The Safe Food for Canadians Regulations (SFCR) was published in June 2018 in Canada Gazette, Part II 1. Now that 2019 is just around the corner, it’s time to make sure your company is ready for this important regulatory change and about how this may impact your business. Some requirements would 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 2. The commodities affected as of January 15, 2019 include: Dairy products, Eggs, Fish, Honey, Maple products, Meat products, Processed egg products, and Processed fruit or vegetable products, as well as Fresh Fruits or Vegetables. All other foods have timelines from 2020 – 2021 depending on the size of the business, and the SFCR requirement (e.g. licence, 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 3.
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, labelling 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 a 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 Heart Report” for the Phase III consultations on key proposals to modernize the food labelling system4. 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 the 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.
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dicentra provides sought-after guidance on product and marketing compliance, quality assurance and safety standards, research and development, new ingredient assessments and overall regulatory strategies for food and health-related products sold in North American marketplaces. We can also assist you with your classification determinations for delivery systems or combination drug-device products.