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Packaging Requirements Included in Canada’s SFCA Proposed Implementing Regulations

January 25, 2017

Canada’s proposed regulations to implement the Safe Foods for Canadians Act (SFCA), which was adopted on June 7, 2012, include a section on packaging requirements for prepackaged food that is conveyed from one province to another or that is imported or exported. These requirements, found in Section 183 of the proposed regulations, state that the package must be:

  • Suitable for its intended use and appropriate for the food
  • Capable of protecting the food against moisture, loss, damage, contamination and deterioration during normal handling, storing and conveying
  • Clean and in sanitary condition
  • Of sound construction
  • Free from odors that might affect the food

In addition, a package must not impart any undesirable substance to the food or have a design or mark or be of a color that enhances the appearance of the food with respect to its quality or composition.

There are three key elements to the proposed Regulations:

  • Licenses would be required for anyone (1) importing food; (2) preparing food for export or interprovincial trade (with some exceptions); or (3) slaughtering food animals from which meat products for export or interprovincial trade may be derived. The license would be valid for a period of two years for a fee of approximately $250, and could be suspended or cancelled in cases of non-compliance.
  • International standards established by the Codex Alimentarius Commission for traceability would apply to anyone (1) importing, exporting or interprovincially trading food; (2) holding a license issued under the SFCA; or (3) growing or harvesting fruits or vegetables that are to be exported or traded interprovincially. Electronic or paper records would be required in order to track food forward to the immediate customer and backwards to the immediate supplier.
  • Companies that manufacture food or conduct activities that are subject to the Regulations would be required to have a preventive control plan (PCP) that is consistent with internationally-recognized agricultural and manufacturing practices (i.e., GAPs, GMPs and HACCP).

Among other resources, CFIA has published a handbook for food businesses; interactive tools to help determine whether a license or PCP is needed and the applicable traceability requirements; and step-by-step guides (in draft form) on developing a preventive control plan for domestic food businesses and exporters and importers.

The proposed regulations are intended to be in line with approaches being taken by key trading partners – including the United States, the European Union, Australia and New Zealand. A 90 day consultation period is open through April 21, 2017. Information on how to submit comments can be found here.