expedited border processes;
- assessing other importer business models that differ from the pilot; and
- assessing potential impacts of implementing import admissibility requirements into food regulations.
- examining the implications of anticipated regulations that would require importer licensing.
Given the additional administrative, process and resource requirements identified in the findings of the pilot and the upcoming changes to Canada's food safety regulatory framework, particularly the Safe Food for Canadians Act, the CFIA and CBSA are conducting an analysis to determine how access to the CSA program benefits could be provided to other food importers, while ensuring compliance with Government of Canada requirements. This analysis will assure Canadians that food safety would not be compromised while providing food importers access to expedited border clearance.
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