December 19, 2022
Purpose
The Canadian Food Inspection Agency (CFIA) is reminding you of your responsibility to ensure the food you import is safe and that it meets Canadian requirements. We are doing this in response to finding unacceptable levels of chemical residues in certain fish and seafood products imported into Canada. To support you in these efforts, this message includes practical considerations and steps you can take to meet the regulatory requirements.
Food and hazard-specific information
Hazards associated with fish and seafood include pathogens, chemical residues, heavy metals, natural toxins and undeclared allergens. The CFIA regularly inspects and tests fish and seafood imported into Canada. Through these activities, the CFIA has found elevated levels of mercury and veterinary drug residues, which could pose a risk to consumers.
Mercury levels
Mercury is a highly toxic metal that accumulates in fish muscle, primarily from fish ingesting prey but also by fish absorbing it from the surrounding water. Elevated levels of mercury in fish indicate that the producer or exporter does not have an adequate monitoring program in place to ensure that their products are safe and meet Canadian requirements.
Under the Food and Drugs Act, Canada has established Maximum Residue Limits (MRLs) for mercury in fish.
Veterinary drug residues
A veterinary drug is a therapeutant used to treat a disease in aquatic animals. It is usually administered as a medicated feed.
Elevated levels of veterinary drug residues indicate that the drug was not administered according to the label directions or the veterinary prescription. For example, the dosage may have been too high, the drug may not be intended for aquatic animals or the withdrawal time may not have been adhered to.
Canada has established MRLs for veterinary drugs in fish. Only those drugs for which an MRL has been established by Health Canada may be used for fish sold in Canada. Banned drugs, or those for which use has not been authorized by Health Canada, should not be used for fish sold in Canada.
Your obligations as an importer
As a licensed importer, you are responsible for ensuring that the food you import is safe and that it meets Canadian requirements. You are required by the Safe Food for Canadians Regulations (SFCR) 11 (1) to source from foreign suppliers who manufacture, prepare, store, package and label the food you import under conditions that provide at least the same level of protection as the preventive measures outlined in part 4, sections 47-81 of the SFCR.
Under the SFCR, you must:
- implement a written preventive control plan (PCP) that documents how you and your foreign supplier(s) control the microbiological, physical and chemical hazards and risks associated with the foods you import
- keep complete and accurate traceability records that show who the food was obtained from and who it was sent to
You can find guidance on these regulatory requirements in the CFIA's Regulatory requirements: Preventive controls.
While the SFCR includes a set of general requirements that apply to a broad range of foods, some specific requirements apply to fish. These are specified in part 6, division5 of the SFCR. The CFIA has published a guidance document that provides an overview of these requirements.
Failure to comply with regulatory requirements may result in your products being recalled, seized or detained. In addition, your licence could be suspended or cancelled.
How to demonstrate that you are meeting regulatory requirements
You can demonstrate that you are meeting your regulatory requirements by taking the following steps:
- document your hazard analysis
- document evidence of the measures being taken by your foreign supplier(s) to prevent, eliminate or reduce to an acceptable level the hazards associated with the products you import
- validate, implement and then verify that your PCP is effective at controlling the identified hazards
- implement procedures and processes to detect and respond to food safety issues, to handle complaints and to conduct recalls
To help you develop, implement and maintain your PCP, the CFIA has written the importer guide: prepare your preventive control plan and a series of guidance documents.
Practical considerations
To help you achieve regulatory requirements, consider the following:
- select suppliers whose exports are certified by a foreign competent authority by choosing from the list of eligible exporters posted by the Foreign Competent Authority, if available
- select suppliers who implement Hazard Analysis and Critical Control Point (HACCP)-based food safety programs and/or internationally recognized voluntary third-party assurance programs
- select suppliers who can provide documented evidence that the food they supply to you meets Canadian requirements
- Select suppliers who regularly sample and test their products and process environment, have the samples analyzed by an accredited laband provide certificates of analysis
- select suppliers who have not been involved in recent food safety issues
- establish a formal agreement with your supplier to help ensure that their products meet Canadian requirements for safe food
The CFIA has created the Supplier Food Safety Assurance Program (SFSAP) to help you comply with the regulations. It's your choice. You may use other guidance documents that have been developed by provincial governments, industry associations, international partners or academic bodies, as long as they can achieve the same outcome.
Questions
For more information, visit our updated Toolkit for food businesses and use our new virtual assistant tool. If you are unable to find answers to your questions, you can contact CFIA online.
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