Safe Food for Canadians Regulations becomes law with effective date of January 15, 2019

The Minister of Health announced the publication of the final Safe Food for Canadians Regulations. This regulation has been in the development stages since November 2012 following the enactment of the Safe Food for Canadians Act. Retail Council of Canada (RCC) has been actively involved in helping shape the new regulations.

The Safe Food for Canadians Regulations is the biggest change in food regulation in over 25 years. It applies to all food, consolidates 14 different food regulations into one, strengthens food safety requirements, including requiring traceability of food by all supply chain partners, and governs domestically produced, imported and exported food.

New requirements for food industry companies include:

• Requiring all who manufacture, process, treat, preserve, grade, package and label food for interprovincial trade and export; import food; store or handle meat products that need Canadian Food Inspection Agency (“CFIA”) inspection or slaughter food animals; to hold a CFIA licence;
• Requiring companies to have a written and implemented food safety preventive control plan;
• Requiring companies to have processes in place for tracking and tracing food one-back and one-forward.

Retailers are specifically required to maintain one-back traceability records and, depending on other activities they perform, may be required to meet additional requirements.

CFIA has published numerous guidance documents to facilitate industry understanding and compliance which can be found here.

The regulations come into force on January 15, 2019. This allows both industry and government to better adapt to the changes and create a smoother transition. For new provisions, industry will have additional time to comply from 6 months to 2 ½ years (most will have an additional 1 ½ years).

Through the efforts of RCC and other food industry associations, there were some important changes secured from what was originally proposed. For example:

• Importers who are located outside of Canada and produce food in a country where there is recognition of food safety systems between Canada and that country, can seek a licence from CFIA and do not require a business address in Canada;
• The coming into force date and additional transitional provisions recognize the time required for such a large change;
• Organic certification will no longer be required for storage and distribution activities. It is limited to packaging and labelling.

Next Steps:

• RCC will continue to engage with CFIA to further understand the regulations, answer member questions and work with CFIA where there may be continued concerns;
• RCC will update the RCC Safe Food for Canadians Guidebook that was published in 2017.

If you have questions or concerns, please do not hesitate to contact Cory Anderson at canderson@retailcouncil.org or 613-668-9114 or Sherry Casey at scasey@retailcouncil.org