Safe Food For Canadians Licensing Process Updated

The Canadian Food Inspection Agency (CFIA) has updated the Safe Food for Canadians (SFC) licensing process, including the introduction of additional information requirements, more thorough pre-issuance review procedures, and longer processing times.

The Safe Food for Canadians Regulations (SFCR) made under the Safe Food for Canadians Act (SFCA) establishes the framework for food safety and licensing in Canada.  Under the SFCR, businesses that conduct certain food related activities (e.g., importing, exporting or manufacturing food products) must obtain a licence. To do so, they must apply to the CFIA, which has the authority to issue, renew, amend, suspend or cancel a SFC licence. The changes originally introduced by the SFCA parallel those in the U.S. under the Food Safety Modernization Act (FSMA).  

One of the key changes introduced to the SFC licensing process is the introduction of the Food Safety Supplemental Information (FSSI) questionnaire, which replaced the previous Additional Establishment Information (AEI) questionnaire. Food businesses conducting domestic activities are now required to complete this questionnaire about their establishment’s operational activities and mitigation measures with respect to food safety risks as part of the licensing process when applying, renewing or amending a SFC licence or when changing operational practices (e.g. new product).

Further, SFC licence applications, renewals and amendments will undergo a pre-issuance review by the CFIA before approval, which may include evaluating the businesses’ inspection history, among other things.

Processing timelines have also increased significantly. While applications could previously be processed relatively quickly, the CFIA has introduced a service standard of an average of 70 business days to process requests requiring pre-issuance verification. As a result, early renewal submissions are recommended. Businesses can apply up to 120 days before licence expiry. If a licence lapses, businesses must stop their operations relating to that licence until a new licence is issued.

The CFIA has also highlighted that licence details must accurately reflect current operations, and amendments cannot be processed while a licence renewal is under review.  Lastly, the updates reinforce the importance of implementing preventive controls and maintaining a Preventive Control Plan (when required) in compliance with Part 4 of the SFCR.

For questions regarding regulatory law, including how the updated SFC licensing process may affect your operations or licence renewal timeline, contact Gordon S. Jepson or Victoria Di Felice.

Summary By: Victoria Di Felice & Gordon S. Jepson