Overview: importing fish and shellfish
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.
On this page
- General information
- Specific requirements for imported fish
- Specific requirements for shellfish
- What's new for fish importers under the SFCR
- Standards of identity and grades for fish
- Labelling requirements
- Organic fish
This document outlines requirements specific to importing fish. In order to ensure that you will also meet the general import requirements for importing food and the preparation of your preventive control plan, please refer to the Importing Food: A Step by Step Guide and A guide for preparing a preventive control plan – For importers.
The specific import requirements for importing fish can be found in the Automated Import Reference System (AIRS). AIRS information is updated frequently so prior to importing you should verify AIRS to ensure that the import requirements have not changed.
Importers are responsible for ensuring that they import fish that meet all applicable food safety and consumer protection requirements outlined in the Safe Food for Canadians Regulations (SFCR) as well as any applicable requirements of the Health of Animals Regulations.
The CFIA verifies compliance to Canadian regulatory requirements and works with the competent authorities of Canada's major trading partners to provide reasonable assurances that imported products are safe and meet regulatory requirements.
Certain aquatic animal species from certain countries may be classified as "susceptible" to diseases of concern in Canada and may require an Aquatic Animal Health Import Permit. For more information on susceptible fish and aquatic animal health import requirement refer to Susceptible species of aquatic animals and Aquatic animal imports web pages.
Specific requirements for imported fish
- Imported frozen fish must be transported in a way that protects the import from dehydration and oxidation.
- Importers are responsible for ensuring product compliance by implementing measures to address thereapeutant use in aquacultured finfish imported for human consumption. Fish intended for human consumption must meet the Maximum Residue Limits (MRL) for therapeutants outlined in the CFIA aquaculture therapeutant residue monitoring list.
Specific requirements for shellfish
- Importers that are importing live and raw molluscan shellfish must import from an authorized country of harvest that has been approved to export to Canada. A list of the authorized countries and approved species of molluscan shellfish can be found on Importing Live and Raw Molluscan Shellfish.
- Foreign vessels importing, processing or otherwise handling live molluscan shellfish must comply with the provisions of the United States' National Shellfish Shippers Program and must appear on the approved list of establishments contained in the Interstate Certified Shellfish Shippers List (ICSSL).
- Vibrio parahaemolyticus (Vp) is a bacterium that can cause gastrointestinal illness in humans. It naturally inhabits coastal waters throughout the world and can be found in higher concentrations during warmer months. Importers must effectively control Vp in bivalve shellfish destined for raw consumption and must verify that their suppliers have Vp controls. For more information refer to:
Refer to the CFIA web page Food-specific requirements and guidance – Fish to view various guidance documents including:
Regulatory requirements: Fish explains the SFCR requirements related to fish and shellfish, including specific requirements for importing
Preventive controls for food – Fish provides information on select preventive control practices to mitigate food safety risks associated with the processing of fish and shellfish.
What's new for fish importers under the SFCR
The CFIA, under SFCR, is adopting a risk-based approach to inspection, which will result in changes to current processes. Importers will be required to adopt and follow these changes.
The information presented below is intended to highlight the main changes to CFIA's fish import processes under the SFCR compared to established processes under the Fish Inspection Regulations (FIR).
|Fish Inspection Regulations
(to be repealed January 15, 2019)
|Safe Food for Canadians Regulations
(effective January 15, 2019)
|Import notification and release of shipments||Importers use Fish Import Notification (FIN) form||Importers use Single Window – Electronic Data Interchange (EDI)|
|Import notification and release of shipments||Importers notify within 48 hours after importation||Importers notify before or at time of import|
|Import notification and release of shipments||
Once fish shipment is released by CBSA:
|Once fish shipment is released by CBSA, all fish shipments can be distributed immediately|
|Importer licences and associated import fees||Two types of licences; basic and QMPI. Product import fees determined by type of licence||One type of licence; a preventive control plan (PCP) is mandatory. Product import fees remain as they were prior to coming into force of the SFCR|
Mandatory CFIA product inspection triggers in place:
MIL and EIL will cease to exist.
Product inspection and sampling by CFIA continue through the ongoing compliance verification by inspectors of importer PCPs
|CFIA Inspection||Compliance verifications of QMPI importers and their documented plans||Compliance verification of licensed importers and their PCPs|
|CFIA Inspection||Fish products subject to CFIA inspector sampling/inspection are normally held||Fish products subject to CFIA inspector sampling/inspection are not generally held (unless inspector suspects an issue)|
|Requests for re-inspections||Re-inspections offered when a lot fails an inspection test that does not present a health and safety concern||Re-inspections are no longer offered. The importer is required to take corrective actions|
Fish Import Notifications (FIN) and the release of shipments
Under the FIR, importers were required to provide information on their imported shipments via a FIN that is submitted to a regional CFIA office up to 48 hours post import.
- fish importers are not required to send the FIN to CFIA
- all import information must be submitted by importers as part of the paper or electronic declaration prior to or at time of import (rather than within 48 hours of import)
- fish importers no longer need to wait for a CFIA notification or approval before distributing a shipment that was released to commerce by the CBSA
Importer licences and associated import fees
Under the Fish Inspection Regulations (FIR) there were two levels of fish import licences: basic and QMPI. The requirements and nature of CFIA compliance verification activities varied for each level.
|Importers were responsible for the compliance of the fish they import. They developed a Quality Management Program (similar to a PCP). In addition, they were required to follow the same product inspection frequencies as the CFIA (prescribed by the FIR) and had to submit an inspection report of all results to the CFIA every 6 months||Importer requirements were simplified and there was no PCP-like documents required|
Import licences under SFCR:
- the two levels of fish import licences will cease to exist. All fish importers will continue to require a licence. The requirements for such a licence will be consistent, as defined in the SFCR. Current basic importers will be required to meet additional requirements, including the requirement for a PCP
- during the first year of SFCR coming into force, fish importers (both basic and QMPI) can continue to use their existing import licence, as issued prior to SFCR coming into force until it expires. Once the existing licence expires, importers will need to have a licence issued under the SFCR in order to continue their import activity
Import fees under SFCR:
- the charges for the two different classes of fish import licences will no longer be applied; these will be replaced by the 2-year licence issued under SFCR which has a proposed cost of $250. This will be a savings to importers
- prior to SFCR, product that was being imported and being directed for further processing in a federally regulated established was charged a flat import fee of $30 per shipment. This will continue under SFCR meaning there will be no change for importers
- prior to SFCR, product that was being imported and not being directed for further processing was charged import fees that were calculated based on the product type, weight and classification of the licence (Basic or QMPI). In an effort to keep costs stable for importers, the CFIA is proposing to continue this approach. For example:
- if you held a QMPI licence prior to the coming into force of the SFCR the fees have been grandfathered and it is proposed that you will continue to pay the QMPI rate of $0.002/kg
- if you held a basic licence prior to the coming into force of the SFCR, or you are a new licence holder, it is proposed that you will pay the basic rate which ranges between $0.01 - $0.15 per kg depending on type of product being imported
The CFIA's inspection scheme established under the FIR focused on obtaining reasonable assurance that imported fish products consistently met Canadian standards and requirements. The CFIA inspections were tied to product type and producer, with the following inspection triggers:
- the inspection of fish imported for the first time
- random inspections
- mandatory inspection of fish with a history of non-compliance; as listed on the Mandatory Inspection List (MIL) and the Enhanced Inspection list (EIL)
The MIL and EIL allowed the CFIA to identify non-compliant fish to ensure that subsequent imports of these products were subject to analysis/product inspection before being sold or distributed in Canada.
For basic importers, CFIA oversight was largely based on the inspection triggers listed above as well as lot-by-lot tracking/assessment of the need for product analysis/inspection (based on risk factors). For QMPI, CFIA current oversight was largely based on compliance verification of their documented QMPI plan (similar to a PCP under the SFCR).
- the CFIA is replacing the MIL and EIL with a risk based approach to product inspection and sampling; fish importers will be responsible for showing compliance through their PCPs
- fish imports are generally not held; there is no mandatory 'hold and test'
- importers will need to maintain PCP records and verify the effectiveness of their PCP. CFIA inspectors will conduct inspections of licensed fish importers. This inspection approach will focus on verifying and monitoring the effectiveness of the preventive controls applied by importers and addressing non-compliance issues
Under the FIR, importers could request CFIA to conduct a re-inspection of non-compliance issues that did not present a health and safety concern. It enabled importers to:
- cull or rework the fish
- remove suspect codes from the lot of fish
- request that a duplicate set of samples be withdrawn for private analysis
- have a lot re-inspected on a code by code or a lot basis
- re-inspections are no longer offered. Actions such as culling, reworking or removing suspect lots will be considered a type of corrective action under a PCP
- importers will continue to be able to cull, rework or remove suspect lots under their PCP, however they will have to take additional actions to prevent reoccurrence of the non-compliance
Standards of identity and grades for fish
There are grades and standards referred to in the regulations for fish. These standards of identity and grades have been combined into a collection of Documents incorporated by reference – Safe Food for Canadians Regulations. Imported fish that declare a common name as stated in the Canadian Standards of Identity document must meet the corresponding standard and any grade declarations must be in accordance with the grades set in the Canadian Grade Compendium. Refer to:
- Canadian Standards of Identity Volume 3, Fish
- Canadian Grade Compendium Volume 8, Fish
- Grade Names for Imported Food (Refer to items 36-52 in this table for information relevant to fish products)
- Common Names for Prepackaged Fish
The label of imported prepackaged fish must bear the name of the foreign state of origin in addition to the core labelling requirements outlined in the Industry labelling tool. The Industry labelling tool is a food labelling reference for all industry that outlines the requirement for food labelling and advertising
Labelling Requirements for Fish and Fish Products outline the labelling requirements specific for fish and fish products.
Imported organic fish may be certified to the Canadian Organic Standard by a CFIA accredited Certification Body or be certified in accordance with an equivalency arrangement established between Canada and the exporting country. Where an equivalency arrangement is in place, organic products may be certified by a certification body accredited by that country and recognized by Canada. Imported certified organic products with 95 per cent or more organic ingredients may display the Canada organic logo on the labels. All relevant Canadian legislation would also continue to apply for the imported product.
Any person who imports a product or markets it in Canada as an organic product must be able to demonstrate, at all times, that the product meets one of the requirements set out above and must retain the documents attesting that the product is organic.
For further information about organic products refer to Organic products.
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