The proposed Safe Food for Canadians Regulations, under the authority of the Safe Food for Canadian Act, were published in Part 1 of the Canada Gazette on January 21, 2017.
Included in the proposed regulations are requirements for licenses, traceability, and a preventive controls and preventive control plan (PCP), all of which are of interest to CSCB members and their clients.
Of particular concern is the requirement for a licence. This has been addressed as a stakeholder concern and CFIA’s response is included in the Regulatory Impact Analysis Statement:
1. Many importers currently operate from outside of Canada. A requirement to have a Canadian fixed place of business could result in significant costs associated with setting up an office in Canada.
CFIA response: The proposed Regulations would allow for importers who do not have a fixed place of business in Canada to hold a licence if they have a fixed place of business in a foreign state that has a food safety system that provides at least the same level of protection to that of Canada. Canada has such an arrangement with the U.S. Food and Drug Administration, which was signed in 2016.
The CFIA is proposing a phased approach for the coming into force of the proposed Regulations and these time frames are listed in Table 1. Please note that changes will take effect immediately upon the Act coming into full force.