The Safe Food for Canadians Regulations (SFCR) handbook was recently published to help businesses understand the requirements and the implications they may have. Now that 2019 is just around the corner, it’s time to make sure your company is ready for this important regulatory change. Some requirements will be set immediately starting from January 15, 2019, while other requirements are to be phased in over a period of 12 – 30 months. The phased approach will depend on the food commodity, the type of activity and the business size.
The commodities affected as of January 15, 2019, include:
All other foods have timelines from 2020 – 2021 depending on the size of the business, and the SFCR requirement (e.g. license, or traceability). In addition to the SFCR, the CFIA Food Labelling Modernization (FLM) initiative was not modernized during the development of the SFCR but rather will be occurring at a separate timeline, under the FLM proposal by the CFIA.
These SFC Regulations (SFCR) generally apply to food for human consumption (including ingredients) that is imported, exported or inter-provincially traded; and also applies to food animals from which meat products are exported or inter-provincially trade; and some of the traceability, labeling, and advertising provisions apply to intra-provincially traded foods.
The key elements of the SFCR are:
Licencing is one of the most notable changes – which will apply to specific activities such as manufacturing, processing, treating, preserving, grading, packaging, or labelling food that will be exported or moved between Canadian provinces, or importing a food. Licencing would not apply to foods sold and consumed within a province, as well as for growing and harvesting fresh fruits or vegetable, handling fish on a vessel, and food sold onsite at the retail grocery store (e.g. packaging and labelling of food at the retail grocery store for sale to consumers).
Earlier this year the CFIA published the What we Heard Report for the Phase III consultations on key proposals to modernize the food labelling system. With regards to the FLM, various changes have been proposed to labelling including updates to: date marking, food company information, labelling for imported products, legibility and placement of information, key ingredients being emphasized, food standards & class names, standard container sizes and streamlining commodity specific regulations. The development of the FLM regulatory package for pre-publication in Canada Gazette Part I is planned for Spring of 2019. In addition to the FLM changes proposed in the near future by the CFIA, Health Canada is also working closely with the CFIA on a few other labelling aspects, including marketing to children and Front of Pack Labelling (FOP) which is aiming to be published in Canada Gazette Part II in fall 2018.
The take-home message is: make sure to know of how are you affected by the Safe Food for Canadians Act and Regulations and to make sure you meet the timeline for your specific food commodity and/or activity. For more assistance in assessing the regulatory compliance of your food business, please be sure to contact dicentra for assistance and for more information by filling out the form below or contacting us directly.
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