The Safe Food for Canadians Regulations will undoubtedly have a significant impact on how manufacturers, packagers, labelers, importers, and retailers of food products conduct their operations, particularly with respect to those food sectors (such as chips, cookies, bars) that were not previously governed by any commodity–specific regulations (such as meat, fish, dairy). Most companies affected by the new regulations have at least heard of the Safe Food for Canadians Regulations, and many are already taking steps towards compliance. However, there are some companies who remain unware of the new regulations or, if they have heard of them, assume that they do not apply to their operations. One such group is internet retailers.
In reality, the proposed regulations will apply to companies trading food online, as it would to any other food business. So what does an internet retailer need to know? There are three key elements of the proposed Safe Food for Canadians Regulations:
However, not all of these requirements will necessarily apply to a retailer. If you are crossing provincial boundaries by simply sending food from one province to another, as most online retailers likely are, then elements one and two above (site licensing and PCPs) will not apply to you, but element three (traceability) will. Traceability simply means that you have a system in place for tracking the food items you procure and sell. Such a system is necessary in the event of a safety or quality related incident, such as a recall, and is intended to allow you to identify, contact, and communicate with the affected consumers downstream and the applicable suppliers upstream in an effective manner.
On the other hand, if, as an online retailer, you are also engaged in importing the food products you sell, then you would require a site licence. This is actually the easiest of the requirements as it will simply involve completing and submitting an online application. You would also need to have a written PCP plan in place (unless your gross annual food sales are less than $30,000 and you are not importing meat, fish, dairy, eggs, or fruit and vegetable products; in which case you would receive a special exemption). The PCP is a written document that demonstrates how you are effectively identifying and controlling all hazards and risks to the food you handle. Undoubtedly, the PCP will be the most challenging of all of the requirements to develop and implement.
As an online retailer, you should start to consider how the proposed regulations will impact you. If you have not already done so, there is no cause for panic at this stage. The Canadian Food Inspection Agency anticipates that the final Safe Food for Canadians regulatory text will be published in the spring of 2018, after which, for most food commodities, there will be a phased-in compliance period.
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