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Regulatory requirements: Traceability

Although the Safe Food for Canadians Regulations (SFCR) came into force on January 15, 2019, certain requirements may apply in 2020 and 2021 based on food commodity, type of activity and business size. For more information, refer to the SFCR timelines.

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1.0 Introduction

The traceability requirements in the Safe Food for Canadians Regulations are based on the international standard established by Codex Alimentarius - tracking of food forward to the immediate customer and back to the immediate supplier. Developing an effective traceability system will allow you to:

The following provides an overview of the regulatory requirements on traceability, as found in Part 5 of the Safe Food for Canadians Regulations.

2.0 Application of the traceability requirements

The traceability requirements apply to a broader scope of food businesses than the licensing and preventive control plan requirements. For example, some of the traceability requirements apply to persons who sell food to consumers at retail as well as persons who send or convey food from one province or territory to another.

Although the Safe Food for Canadians Regulations came into force January 15, 2019, the traceability requirements follow a phased-in implementation approach.

Please refer to the traceability interactive tool to help you determine if, how, and on which date the traceability requirements will apply to your food business.

3.0 Documentation requirements

Safe Food for Canadians Regulations: Sections 90 and 91

Rationale

Traceability documents will allow you to identify from where you sourced the food and/ or food commodity (one step back), and to whom you provided the food (one step forward). Preparing, keeping, and retaining traceability documents will allow you to accurately identify the scope of a recall, and thereby ensure that consumers are protected against risk of injury to their health.

What this means for your food business

To help you understand these requirements, specific criteria and examples are outlined below. The examples are not exhaustive but help illustrate the intent of the requirement and offer examples of what you can do to comply. Key terms throughout the text have been hyperlinked to the SFCR glossary.

Subsection 90(1): Documentation requirements for food businesses other than retail

Subsection 90(2): Documentation requirements for persons who sell food to consumers at retail

Subsection 90(3): Retention and accessibility of traceability documents

Examples:

Subsection 91(1): Production of traceability documents upon request

4.0 Traceability-specific labelling requirements

Safe Food for Canadians Regulations: Section 92

Rationale

Traceability information that is applied or attached to a food or that accompanies a food will allow both you and the person to whom you provide the food to effectively identify whether a particular food is subject to a recall.

What this means for your food business

To help you understand these requirements, specific criteria and examples are outlined below. The examples are not exhaustive but help illustrate the intent of the requirement and offer examples of what you can do to comply. Key terms throughout the text have been hyperlinked to the SFCR glossary.

Other sections of the SFCR may require you to provide information on your labels in specific ways or despite exceptions noted in the traceability section. Refer to the Industry Labelling Tool for additional information on labelling requirements.

Subsections 92(1) and (2): Labelling information that must be provided with the food

Paragraph 92(3)(a): Labelling exceptions for food at time of export

Foreign states may have specific labelling requirements that are different from the SFCR.

Paragraphs 92(3)(b) and (c): Labelling exceptions for lot code or unique identifier; and name and principal place of business for certain food at the time of sale to consumers at retail

Paragraphs 92(3)(b) to (c), and Subsection 92(4): Labelling exceptions for common name for certain food at the time of sale to consumers at retail

Subsection 92(5): Labelling exceptions for name and principal place of business for consumer prepackaged fresh fruits or vegetables at the time of sale to consumers at retail

5.0 Traceability-specific labelling requirements by food commodity

Table 1, 2 & 3 Legend

The "not applicable" is used to indicate when a requirement is either not applicable or not required, and is accompanied by the applicable regulatory reference(s).

The "applicable" is used to indicate when a requirement is applicable, and is accompanied by the applicable regulatory reference.

Table 1: Traceability-specific labelling (applied, attached or accompany) for dairy products, eggs, fish, honey, maple products, meat products, processed egg products and processed fruit or vegetable products [SFCR reference]
Traceability-specific labelling requirements Must have lot code Must choose between: Lot code or unique identifier Name and principal place of business Common name
Primary producers (interprovincial trade)
Consumer prepackaged applicable [92(2)] not applicable [92(2)] applicable [92(1)] applicable [92(1)]
Prepackaged other than consumer prepackaged (for example, shipping container) not applicable [92(1)] applicable [92(1)] applicable [92(1)] applicable [92(1)]
Licence holders who manufacture, process, treat, preserve, grade, store, package or label
Consumer prepackaged applicable [92(2)] not applicable [92(2)] applicable [92(1)] applicable [92(1)]
Prepackaged other than consumer prepackaged (for example, shipping container) not applicable [92(1)] applicable [92(1)] applicable [92(1)] applicable [92(1)]
Interprovincial trade (sole activity)
Consumer prepackaged applicable [92(2)] not applicable [92(2)] applicable [92(1)] applicable [92(1)]
Prepackaged other than consumer prepackaged (for example, shipping container) not applicable [92(1)] applicable [92(1)] applicable [92(1)] applicable [92(1)]
Import (sole activity)
Consumer prepackaged applicable [92(2)] not applicable [92(2)] applicable [92(1)] applicable [92(1)]
Prepackaged other than consumer prepackaged (for example, shipping container) not applicable [92(1)] applicable [92(1)] applicable [92(1)] applicable [92(1)]
Retail (at place of sale to the consumer)
Consumer prepackaged, not packaged at retail applicable [92(2)] not applicable [92(2)] applicable [92(1)] applicable [92(1)]
Consumer prepackaged food, packaged at retail not applicable [92(1)] applicable [92(1)] applicable [92(1)] applicable [92(1)]
Food that is not a consumer prepackaged food, for example food that is presented in bulk display not applicable [92(3)(b)] not applicable [92(3)(b)] not applicable [92(3)(b)] not applicable [92(3)(b)]
Table 2: Traceability-specific labelling requirement for fresh fruits or vegetables (FFV) [SFCR reference]
Traceability-specific labelling requirements Must have lot code Must choose between: Lot code or unique identifier Name and principal place of business Common name
Grow or harvest (interprovincial trade)
Consumer prepackaged applicable [92(2)] not applicable [92(2)] applicable [92(1)] applicable [92(1)]
Prepackaged other than consumer prepackaged (for example, shipping container) not applicable [92(1)] applicable [92(1)] applicable [92(1)] applicable [92(1)]
Licence holders who manufacture, process, treat, preserve, grade, store, package or label
Consumer prepackaged applicable [92(2)] not applicable [92(2)] applicable [92(1)] applicable [92(1)]
Prepackaged other than consumer prepackaged (for example, shipping container) not applicable [92(1)] applicable [92(1)] applicable [92(1)] applicable [92(1)]
Interprovincial trade (sole activity)
Consumer prepackaged FFV applicable [92(2)] not applicable [92(2)] applicable [92(1)] applicable [92(1)]
Prepackaged other than consumer prepackaged (for example, shipping container) not applicable [92(1)] applicable [92(1)] applicable [92(1)] applicable [92(1)]
Import (sole activity)
Consumer prepackaged FFV applicable [92(2)] not applicable [92(2)] applicable [92(1)] applicable [92(1)]
Prepackaged other than consumer prepackaged (for example, shipping container) not applicable [92(1)] applicable [92(1)] applicable [92(1)] applicable [92(1)]
Retail (at place of sale to the consumer)
Consumer prepackaged, not packaged at retail (*exception) applicable [92(2)] not applicable [92(2)] applicable [92(1)] applicable [92(1)]
*Consumer prepackaged FFVs that are packaged in such a manner that they are visible and identifiable in the container (includes whole and fresh cut) (not packaged at retail) (for example, tomatoes packaged in a styrofoam tray that has been over-wrapped with clear plastic wrap do not have to be labelled with the common name "tomatoes") applicable [92(2)] not applicable [92(2)] applicable [92(1)] not applicable [219(1)(a); 92(4)]
*Consumer prepackaged fresh apples that are packaged such that the variety name is shown on any part of the label, except if that name is applied to the bottom of the container (not packaged at retail) (for example, apples in opaque bags, boxes, etc. that would not ordinarily be visible and identifiable in the package) applicable [92(2)] not applicable [92(2)] applicable [92(1)] not applicable [219(1)(b); 92(4)]
Consumer prepackaged, packaged at retail (**exception) not applicable [92(1)] applicable [92(1)] applicable [92(1)] applicable [92(1)]
**Consumer prepackaged FFVs that are packaged in such a manner that they are visible and identifiable in the container (includes whole and fresh cut) (packaged at retail) (for example, tomatoes packaged in a styrofoam tray that has been over-wrapped with clear plastic wrap do not have to be labelled with the common name "tomatoes") not applicable [92(1)] applicable [92(1)] not applicable [220; 92(5)] not applicable [219(1)(a); 92(4)]
**Consumer prepackaged fresh apples that are packaged such that the variety name is shown on any part of the label, except if that name is applied to the bottom of the container (packaged at retail) (for example, apples in opaque bags, boxes, etc. that would not ordinarily be visible and identifiable in the package) not applicable [92(1)] applicable [92(1)] applicable [92(1)] not applicable [219(1)(b); 92(4)]
FFV packaged in a wrapper, or confining band, less than 13 mm in width not applicable [213(b); 92(3)(c)] not applicable [213(b); 92(3)(c)] not applicable [213(b); 92(3)(c)] not applicable [213(b); 92(3)(c)]
FFV packaged in a protective wrapper, or a protective bag, that is transparent and on which no information is shown other than a price, bar code, number code, environmental statement or product treatment symbol (for example, FFV that are typically found in such protective wrappers or bags include an English cucumber, a head of lettuce or cauliflower, a bunch of grapes, etc.) not applicable [213(c); 92(3)(c)] not applicable [213(c); 92(3)(c)] not applicable [213(c); 92(3)(c)] not applicable [213(c); 92(3)(c)]
FFV that are not a consumer prepackaged, for example food that is presented in bulk display not applicable [92(3)(b)] not applicable [92(3)(b)] not applicable [92(3)(b)] not applicable [92(3)(b)]
Table 3: Traceability-specific labelling requirement for all other food, including food found in Schedule 1, food additives and alcoholic beverages [SFCR reference]
Traceability-specific labelling requirements Must have lot code Must choose between: Lot code or unique identifier Name and principal place of business Common name
Primary producers who farm or produce (interprovincial trade)
Consumer prepackaged applicable [92(2)] not applicable [92(2)] applicable [92(1)] applicable [92(1)]
Prepackaged other than consumer prepackaged (for example, shipping container) not applicable [92(1)] applicable [92(1)] applicable [92(1)] applicable [92(1)]
Licence holders who manufacture, process, treat, preserve, grade, store, package or label
Consumer prepackaged applicable [92(2)] not applicable [92(2)] applicable [92(1)] applicable [92(1)]
Prepackaged other than consumer prepackaged (for example, shipping container) not applicable [92(1)] applicable [92(1)] applicable [92(1)] applicable [92(1)]
Interprovincial trade (sole activity)
Consumer prepackaged applicable [92(2)] not applicable [92(2)] applicable [92(1)] applicable [92(1)]
Prepackaged other than consumer prepackaged (for example, shipping container) not applicable [92(1)] applicable [92(1)] applicable [92(1)] applicable [92(1)]
Import (sole activity)
Consumer prepackaged applicable [92(2)] not applicable [92(2)] applicable [92(1)] applicable [92(1)]
Prepackaged other than consumer prepackaged (for example, shipping container) not applicable [92(1)] applicable [92(1)] applicable [92(1)] applicable [92(1)]
Retail (at place of sale to the consumer)
Consumer prepackaged, not packaged at retail applicable [92(2)] not applicable [92(2)] applicable [92(1)] applicable [92(1)]
Consumer prepackaged, packaged at retail not applicable [92(1)] applicable [92(1)] applicable [92(1)] applicable [92(1)]
Prepackaged confections that are sold individually, commonly known as one-bite confectionaries not applicable [213(a); 92(3)(c)] not applicable [213(a); 92(3)(c)] not applicable [213(a); 92(3)(c)] not applicable [213(a); 92(3)(c)]
Food that is not a consumer prepackaged food, for example food that is presented in bulk display not applicable [92(3)(b)] not applicable [92(3)(b)] not applicable [92(3)(b)] not applicable [92(3)(b)]
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