Temporary import requirements for romaine lettuce from the United States

These requirements begin on September 24, 2026, and end on December 17, 2026.

1. Introduction

Romaine lettuce imported from the United States (U.S.) have been associated with several outbreaks of foodborne E. coli O157:H7 illnesses in Canada and the U.S. Food safety investigations from U.S. authorities have identified a recurring geographical area as the source of the outbreaks. This area encompasses the California Salinas Valley counties of Santa Cruz, Santa Clara, San Benito, and Monterey.

To decrease the risk associated with E. coli O157:H7 in romaine lettuce, the Canadian Food Inspection Agency (CFIA) is implementing temporary Safe Food for Canadians (SFC) licence conditions the importation of romaine lettuce originating from the U.S.

Temporary licence conditions pursuant to section 20 (3) of the Safe Food for Canadians Act will be in effect for the period of September 24 to December 17, 2026, including those dates.

Given the absence of reported E. coli O157:H7 outbreaks linked to romaine lettuce in recent years, along with the implementation of strengthened control measures for romaine lettuce originating from the Salinas Valley, the CFIA is introducing this year an alternative to lot-by-lot testing as part of the licence condition for importers.

This new option allows the importation of romaine lettuce, or products containing romaine lettuce from the specified four counties in California's Salinas Valley if the importer demonstrates that the member supplying the product is a California Leafy Greens Marketing Agreement (LGMA) member that participates and is in compliance with the California LGMA Romaine Test & Learn Program.

Compliance with the LGMA Romaine Test & Learn Program is demonstrated by obtaining evidence confirming that the LGMA member participates in the LGMA Romaine Test & Learn Program. Section 2 outlines additional details on this option.

Importation of romaine lettuce and products containing romaine lettuce from outside of the four specified California counties will continue to be allowed entry if the importer obtains a "proof of origin" indicating the state and county where the romaine lettuce was harvested. This is unchanged from the 2025 requirements.

The CFIA has removed the requirement to provide the Importer's attestation for romaine lettuce products from the Salinas Valley, California, United States (CFIA/ACIA 5961) form.

The CFIA has also removed the requirement for the supporting documents to be uploaded as part of the import declaration. However, importers must still obtain and retain the documents to demonstrate that all applicable temporary import requirements have been met.

The Appendix outlines the key changes to temporary licence conditions for the 2026 harvest season and the updated documentation requirements.

2. Temporary SFC licence conditions

2.1 Scope

The temporary SFC licence conditions apply to all U.S. import shipments of romaine lettuce and/or salad mixes containing romaine lettuce, sold in bags, in bulk, or combined with other food items, in a fresh state. It applies to all varieties of mature and baby romaine.

2.2. Requirements

From September 24 to December 17, 2026, importers of romaine lettuce and/or salad mixes containing romaine lettuce from the U.S. must meet the following requirements:

If the romaine lettuce originates from outside the counties of Santa Cruz, Santa Clara, San Benito, and Monterey in the Salinas Valley, California:
- as per the 2025 requirements, obtain a proof of origin from the exporter demonstrating the products do not originate from these counties (refer to Proof of Origin for more information).
If the romaine lettuce originates from the counties of Santa Cruz, Santa Clara, San Benito and Monterey in the Salinas Valley, California or if proof of origin is not provided, importers may choose one of the following two options:
- obtain evidence of participation in the Romaine Test & Learn (T&L) program from the LGMA member (New option for the 2026 harvest season) (Refer to 3.2 for details on the T&L option)
  
  or
- as per the 2025 requirements, obtain a Certificate of Analysis (CoA) for each consignment/shipment to demonstrate that the romaine lettuce/salad mixes do not contain detectable levels of E. coli O157:H7 (Refer to 3.3 for details on the CoA option)

2.3. Record-keeping

Importers must retain the applicable document(s) (Proof of Origin, evidence of participation in the LGMA Romaine T&L Program, or CoAs) on file to demonstrate that each consignment/shipment complies with this SFC licence condition.

NOTE: CFIA has removed the requirement for the documents above to be uploaded as part of the import declaration.

3. Guidance on the temporary SFC licence conditions Options

3.1. Proof of Origin

For shipments of romaine lettuce and/or salad mixes containing romaine lettuce from the U.S. but outside the California counties of Santa Clara, Santa Cruz, San Benito, and Monterey, a declaration from the exporter on an official company letterhead must be available upon request by CFIA and include:

the signature of the exporter
the date the letter was signed by the exporter
the state and county where the romaine lettuce was harvested

The same proof of origin letter may be used for multiple shipments. They do not have to be re-dated for each shipment.

3.2. Evidence of Participation in the LGMA Romaine Test & Learn Program (New option)

During the implementation period of these temporary licence conditions, importers who choose not to conduct lot-by-lot testing as outlined in section 3.3 must obtain evidence demonstrating that the LGMA member supplying the product participates in the LGMA Romaine T&L Program.

The evidence must be provided in the form of a letter and must include, at a minimum, the following information:

Name of the LGMA member
Date of issuance of the letter
A statement confirming that the certified LGMA member participates in the LGMA Romaine T&L Program
Name, title and signature of the LGMA member representative

The letter may be obtained once at the beginning of the import period. Upon request by CFIA, the importer must be able to provide the evidence demonstrating that the LGMA member supplying the product participates in the LGMA Romaine T&L Program.

3.3. Certificate of Analysis

Importers who do not choose the new option are required to obtain a Certificate of Analysis (CoA) issued by the laboratory that conducted the test for each romaine product in an import shipment, demonstrating that the test result for E. coli O157:H7 is negative. The CoA must include:

the date of sample collection
the certificate number
the laboratory that analysed the sample
the client
a product description and lot identifier(s)
the methodology
the sample weight and number of units
the test result
the test date

Importers must be able to demonstrate how the CoA links to the specific type of romaine product in the shipment.

3.3.1. Certificate of Analysis (CoA) Requirements

Each shipment must meet the following conditions:

the licence holder's preventive control plan includes a written procedure describing how the sampling and testing requirement outlined below is implemented
each shipment has an official Certificate of Analysis (CoA) for each romaine-lettuce product in the shipment; sampling and testing was conducted according to the temporary SFC licence conditions (points d., e., and f. below); and E. coli O157:H7 was not detected
each shipment can be linked to the CoA issued for the romaine products in the shipment
the imported product was sampled and tested for E. coli O157:H7 according to 1 of the 2 sampling options described below and the testing conditions outlined in points e. and f.:
- Option 1: Finished-product sampling
  - sampling and testing is conducted after all post processing and handling steps are completed, but before the product is imported into Canada
  - a sampling lot is 1 type of romaine-lettuce product and a size no larger than the equivalent of 1 truckload of product (no more than 20,400 kilograms/45,000 pounds)
  - for each sampling lot, the minimum sampling and testing requirement is a total sample weight of 1,500 g consisting of 60 individual random sample units of 25 g each
- Option 2: Pre-harvest sampling
  - sampling of romaine lettuce in the field is conducted no more than 7 days before harvest
  - a sampling lot is a 2 acre field or less of homogeneous romaine lettuce crop that has been exposed to homogeneous agricultural conditions
  - for each sampling lot, the minimum sampling and testing requirement is a total sample weight of 1,500 g consisting of 60 individual random sample units (grab specimens) of 25 g each
  - this sampling option can be used for romaine lettuce that will be field-packed at the time of harvest
    
    This option is also acceptable for romaine lettuce destined for further processing before export (for example, chopped or mixed with other products) if the product is to be processed in separate batches, and a link can be established and documented between the Certificate of Analysis of the product sampled in the field and the finished product at the time of import
testing with both screening and confirmation methodologies must be performed in a laboratory accredited by an accreditation body that is a signatory to the International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Agreement (MRA) as conforming to the requirements of ISO/IEC 17025:2017 for specific tests

The chosen method must be on the laboratory's scope of accreditation

The "application" section of the method chosen must be appropriate for the intended purpose, including that it is intended for testing romaine lettuce, leafy greens, or fresh fruits and vegetables
a presumptive positive result from a screening method is treated as a positive result for E. coli O157:H7 unless a confirmation test is performed on the original enrichment broth within 24 hours of the first test and produces a negative result (that is, not detected)

The confirmation test is a cultural method that is compatible with the screening method

3.3.2. Sampling

The sampling level is based on International Commission on Microbiological Specifications for Foods (ICMSF) recommendations for E. coli O157:H7. The 2 sampling options are considered of similar value in achieving the required sampling level. The sample units must be collected aseptically and be representative of the lot being tested.

For option 2, additional guidance on how to take representative samples from a field is available on the California LGMA website (see Appendix C (PDF)).

Examples of appropriate sampling for option 1: Finished-product sampling

When to sample:

field packaged romaine hearts can be sampled after cooling and just before they are loaded into a transport truck destined for Canada
bulk romaine lettuce can be sampled just before it is loaded into a transport truck destined for Canada
mixed salad sold in bags can be sampled during the packaging process at the processing facility or before it is loaded into a transport truck destined for Canada

Sampling lots:

Example 1 – A shipment of 800 cartons of pre-packaged romaine hearts, 50 cartons of wrapped iceberg lettuce and 169 cartons of mixed bagged salad containing romaine lettuce:
- this shipment should be considered 2 sampling lots
  
  1 sampling lot is 800 cartons of pre-packaged romaine hearts
  
  the other sampling lot is 169 cartons of mixed bagged salad containing romaine lettuce
- when romaine-lettuce products in a shipment have different bar codes or Price Look-Up (PLU) codes, they should be treated as separate sampling lots
Example 2 – A shipment of bulk romaine lettuce with a weight of 14,000 kilograms

The shipment will be delivered to numerous clients in Canada after import to Canada:
- this shipment should be considered 1 sampling lot
Example 3 – An importer purchases 1,500 cartons of pre-packaged romaine hearts weighing less than 20,400 kilograms

This product will be shipped to Canada in 4 shipments headed to various distribution centers in Canada:
- this product can be considered 1 sampling lot
- the importer's preventive control plan must include a system for tracking all shipments that are associated with the Certificate of Analysis

All packages, cases or containers in the sampling lot must be equally represented in the sample. For example, a shipment of 800 cartons should have no more than 1 piece taken in a carton, and the 60 cartons sampled should be selected from various parts of the shipment. A shipment of 10 cartons should be sampled by collecting 6 pieces per carton. Product sampled during the packaging process should be sampled at the beginning, middle and end of the lot.

Examples of appropriate sampling for option 2: Pre-harvest sampling

When to sample:

sampling is conducted as close as possible to harvest day, but not more than 7 days before harvest
if the 7-day window is exceeded, the sampling lot can be re-sampled before harvest or the finished product can be sampled later according to option 1: Finished-product sampling

Sampling lots:

Example 1 – A 3-acre plot of romaine lettuce intended for packaged romaine hearts:
- 2 sampling lots must be taken as the field size from which the romaine lettuce was harvested exceeds the maximum 2-acre sampling size
Example 2 – A shipment of bulk romaine lettuce with a weight of 14,000 kilograms
- The bulk romaine is from 2 farms:
  - this shipment should originate from at least 2 pre-harvest sampling lots (at least 1 from each farm)
  - the number of sampling lots from each farm depends on field size from which romaine lettuce was harvested (maximum 2-acre sampling size)
Example 3 – A shipment of 169 cartons of mixed bagged salad containing romaine lettuce:
- this shipment could originate from 1 pre-harvest sampling lot provided all of the romaine lettuce was harvested from 1 homogeneous field not exceeding 2 acres
- the product must be processed in batches separate from other product with a clear break between production lots
- a link must be established and documented between the Certificate of Analysis of the product sampled in the field and the finished product at the time of import
- if the processing facility handles tested and untested products (or products not tested according to the temporary SFC licence conditions), the break between production lots requires a full sanitation of the production line
Example 4 – Pre-harvest sampling and testing is conducted on a sampling block that is subsequently harvested over multiple days:
- the gap between the sampling date and the last harvest date must not exceed 7 days

3.4 Document

Depending on the import admissibility option used, licence holders must retain copies of all documents and make them available to CFIA upon request to demonstrate compliance with the temporary licence conditions. This includes Proof of Origin, evidence of LGMA member participation in the LGMA Romaine T&L Program and/or CoAs.

4. Legislative authority

The licence conditions are based on the following legislative authority.

Section 20(3) of the Safe Food for Canadians Act states: "The Minister may make a registration or licence subject to any additional conditions that the Minister considers appropriate."

The import requirements are based on the following legislative authority.

Section 8 of the Safe Food for Canadians Regulations and Section 4 of the Food and Drugs Act.

Section 8(1) of the Safe Food for Canadians Regulations states:

"Any food that is sent or conveyed from 1 province to another or that is imported or exported

(a) must not be contaminated
(b) must be edible
(c) must not consist in whole or in part of any filthy, putrid, disgusting, rotten, decomposed or diseased animal or vegetable substance; and
(d) must have been manufactured, prepared, stored, packaged and labelled under sanitary conditions"

Section 4 of the Food and Drugs Act states: "No person shall sell an article of food that:

(a) has in or on it any poisonous or harmful substance
(b) is unfit for human consumption;
(c) consists in whole or in part of any filthy, putrid, disgusting, rotten, decomposed or diseased animal or vegetable substance;
(d) is adulterated; or
(e) was manufactured, prepared, preserved, packaged or stored under unsanitary conditions."

Failure to comply with the temporary licence conditions and import requirements may result in enforcement action taken by the CFIA.

5. Appendix: Documentation requirement changes for 2026

Document	Requirements Applicable Prior to the 2026 Harvest Season Review	New Requirements for the 2026 Harvest Season
Proof of origin	Must accompany each shipment of romaine from outside of the 4 Salinas counties. Must be uploaded at time of import declaration.	Must be available for each shipment of romaine from outside of the 4 Salinas counties. Must be made available to CFIA upon request.^{Table Note *}
Attestation Form	Must accompany each shipment from the 4 Salinas counties. Must be uploaded at time of import declaration.	Not required
Certificate of Analysis (CoA)	Must accompany each shipment from the 4 Salinas counties. Must be uploaded at time of import declaration.	Must be available for each shipment from the 4 Salinas counties, unless evidence of participation in the LGMA Romaine T&L Program is obtained from the LGMA member. Must be made available to CFIA upon request.^{Table Note *}
Evidence of participation in the LGMA Romaine T&L Program	Not required	Must be obtained from the LGMA member, unless a certificate of analysis for each shipment is provided. Must be made available to CFIA upon request.^{Table Note *}

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