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PCP for importers

Obligations for importers to be taken seriously

Until January 15, 2019 , import operations required few steps other than applying for a permit and following labeling rules in addition to complying with customs formalities . This, however, did not change the fact that importers were and still are responsible for ensuring that products entering Canada comply with current regulatory compliance requirements and to be ready to demonstrate this if necessary. .

Since January 15, 2019 , importers must first check whether they need to obtain a license and, if so, they must then determine whether they need to implement one or more Preventive Control Plans - PCP .

This is part of the new provisions of the Safe Food for Canadians Regulations (SFCR) which is under the supervision of the CFIA . All Canadian companies that manufacture or trade food are now required to comply with the compliance requirements applicable in their particular case.

This can be very simple and only require a traceability program and a license or even go as far as the complete implementation of PCPs.

How far should importers go in their process?

Each case is specific and the level of potential hazards represented by the imported products will make a difference in the measures to be applied. The most regulated sectors are those for which compliance requirements will be the most elaborate.

Among these sectors there are:

  • Meat and poultry products

  • Dairy products

  • Preserves

  • Infant foods

  • Ready-to-eat processed foods

This does not mean that other foodstuffs are not controlled, but these are subject to more stringent control because of the hazards or potential impacts they represent in the event of food poisoning, for example. The list of food business activities that require a license is very long and detailed and it is not always easy to navigate through it. This is why importers are encouraged to, and can go, check themselves with the CFIA's online interactive tools to determine what their obligations are.

There are two important tools to help importers determine how far they need to go:

What to do next

Once the verifications are made , importers must comply with the compliance requirements that apply to them.

The best thing to do is to check with the representative of the regulatory authority, the CFIA in this case, whether you have correctly identified your responsibilities and the compliance requirements that you must meet.

You must then implement the mandatory elements to be compliant . To do this, it is advisable to prepare a work plan and appoint a person in charge of handling the files. This could be a member of your staff or a resource that you will hire.

It is also possible that you want to use an external resource to guide you and you in your efforts.

Given that the SFCR is now in force and fully in effect; you will have to complete everything before starting to operate, except perhaps in very special cases.

Contents of a PCP for an importer

Importers have all, as basic compliance requirements, to have in place a traceability program and a recall program.

If it turns out that a PCP is mandatory; it will be necessary to implement the following elements:

  • Perform a hazard analysis

  • PASF

  • A cleaning program

  • Procedures for receiving and shipping

  • A procedure for controlling allergens

  • An employee training program

  • A procedure for monitoring and updating the PCP (s)

  • Etc.

We are able to assist you with the implementation of a PCP as an importer including the implementation of your control measures for you to be able to comply with regulatory compliance requirements, norms , standards as well. that your customers' requirements (including those stipulated in the GFSI standards). This will make it possible to operate in full compliance with the rules and to conduct your import trade activities more smoothly and easily thanks to the new measures in place for import control. This will help you avoid unnecessary delays or potentially costly border detentions as well as prevent monetary penalties and/or losses.

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