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Discussion paper: Boat-to-plate traceability mandate commitment

This discussion paper is part of a consultation to inform approaches to deliver on the Government of Canada's commitment for boat-to-plate traceability of fish and seafood products. The 120-day consultation will be from August 13, 2021 to December 11, 2021.

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Introduction

The Minister of Health's mandate letter (December 2019) introduced a commitment to develop a boat-to-plate traceability program for fish and seafood products. The Canadian Food Inspection Agency (CFIA) is undertaking this work along with Agriculture and Agri-Food Canada, and Fisheries and Oceans Canada.

"Working with the Minister of Fisheries, Oceans and the Canadian Coast Guard and the Minister of Agriculture and Agri-Food, in your role as the Minister responsible for the Canadian Food Inspection Agency, develop a boat-to-plate traceability program to help Canadian fishers to better market their high-quality products."

Rt. Hon. Justin Trudeau, P.C., M.P.
Prime Minister of Canada

The Government of Canada is committed to fulfilling the mandate commitment and has engaged various stakeholders in the fish and seafood sector since the mandate letter was issued, including:

We engaged with stakeholders to:

Based on the information gathered from these initial consultations, we have developed this discussion paper and are seeking feedback from all stakeholders (such as industry, associations, academia, non-government organizations, other government departments) including consumers.

This is also an opportunity to review the traceability systems currently in place and to better understand how these may be further developed to better respond to consumer, industry and other stakeholder needs.

How to participate in the consultation

We are seeking your input on the 3 key themes (or drivers) of the mandate commitment, which were identified during various stakeholder engagements to date:

Since traceability is a potential tool and supports the 3 themes, the topic of traceability is embedded in these sections as relevant.

We invite you to review the discussion paper, which includes background information and an analysis of each theme, and provide your feedback on related questions.

You can also share any additional information relevant to the themes that you'd like us to consider. Please include comments where appropriate and give examples whenever possible.

You can submit your feedback online or email written comments about any element of this paper to BTP-BAT@inspection.gc.ca.

The 120-day consultation will be open from August 13, 2021 to December 11, 2021.

Once the comment period ends, we will analyze the feedback and publish a report summarizing what we heard. Your feedback and responses, combined with those of others, will help guide and support identification of approaches to fulfill the boat-to-plate traceability mandate commitment.

Fish and seafood in Canada

Fish and seafood are important to our economy and the diet of many Canadians. Bound by 3 oceans, the Pacific, Arctic and Atlantic Oceans, Canada is home to the longest coastline and largest freshwater lake system in the world.

Canadian marine and freshwaters contain more than 160 species of fish and seafood. Our fresh, frozen, smoked and canned products are in high demand in every corner of the globe. Canada exports approximately $7 billion worth of fish and seafood annually to just over 120 countries and imports about $4 billion in fish and seafood from just over 140 countries.

According to available international trade statistics, the top exported species in 2019 (by volume) were lobster, Atlantic salmon, shrimp, snow crab, and other crab. The top species imported into Canada (by volume) were salmon (all species), shrimp (all species), skipjack tuna, and all species of crab. According to available statisticsFootnote 1, 17.4% of Canadians include fish or shellfish as a source of protein in their diet on any given day. The per capita fish and seafood consumption in Canada has been relatively stable for the past 20 years.

Federal roles and responsibilities

The Government of Canada's responsibility for the regulation of the fish and seafood sector is shared between various departments at the federal level. The provincial, territorial, and municipal governments also have legislation to regulate and safeguard fish and seafood in Canada.

The roles and responsibilities described below are those of the 3 federal government departments identified in the Minister of Heath's Mandate commitment to develop a boat-to-plate traceability program for fish and seafood products. The CFIA is undertaking this work along with Fisheries and Oceans Canada and Agriculture and Agri-Food Canada.

Canadian Food Inspection Agency

Food safety and consumer protection are key priorities for the CFIA. CFIA sets the policy for the Safe Food for Canadians Regulations (SFCR), and the Food and Drug Regulations (FDR) related to food, except those that relate to public health, safety or nutrition, which falls under Health Canada. CFIA enforces all the requirements of the Safe Food for Canadians Act (SFCA) and its regulations and the Food and Drugs Act (FDA) and its regulations as it relates to food.

The SFCR generally applies to food for human consumption (including ingredients) that is imported, exported, or inter-provincially traded for commercial purposes. The legislation includes requirements for licensing, preventive controls, and traceability. Certain provisions also apply to the handling of fish that are to be exported or sent or conveyed from one province to another.

CFIA also has a mandate to support and protect the health of Canada's wild and farmed aquatic animal resources, including fish and seafood. CFIA regulates aquatic animals that can carry diseases of finfish, molluscs and crustaceans through the National Aquatic Animal Health Program (NAAHP). CFIA has the authority to administer the NAAHP using the Health of Animals Act and its associated regulations.

Fisheries and Oceans Canada

Fisheries and Oceans Canada (DFO) is the federal lead for safeguarding Canada's waters as well as managing fisheries and ocean resources.

DFO helps to ensure healthy and sustainable aquatic ecosystems through habitat protection and sound science. It supports economic growth in the marine and fisheries sectors, and innovation in areas such as aquaculture and biotechnology.

DFO enforces the Fisheries Act and other regulations and legislation, advances policies and manages fisheries to support a healthy and sustainable fishing sector. As part of this work, DFO regulates harvest and landings for Canadian marine fisheries regulating the introduction or transfer of fish into the marine environment, and aquaculture (in British Columbia and Prince Edward Island) when they are in the water; the earliest point in the domestic supply chain. DFO is also responsible for:

Agriculture and Agri-Food Canada

Agriculture and Agri-Food Canada's (AAFC) mandate with regards to the fish and seafood processing industry is to provide market development programs and services, as well as providing technical and program assistance for the development and implementation of traceability systems.

AAFC is also leading on the Food Policy for Canada, a roadmap for a healthier and more sustainable food system in Canada – one that builds on the Government's ambitious agenda to support the growth of Canada's farmers and food businesses, as well as key federal initiatives like the Heathy Eating Strategy, Canada's Food Guide, and the Poverty Reduction Strategy, as well as work on food fraud, food labelling, and food loss and waste, among others.

Theme 1: Consumer protection and food safety

Seafood misrepresentation and mislabelling

When we buy fish, we expect to get what we paid for, but sometimes that is not the case. Misrepresentation and mislabelling occur when advertising or labelling of a food doesn't align with what the food actually is or contains. Species substitution occurs when one species of fish is incorrectly or falsely represented as another species, usually of higher value. For CFIA purposes, food fraud relates to misrepresentation of food.

Misrepresentation can negatively impact consumer trust and can lead to negative economic impacts for consumers and industry. It can also have impacts on human health, such as presence of undeclared allergens or non-permitted substances. Misrepresentation can also lead to an unfair marketplace for those selling accurately labelled food products.

Budget 2019 introduced funding for the CFIA, through the Food Policy for Canada to enhance efforts to tackle this aspect of food fraud, including for fish and seafood. Between April 2019 and March 2020, the CFIA sampled and tested fish from domestic processors, importers, and retail establishments across Canada for authenticity.

CFIA published a summary report of its findings Enhanced fish species substitution surveillance (2019 to 2020). The samples were assessed satisfactory if the declared common name on the fish sample's label matched the common name on the CFIA Fish List for the species identified from the DNA database.

This targeted surveillance and sample collection found 91.8% out of the 352 samples tested had a common name on the label that matched the species identified through DNA testing. 8.2% of the samples tested had common names on the label that did not match the species identified, indicating product misrepresentation.

The breakdown of unsatisfactory results, by level of trade, were as follows (figures are rounded):

Results also showed that out of the types of species sampled kingfish, red snapper and sea bass were most often mislabelled.

Sampling was risk-based and targeted. This means that the CFIA specifically tested species of fish with a higher likelihood of being mislabelled or substituted. CFIA sampling plan also took into account risk factors such as history of non-compliance when collecting samples. As such, the test results don't necessarily represent the marketplace overall.

In addition to CFIA's recent surveillance results, various third-party reports have outlined the occurrence of fish species substitution in Canada. Some organizations have reportedFootnote 2 a higher incidence of fish species substitution in Canada, while others have reported a lower incidenceFootnote 3. The differences may be due to study design factors such as:

CFIA mitigation measures

CFIA has a number of tools available to prevent, detect and deter fish species substitution and fish and seafood misrepresentation in Canada.

Prevention includes promoting compliance to industry, through items such as:

Did you know

CFIA is working with Health Canada to address health and safety risks resulting from food misrepresentation through the Food Policy for Canada.

To detect fish and seafood misrepresentation, the CFIA carries out both planned and reactive (for example, complaint-based) inspection activities. Inspection activities include verifying that preventive controls are in place, and may also include verifying labels and sampling. CFIA uses DNA-based testing of samples to determine if fish species are accurately labelled.

When the CFIA identifies misrepresented food and other non-compliances, it takes appropriate enforcement action, taking into consideration harm, history and intent. To deter non-compliance, there is a range of possible actions including:

In addition, the CFIA publishes enforcement data that identifies regulated parties that have been subject to enforcement actions.

CFIA also plays a role in addressing false and misleading information on restaurant menus as well as deceptive practices. However, restaurant and food service inspections across Canada are generally carried out for food safety by provincial governments, municipalities and regional health authorities.

Discussion points: Seafood misrepresentation and mislabelling

  • Are you aware of the potential for fish species being misrepresented on the label?
  • Can you recall an instance where you believed fish was misrepresented when you made a purchase? If yes, what information did you use to determine this? Please explain.
  • What sources of information do you access or follow to stay informed and protect yourself from potential fish fraud?
    • Government websites
    • News channels and websites
    • Social media
    • Word of mouth - friends, relatives, and others
    • Others (please describe)
    • Not applicable
  • Are you aware of types of fish misrepresentation other than species substitution that needs attention? If so, please explain.
  • Various reports indicate that fish species substitution increases as it moves through the supply chain from primary producers to the retail or restaurant level. What information do you have that either supports or contradicts this statement? Why do you think this is?
  • CFIA has described several of the measures it takes to mitigate fish species substitution and other types of misrepresentation. What complementary measures are currently in place by industry at the various levels of trade, such as the domestic processor, importer, retail and restaurant level?
  • What additional measures would be most effective and how would they be effective?
  • Is there sufficient understanding by regulated parties of the regulatory requirements and tools available to ensure fish and seafood is not falsely labelled or misrepresented?
  • What type of information and communication mechanisms do you recommend to help increase awareness?
  • What role do you see your organization playing in promoting compliance or in educating consumers about fish and seafood misrepresentation?
  • Do you have additional comments to share about seafood misrepresentation and mislabelling?

Food labelling: Information on fish species

The Food and Drug Regulations (FDR) and Safe Food for Canadians Regulations (SFCR) require a common name on the principal display panel of a prepackaged food [B.01.001(1), B.01.006(1), FDR 1; 218(1)(a), SFCR]. The common name of the food is the name by which the food is commonly known, unless it is otherwise prescribed by regulation.

A scientific species name is not required to be on the label of prepackaged fish and seafood in Canada. Fish products are not unique in this regard. For example, tea and various herbs are not required to be labelled with the plant species from which they are derived.

Canada's labelling requirements for common name of fish provides the consumer with a name they recognize and use, such as "salmon" on the label rather than Oncorhynchus kisutch.

While a scientific name is not required to be on the label of a prepackaged food in Canada, it could be voluntarily added, provided it is not false or misleading. Some countries use different approaches, such as declaring a scientific name and a common name on fish and seafood labels (for example countries in the European Union).

Food labelling: Information on country of origin

Prepackaged fish and fish products imported into Canada are required to clearly identify the name of the foreign state of origin [13(1)(c) 266, SFCR]. CFIA's position in regards to the foreign state of origin aligns with Codex Alimentarius, the international food standard-setting body. The Codex General Standard for Labelling of Prepackaged Foods – PDF (279.5 kb) indicates that the country of origin for the purposes of labelling is the country where the food undergoes the last substantial processing step that changes its nature.

Through consultations on the Food Labelling Modernization initiative, the CFIA learned that consumers were supportive of country of origin labelling (aligned with Codex Alimentarius) while industry had a range of views. Some industry stakeholders outlined the challenges of origin labelling when multiple locations are used for processing or when products are sourced from different origins depending on factors such as seasonality, availability and pricing.

Food labelling: Information on catch method or farming

Currently the catch method is not required to be declared on the label of prepackaged fish and seafood products in Canada, but can be applied provided it is not false or misleading. In some jurisdictions it is required, such as the European Union (EU) – PDF (2.06 mb). In the EU, the product label must indicate whether the fish or seafood was caught at sea, in freshwater or was farmed. In addition, the type of fishing gear used to catch the product to be declared, such as "seines," "gillnets and similar nets," "hooks and lines" or "dredges."

Food labelling: Consumer access to information

Did you know

Nunavut has a Lake-to-Plate program designed to support local, Inuit fishers to sell whole, hand caught, unprocessed Arctic char across Canada.

Food labels must include the name and principal place of business for whom or by whom the food was manufactured, prepared, produced, stored, packaged or labelled [218(1)(b), SFCR; B/01/007(1.1)(a), FDR]. Consumers can use this information to contact the responsible food business to request information on specific products.

Some fish and seafood businesses have begun to voluntarily include information on catch method, location or harvesting country and scientific species name on product labels. Voluntary disclosure of additional information on food labels is permitted in Canada, provided the information is not false or misleading [6(1), SFCA; 5(1), FDA].

Discussion points: Food labelling

  • When deciding what fish to buy, does the common name sufficiently identify the fish? If not, please explain why.
  • Have you experienced situations where you were unable to make an informed choice about the type of fish because the scientific species name (for example, Oncorhynchus mykiss) wasn't on the label?
  • If yes, please describe the situation. Were you able to obtain information on species when you requested it from the food business?
  • Have you ever contacted a food business to get information that was not provided on a fish or seafood label? If no, why? If yes, was the information made available to you?
  • How important are the following to you when purchasing seafood? Rank each item in the order of its importance to you. Number 1 being 'most important to you' and 12 as 'least important'.
    • price
    • brand
    • freshness/quality
    • traceability information on label
    • sustainably sourced/certified on label
    • country of origin
    • organic
    • wild caught
    • farmed fish
    • best before date marked on the label
    • information about fishing gear on the label
    • catch methods and their effect on fish stocks and ecosystems
  • If considering the country of origin for your purchase, are you aware the country of origin for the purposes of labelling is the country where the food undergoes the last substantial processing step that changes its nature?
  • What are some considerations for industry regarding labelling of scientific species name, catch location and catch method that are required in some other jurisdictions?
    For example:
    • Is this information readily available?
    • Is your organization already providing it voluntarily to consumers?
    • Would providing it incur additional costs? Are you able to quantify these?
  • Do you have additional comments to share about food labelling?

The CFIA Fish List

The CFIA Fish List provides guidance on common names for fish and seafood that are considered to be acceptable for labelling fish products sold in Canada. Adhering to the Fish List is not a regulatory requirement, using common names published in the CFIA Fish List is considered to be in compliance with common name regulatory requirements.

Internationally, the Food and Agriculture Organization of the United Nations – PDF (621.7 kb) recognizes that a list of common names linked to species is a critical tool in addressing fish fraud.

The CFIA Fish List also provides a taxonomic serial number for each species, along with any associated hazards. Scientific names for fish species are verified with the Integrated Taxonomic Information System.

The CFIA Fish List is a tool intended to help industry meet the requirements for use of common names on food labels in Canada. Its purpose is to provide a consistent basis for determining common names, in support of market fairness, and to protect consumers from false or misleading common names.

Discussion points: The CFIA Fish List

  • Before reading this discussion paper, were you aware of the CFIA Fish List and its associated guidance for fish common names?
  • Is the CFIA Fish List and its associated guidance an appropriate tool to assist in determining common names?
  • Please explain. For example, if you answered yes for the question above, describe what you see as the value and utility of the CFIA Fish List.
  • Do you use the CFIA Fish List and its associated guidance to help you determine an acceptable common name?
  • If you use a different resource to determine acceptable common names, please describe it (for example, scientific literature, other lists, documents from suppliers, etc.)
  • CFIA currently maintains the CFIA Fish List, but could there be alternative approaches and/or stakeholder involvement to maintain it? If yes, what could those alternative approaches be? What types of stakeholders would need to be involved?
  • Do you have additional comments to share about the CFIA Fish List?

Traceability

Traceability is the ability to trace an item, whether it be an animal, plant, food product, or ingredient, from one point in the supply chain to another, either backwards or forwards (ISO/DIS 22005).

Traceability systems are important, effective tools to provide consumers with assurances related to food safety, sustainability, authenticity, etc. Traceability also enables industry to meet regulatory requirements and effectively manage their supply chains. Systems can be voluntary or mandatory, implemented through individual supply chains or throughout entire sectors.

Seafood traceability is not a new concept in Canada. For certain species and fisheries, domestic industry practices are already in place to achieve traceability which includes the current preventive control plans (PCP) (formerly quality management programs (QMP)). The industry also adopts private standards and voluntary certifications in an effort to ensure high standards of food safety and quality, environmental sustainability, combatting Illegal, Unreported and Unregulated (IUU) fishing, and traceability via full-chain custody of seafood products.

Many consumers want to know when, where and how their seafood was harvested and processed. Industry and governments have developed and implemented key components of traceability systems to assure consumers in Canada and to meet market requirements around the world.

Traceability requirements for food safety

In 2019, the CFIA implemented new food traceability requirements under the Safe Food For Canadians Regulations (SFCR). Most food businesses are required to keep records "one step forward and one step back." This allows food to be traced from one point in the supply chain to the next.

Food businesses subject to SFCR must keep documents to identify the food. These documents must indicate the following:

Food businesses subject to traceability requirements must also keep records of who provided them with the food and on what date; and, except at the retail level, to whom they provided the food and the date on which they provided it.

Along with record keeping, the SFCR also includes traceability labelling requirements which require businesses to include the following information on the food label:

SFCR traceability requirements apply to all foods traded interprovincially, imported or exported, and to foods sold at retail (other than meals and snacks sold by restaurants and similar enterprises). The requirements are not tailored to specific food commodities. These requirements are based on the international standard for traceability established by Codex Alimentarius.

Did you know

The SFCR traceability requirements apply to a broader scope of food businesses than the licensing and preventive control plan requirements. For example, traceability requirements apply to persons who import, export or send or convey food from one province to another, as well as who sell food to consumers (other than meals or snacks sold by restaurants and similar enterprises).

The SFCR traceability requirements can aid in the quick removal of unsafe food from the marketplace. However, it is important to note that these requirements do not apply to meals or snacks sold by restaurants and similar enterprises, or food businesses that trade food only within the province prior to retail sale. Imported food, can be traced back to the foreign exporter.

Fish and seafood products imported into Canada must be safe to consume and must meet all applicable Canadian requirements. This means that any imported fish and seafood must be prepared with the same level of food safety controls as other types of foods prepared in Canada. It must also comply with all Canadian labelling and compositional requirements. In addition, imported seafood must be declared by its appropriate scientific name for traceability purposes for aquatic animal disease control on the importing document [194 (c), Health of Animals Regulations].

Discussion points: Food safety traceability

  • Please comment on the points in the supply chain at which the food safety traceability requirements of the Safe Food for Canadian Regulations (SFCR) apply. Do you see any gaps? If yes, please explain.
  • What would be some considerations related to expanding the reach of existing traceability to additional points in the supply chain such as restaurants?
  • Are current SFCR food safety traceability requirements sufficient for fish-specific food safety traceability? Please explain.
  • What voluntary mechanisms, including use of technology such as distributed ledger technology (that is, Blockchain) or QR codes, have been adopted by industry to maintain traceability information?
  • How ready are you to use technology for traceability?
  • Do you maintain records electronically or do you use other means?
  • Beyond requirements to meet the SFCR, what type of product traceability information is being recorded by your company? For what reason?
  • Do the existing food safety traceability tools provide accurate information throughout the seafood value chain? Are there known gaps or sources of error?
  • What additional information could businesses include in their traceability systems to better align with industry best practices?
  • What additional information could businesses include in their traceability systems to enhance food safety controls?
  • Do you have additional comments to share about food safety traceability?

Theme 2: Sustainability and fisheries management related to traceability and combatting illegal, unreported and unregulated fishing

Key data elements and fisheries management related to traceability

Traceability in the context of this mandate commitment extends beyond the food safety traceability requirements under the SFCR. Some seafood market states have introduced their own catch certification requirements for fish and seafood imports.

In jurisdictions like the EU, enhanced traceability requirements have been introduced for fish and seafood. These requirements include tracking key data elements, such as catch date and location, vessel information, and authority managing the fishery. These key data elements are traced from the point of harvest through the supply chain to the point of entry in the EU. Another example is the United States (U.S.) Seafood Import Monitoring Program (SIMP), established under the U.S. National Oceanic and Atmospheric Administration, SIMP requires industry, as a condition to import, to trace key data elements for 13 specific fish and fish species groups identified as most vulnerable to IUU fishing, seafood fraud, or both.

In some cases, fish products entering a processing facility are harvested by the facility's own fishing vessels. This allows the fish product to be traced directly back to a specific vessel, date, time and fishing area of harvest. In other cases, food businesses such as processors that purchase from several sources are able to trace fish products back to a small group of vessels or a specific fishing area. Both electronic and paper systems are currently used to capture this information.

Many fish and seafood businesses have also adopted in-house or third-party certification approaches to sustainably source products. Some of these use approaches that verify and audit the chain of custody of products.

Sustainable fisheries and international cooperation

Canada works with others in the international community at the United Nations and other international organizations to advance sustainable fisheries and oceans management efforts.

Each jurisdiction manages fisheries in its own waters. In the international waters or when stocks straddle international boundaries or are highly migratory, jurisdictions cooperate to ensure sustainable fisheries management and conservation on a global scale. This is achieved through various mechanisms such as:

Commitments between sovereign jurisdictions are usually achieved through consensus-based decision-making. In fisheries management, flag states of vessels, coastal states, port states, and market states all have roles – and obligations, in promoting sustainable fisheries and ensuring compliance with conservation and management measures.

Illegal, unreported and unregulated fishing

IUU fishing is a major contributor to the decline of fish stocks and marine habitat destruction. Globally, IUU fishing takes many forms both within nationally controlled waters and international waters. It is estimated to account for approximately 30% of all fishing activity worldwide.

According to the United Nations Food and Agriculture Organization (FAO), IUU fishing represents up to 26 million tonnes of fish caught annually, valued at between $10 to $23 billion USD. Illegal fishing is most prevalent where governance measures to manage fisheries or the resources to enforce those measures are the weakest. This means developing countries are the hardest hit by IUU fishing. IUU fishing is also linked to other forms of transnational organized crime including smuggling, drug trafficking, human trafficking and slavery, tax evasion, and fraud.

Monitoring, control and surveillance

Joint monitoring, control, and surveillance (MCS) efforts by national fisheries enforcement agencies in international waters are a primary means to detect and curb IUU fishing. MCS includes surveillance of fishing activities from land, air, and sea, including at-sea inspections of vessels; and, dockside monitoring. Coastal states patrol their own waters, but MCS is more difficult in international waters due to the sheer distances involved.

Technology such as satellite tracking and drone-based surveillance provide information on where IUU fishing tends to take place so enforcement resources can focus on hotspots. MCS can be both expensive and time consuming, especially for developing countries and countries with large ocean areas. Therefore countries have added port state measures to complement at-sea efforts.

Agreement on Port State Measures

The Agreement on Port State Measures (PSMA) was adopted in 2009. The PSMA is the first binding international agreement to specifically target IUU fishing. The agreement requires parties to strengthen and harmonize port controls for foreign-flagged fishing vessels to keep IUU fish out of the world's markets.

The objective of the PSMA is to prevent, deter and eliminate IUU fishing by preventing vessels engaged in these activities from using ports and landing their catches. The PSMA reduces the economic incentive of such vessels to continue operating. It also blocks fish products derived from IUU fishing from reaching national and international markets.

Canada has a strong Port Access Policy, implemented in 2003 through the Coastal Fisheries Protection Act and Regulations. The Policy is based on the concept of a 'closed-port' approach. Using this policy, the Minister of Fisheries and Oceans has the discretion to grant a licence to foreign fishing vessels to enter Canadian waters and ports. However, the vessels are subject to certain limitations set out in the Coastal Fisheries Protection Act and Regulations. The Minister also has an obligation to close ports to vessels flying the flag of any state that has unsatisfactory fisheries relations with Canada. Amendments to the Coastal Fisheries Protection Regulations (2019) enable the Minister to authorize a foreign fishing vessel to enter Canadian fisheries waters for enforcement purposes where the Minister is otherwise precluded from doing so under the Regulations.

Under the Regulations, DFO has the mandate to control port entry and use of port services in respect of any vessel that is:

Fisheries and Oceans Canada's mandate also supports vessels used or equipped for provisioning, servicing, repairing or maintaining foreign fishing vessels at sea. As a responsible member of various regional fisheries management organizations, Canada supports and encourages collaborative efforts to reduce IUU fishing.

Catch documentation schemes

Catch documentation schemes (CDS) are market-related measures implemented at the point of harvest by regional fisheries management organizations for species at higher risk of IUU fishing such as Bluefin tuna. CDS have been developed to combat IUU fishing by making it easier to differentiate legally caught fish from IUU fish based on the presence of a catch document.

CDS systems trace fish from the point of capture to unloading and through the supply chain. A CDS records and certifies where and how a fish was caught, processed and traded. A CDS also ensures fish were harvested in compliance with relevant national, regional and international conservation and management measures.

Discussion points: Sustainability and fisheries management in illegal, unreported and unregulated (IUU) fishing

  • Do you think that having additional information with respect to the sustainability of fishery products would increase consumer confidence?
  • If yes, what information may help to guide consumers in making informed decisions related to the sustainability of fishery products?
  • Do you have concerns that fish imported into or re-exported from Canada may not have been harvested in a sustainable manner? If yes, what are your concerns?
  • Do you have concerns that fish harvested in Canada may not have been reported as part of commercial fishing requirements? If yes, what are your concerns?
  • What do you consider to be the most important elements of sustainable fisheries?
  • What do you feel are the most pressing fisheries sustainability issues hindering Canadian fishers' ability to better market their high-quality products?
  • What sustainability-related market access issues do you feel the boat-to-plate program should address?
  • Should the boat (starting point) to plate (end point) program be domestically-oriented, internationally-focused or both? Please explain.
  • What additional measures should be taken to improve transparency in the national and international fish and seafood industry and its extensive and complex supply chains?
  • How effective do you feel voluntary or industry driven traceability measures are at documenting details about the source and harvesting of fish and seafood?
    • Very effective
    • Somewhat effective
    • Effective
    • Not very effective
    • Not at all effective
  • Is demand increasing for food businesses to share information on harvesting or farming from one point in the food supply chain to the next?
  • Are these demands being met through existing business practices? If no, please explain.
  • Do you have additional comments to share about sustainability and fisheries management?

Theme 3: Market access, trade, and marketing of Canadian fish and seafood

The Minister of Health's mandate letter links a boat-to-plate traceability program to Canadian fishers' ability to market their products. As such, market access, trade, and marketing have been identified as themes of the mandate commitment.

Canada has a reputation for high quality, safe and sustainable seafood. Traceability can be an effective tool to facilitate branding of Canadian fish and seafood and communicating the qualities that Canada is known for domestically and internationally.

Export market access

Many countries have enhanced traceability requirements for fish and seafood to combat IUU fishing and seafood fraud, and enable faster, more efficient recalls to mitigate or prevent foodborne illness outbreaks. These regulations apply to their domestic industry, and to imported fish and seafood.

The fish and seafood sector in Canada is highly export oriented. Euromonitor International reported that in 2017, 85% of Canadian caught fish and seafood were exported. According to Canada's fish and seafood trade in 2019: overview− PDF (1.36 mb), the top export destinations for Canadian fish and seafood in rank order of value were U.S. China, Japan, and EU. To export fish and seafood, exporters must meet foreign country requirements, including traceability and certification requirements.

To combat IUU fishing, and to address other sustainability concerns, some countries have implemented import controls. These are summarized below. The controls highlight the types of requirements domestic fisheries must adhere to when exporting to foreign markets.

The EU introduced its catch certification scheme in 2010, covering all marine wild caught fish imported into the EU market. Detailed traceability information must be recorded electronically throughout the supply chain, including catch and production information.

Similar to the EU catch certification scheme, traceability requirements are also in place for fish and seafood exports to Ukraine, Chile and the United Kingdom. Several other countries, including Japan, Thailand, Indonesia and Serbia are at various stages of implementing similar systems to control and prevent products of IUU fishing from entering their markets.

The U.S. introduced the Seafood Import Monitoring Program in 2018. It covers 13 fish and fish species groups (over 1100 unique species) identified as the most vulnerable to IUU fishing, seafood fraud, or both. This industry-to-industry-based program applies only to imports into the U.S. and requires traceability of certain key data elements, including catch area, catch method, processing weight and species name.

Additionally, the U.S. National Oceanic and Atmospheric Administration has put into effect provisions and restrictions governing the import of foreign fish and seafood products in accordance to the U.S. Marine Mammal Protection Act (MMPA). The import provisions in the Act ban importing fish or fish products harvested in wild capture or aquaculture fisheries that have been caught using fishing techniques that result in the incidental kill or serious injury of marine mammals, in excess of U.S. standards. Associated with these import restrictions is a requirement for foreign fisheries exporting fish and fish products to the U.S. to have comparable standards to minimize marine mammal injury or mortality. Countries must receive a comparability finding from the U.S. to this effect for each of their export fisheries by November 30, 2022 to continue to export to the U.S.

The U.S. Food and Drug Administration also recently consulted on a Proposed Rule for Food Traceability. The proposed rule aims to establish further traceability recordkeeping requirements for persons who manufacture, process, pack, or hold higher- risk foods including finfish, crustaceans, mollusks, and bivalves. These proposed requirements are founded in food safety. They would allow the Food and Drug Administration to identify recipients of food faster and more effectively, to prevent or mitigate foodborne illness outbreaks.

The rule would apply to Canadian businesses export to the U.S. It would require them to maintain records containing key data elements associated with different critical tracking events back to the first receiver of the food. That is the first person, other than the fishing vessel, who purchases and takes physical possession of the food.

China currently requires some traceability information to be added to the export certificates for fish and seafood destined for human consumption.

Imports

Almost 80% of fish products sold in Canada are importedFootnote 4, mainly from the U.S. ($1.4 billion) and China ($628 million)Footnote 5. Imports from the U.S. consist mainly of lobster, salmon and crab. Imports from China consist primarily of shrimp/prawns, haddock and squid. In recent years, Canada has seen a steady increase in the amount of imported fish products.

Fish and seafood products that are imported into Canada must be safe to consume and must meet all applicable Canadian requirements. This means that any imported seafood must be prepared with the same level of food safety controls as food prepared in Canada. It must also comply with all applicable Canadian labelling and compositional requirements.

CFIA's National Aquatic Animal Health Program regulates the import of all 'defined' aquatic animals into Canada to prevent the introduction of serious aquatic animal diseases. Import permits, export certificates and other documentation are required for specific species considered susceptible to diseases of concern.

The Health of Animals Regulations require that every aquatic animal entering Canada, regardless of whether its end use is food or not, must be declared using its scientific (taxonomic) name to avoid misdeclaring a susceptible species that could introduce disease.

Marketing

The Minister of Health's mandate letter talks about marketing the products of Canadian fisheries. In Canada, this relates, in part, to the information provided to consumers so they can identify Canadian or foreign sourced fish and seafood products when making purchasing decisions.

One way to do this is to provide this information on labels. CFIA provides guidance on the use of voluntary claims such as "Product of Canada" or "Made in Canada from domestic and imported ingredients." More specific statements or claims may also be used by industry, as long as they are truthful and not misleading. The use of these claims may differ for fish and seafood products destined for export and may be dependent on the requirements of the importing country.

Additionally, the Canada Brand Program includes branding and graphics that Canadian businesses can use in their domestic and international marketing efforts to help differentiate their food products from the competition.

Discussion points: Market access, trade and marketing of Canadian fish and seafood

  • How often do you consume seafood?
    • A few times every week
    • Once a month
    • Every few months
    • Never
    • Don't know/Not applicable
  • When buying fish and seafood, do you actively seek out Canadian products?
  • How do you identify Canadian products?
  • What current or potential future traceability requirements of other countries affect your ability to import and export? Please provide examples of any related benefits or challenges you may have experienced.
  • What traceability-related gaps exist within Canada that do not support market access?
  • In your experience, have current Canadian traceability requirements resulted in any limitations on your ability to trade? If so, how? Do you foresee any changes that Canada should prepare for?
  • Information about taxonomic serial number is required on import documentation for many imported fish and seafood species. How does your business relay this documentation (or the information in them) through the food supply chain?
  • Do you have any comments on measures that would support the marketing of Canadian products, either domestically or abroad?
  • Are you certified by any of the following:
    • Marine Stewardship Council (MSC)
    • Aquaculture Stewardship Council (ASC)
    • Global Seafood Alliance (GSA)
    • Other, please specify
  • How actively do you promote Canadian content in the sale of fish and seafood products? Why or why not?
  • Do you see opportunities for the market to fulfill consumer interests in sustainable fishing by linking this demand to domestic fish and seafood harvested under Fisheries and Oceans Canada (DFO) oversight? If so, what role do you see your organization playing?
  • As a producer, have you been asked to supply information regarding protection of marine mammals, in particular North Atlantic right whales, in relation to the species you were processing and selling? Were existing measures sufficient to differentiate your product source from those having interactions with marine mammals?
  • Do you have additional comments to share about market access and marketing?
  • Do you have additional comments to share on the subject of boat-to-plate traceability?
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