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Understanding the meat product exceptions under section 25 of the Safe Food for Canadians Regulations

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.

Section 25 of the Safe Food for Canadians Regulations (SFCR) applies to meat products; imported meat products and meat products prepared within Canada. The meat products are grouped into 2 categories:

  1. Mixtures
    • a mixture is a food that contains ready-to-eat (RTE) meat products with other non-meat ingredients (for example, meat stew, tourtière, pepperoni pizza)
  2. Broth/animal fat/ meat flavour or extract
    • broth, lard, leaf lard, tallow or other rendered fat, suet, shortening, flavour or extract

Mixtures and broths/animal fats/ meat flavours or extracts that meet the requirements of section 25 are exempt from SFCR requirements specific to the import of meat products and the work shift requirements, including the storing and handling of meat products in its imported condition for inspection. A comparison of how some of the SFCR requirements apply to meat products that fall under section 25 to all other meat products; whether imported and prepared in Canada are found in Table 1 and Table 2 below.

If you prepare meat products that fall into the two categories in section 25, you need a Safe Food for Canadians (SFC) licence and a written preventive control plan (PCP). Licence holders who are making an RTE meat product prior to mixing it with other non-meat ingredients do not qualify for the exception under section 25.

Certain mixtures and rendered fats have specific standards outlined in the incorporated by reference document Canadian Standards of Identity Volume 7 – Meat Products. The document contains two tables that outline the standards for specific edible meat products.

Importing mixtures or broth/animal fat/meat flavor or extract into Canada

When you import a food that is a mixture of RTE meat and other food, or a broth/animal fat/meat flavour or extract into Canada, it must meet 4 conditions.

  1. It must be manufactured, processed, treated, preserved, handled, tested, graded, coded, stored, packaged or labelled, in a country with an inspection system for meat recognized under Part 7 of the SFCR. See the list of Countries from which commercial importation of meat products is permitted for a list of countries approved to export
  2. It must be imported from a country with an inspection system for meat recognized under Part 7 of the SFCR. See the list of Countries from which commercial importation of meat products is permitted for a list of countries approved to export
  3. The RTE meat used in the mixture or the meat used to make the broth/animal fat/meat flavour or extract must come from establishment that has a system for manufacturing, processing, treating, preserving, handling, testing, grading, coding, slaughtering, storing, packaging or labelling that recognized under Part 7. See the Foreign countries establishments eligible to export meat products to Canada
  4. An official document (such as, an Official Meat Inspection Certificate (OMIC) or an official document in a format approved by the CFIA) issued by the foreign competent authority must be provided to the CFIA before or at the time of import and kept by the importer. This document must be provided for both mixtures and broths/animal fats/meat flavours or extracts in accordance with section 25 of the SFCR and other Canadian regulatory requirements.

Requirements for preparing mixtures in Canada

When you prepare a mixture in Canada, 3 conditions may apply.

  1. If the RTE meat product used in the mixture was manufactured, processed, treated, preserved, packaged or labelled in Canada, the activity was conducted by a SFC licence holder.
  2. If the meat used to make the RTE meat came from a livestock or poultry carcass that was graded in Canada; it was graded by a grader in accordance with the SFCR.
  3. If the RTE meat product used in the mixture was imported, it was imported by a SFC licence holder.

Requirements for preparing broth/animal fat/meat flavour or extract in Canada

When you prepare a broth/ animal fat/ meat flavour or extract in Canada, 3 conditions may apply.

  1. If the meat product used to make the broth/animal fat/meat flavour or extract was manufactured, processed, treated, preserved, packaged or labelled in Canada, the activity was conducted by a SFC licence holder.
  2. If the meat product used to make the broth/animal fat/meat flavour or extract came from a livestock or poultry carcass that was graded in Canada, it was graded by a grader in accordance with the SFCR.
  3. If the meat product used to make the broth/animal fat/meat flavour is imported, it was imported by a SFC licence holder.

Exporting section 25 meat products

If you are exporting a meat product that falls under section 25, you remain responsible for the following:

Cold storage facilities that export meat products and/or store meat products intended for export to other countries may also need to meet certain requirements of the importing country. To understand the export requirements by country, consult the Export requirements library.

Keep in mind

Meat product shipments cannot be exported unless it has received a final inspection, found satisfactory and issued an export certificate or other document by the CFIA as requested by the importing country.

Application of inspection legend to meat products that fall under section 25

Whether prepackaged or not, meat products that fall under section 25 must have the inspection legend on the label when traded interprovincially or exported. If the meat product was imported, it must have the official inspection mark of the foreign state of origin. Consumer prepackaged (definition) meat products may show their inspection legend or inspection mark on any part of the label, except the bottom. For more information on the application of the inspection legends on meat products please see the Labelling requirements for meat and poultry products.

Application of SFCR requirements on section 25 meat products

Meat products that fall under section 25 are exempt from the certain SFCR requirements. The tables below are a comparison of SFCR requirements applicable to section 25 meat products and all other meat products. Please note that these tables are not an exhaustive list of the SFCR requirements; all other meat requirements found in the Safe Food for Canadians Act and Regulations remain applicable.

Table 1: A comparison of SFCR import requirements applicable to section 25 meat products and all other meat products
Section Requirement Applies to mixtures Applies to broth/animal fat/meat flavour or extracts Applies to all other meat products
Section 5: Licensing Licence to import Yes Yes Yes
Section 7(2)(a)(ii): Additional Licensing Licence to store and handle in its imported condition for inspection No No Yes
Section 13: Submitting import information Can submit import information after the time of import; when permission is granted Yes Yes No
Section 14: Further inspection at the time of import If identified for inspection, must be delivered to an establishment where the licence holder has a licence to store and handle the meat product in its imported condition for CFIA inspection No No Yes
Section 22: Return of a meat product that was previously exported Must be returned to the person who exported it from Canada; if that person has a licence to export or returned to the last person who had possession of the product before it's export Yes Yes No
Section 22: Return of a meat product that was previously exported Return must be authorized by an inspector No No Yes
Section 22: Return of a meat product that was previously exported Must be returned to an establishment where the licence holder has a licence to store and handle the meat product in its imported condition and kept in the establishment until an inspector completes an inspection No No Yes
Table 2: A comparison of SFCR requirements applicable to section 25 meat products and all other meat products whether imported or prepared in Canada
Section Requirement Applies to mixtures Applies to broth/animal fat/meat flavour or extracts Applies to all other meat products
Section 28(2) & 29(1)(d): Providing work shift for activities related to meat products A proposed work shift to be provided with licence application and the work shift must be approved by the CFIA No No Yes
Section 31(2): Specified work shift hours The activities related to the meat product are conducted during the approved work shift hours No No Yes
Section 42: Minimum hours of inspection The CFIA determines on the minimum number of hours of inspection required per year during approved work shift No No Yes
Section 46(1)(b): Preventive controls Preventive controls must be applied when storing and handling the meat product in its imported condition for inspection No No Yes
Section 69: Facilities for inspectors to perform their inspection duties Furnished office, lockers, cabinets, lockable storage facility for samples must be available for CFIA inspector and a private office is provided in slaughter establishments for the CFIA inspector No No Yes
Section 167: Import Must meet the import requirements for meat products in section 167 No No Table Note 1 Yes
Section 168: Export Must meet the export requirements for meat products in section 168 No No Yes
Section 296: Label of edible meat products If the meat product label does not meet the SFCR requirements and it is sent or conveyed from an establishment; it must be sealed with a tamper-resistant seal No No Yes

Table Note

Table Note 1

An official document may still be required at the time of import in accordance with the Health of Animals Regulations

Return to table note 1  referrer

Keep in mind

While section 25 meat products are exempt from certain SFCR requirements outlined in the tables above, when exporting, you must meet all requirements of the importing country to avoid affecting your eligibility and status on export eligibility lists. For more information export eligibility lists, consult the Export registers and lists.

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