The following is provided by the Canadian Food Inspection Agency (CFIA).
The European Union (EU) food export requirements library webpage for fish and seafood has been updated in response to the findings of the EU’s audit on Canada’s food safety system as it relates to the production of fishery products intended for export to the EU.
The main updates include:
| Product Specifications section: updated web links to EU regulations which prescribe the microbiological and chemical requirementsNew section: inclusion of guidance on the certification of fish landed by EU vessels, stored in Canada (in-bond) and exported to the EU for human consumption |
Exporters are reminded of the following:
1) As per the Food Export Control Policy, exporters are responsible to ensure that exported foods meet the requirements prescribed in the Safe Food for Canadians Act and Regulations, and any additional conditions agreed upon by the CFIA and the foreign competent authority of the importing country. Where EU requirements differ from Canadian requirements, exporters must prepare and implement effective written controls that demonstrate compliance with these additional conditions. These are outlined as a special condition included under the public health requirements for fish and fishery products for human consumption in Section A of Annex 5-E to Comprehensive Economic and Trade Agreement (CETA), or on the EU food export requirements library webpage.
Please note that EU’s sampling and testing procedures of microorganisms in fish and fishery products may be different from Canadian requirements. For example, the microbiological criteria limits given in the annexes of Commission Regulation (EC) no 2073/2005 of 15 November 2005 on microbiological criteria for foodstuffs refer to each sample unit tested individually, and not as a pooled/composite sample for most microorganisms. Please refer to the most up-to-date/consolidated version of the regulation.
2) As per the Safe Food for Canadians Regulations subsections 47(1) and 47(2), operators licensed to manufacture, process, treat, preserve, grade, package or label food are required to conduct hazard identification and analysis, and to use effective control measures to prevent, eliminate, or reduce the hazards to an acceptable level.
Operators who implement a Supplier Food Safety Assurance Program (SFSAP) and utilize supplier agreements, also known as Supplier Quality Assurance (SQA) agreements, as a control measure when receiving raw materials (including fish and seafood) from non-CFIA licensed fishing vessels/establishments must ensure that the control measure is:
| identified – the preventive control plan (PCP) includes a written description of the SFSAP as a control measure and describes how it controls the identified hazard(s)implemented – any SQA agreement(s) established between the supplier(s) and the operator are documented, signed, valid and maintained on fileverified – the operator has verification procedures in place to ensure that this control measure is effective, and verification records are maintained |
For more information, please refer to the industry guidance: Supplier Food Safety Assurance Program.