Fact sheet - Traceability

The proposed Feeds Regulations, 2022 will impact a variety of stakeholders, including:

• single ingredient feed manufacturers and suppliers
• mixed feed manufacturers and suppliers (for example, commercial feed mills, specialty feed manufacturers, etc.)
• rendering facilities manufacturing livestock feed ingredients
• feed retail outlets
• livestock producers (on-farm feed mills)
• feed importers
• feed exporters

Under the proposed Feeds Regulations, 2022, most feed establishments will be required to keep documents related to traceability and maintain records related to the feeds they manufacture.

This fact sheet applies to you if you conduct any of the following feed-related activities:

• manufacturing
• storing
• packaging
• labelling
• selling
• importing
• exporting

Traceability

Traceability is the ability to track the movement of single ingredient feeds and mixed feeds, one step back and one step forward. This is a new regulatory requirement.

You must prepare, keep and maintain traceability documents related to feed that you provide to another person.

If you provide a single ingredient feed to another person, the following information must be included in the traceability documents:

• Name of the single ingredient feed
• Lot number (sometimes referred to as identification code or unique identifier) of the single ingredient feed
• Name and address of the person who manufactured the single ingredient feed or caused it to be manufactured
• Name and address of the person who provided the single ingredient feed to you, and the date which it was provided (if applicable)
• Name and address of the person who received the single ingredient feed from you, and the date which it was provided

If you provide a mixed feed to another person, the following information must be included in the traceability documents:

• Name of the mixed feed
• Lot number (sometimes referred to as identification code or unique identifier) of the mixed feed
• Name and address of the person who manufactured the mixed feed or caused it to be manufactured
• Name of any single ingredient feed, any medicating ingredient referred to in the Compendium of Medicating Ingredient Brochures, any pest control product, any non-feed product referred to in the Compendium of Non-Feed Product Brochures, or any other feed (for example, a premix) used to make the final mixed feed; the name and address of the person who provided it to you, and the date on which you received it
• Name and address of the person who provided the mixed feed to you, and the date which it was provided (if applicable)
• Name and address of the person who received the mixed feed from you, and the date which it was provided

The requirement to keep distribution records (who you provided feed to) applies to both the transfer of feeds between commercial feed businesses and retail sales. End users of feeds (farmers) would not be required by the proposed Feeds Regulations, 2022 to keep records of who they received their feed from. However, farmers may be required to keep certain records under the Health of Animals Act and regulations.

The lot number is one of the key pieces of information required to ensure traceability of feed. Manufacturers are responsible for determining what they consider to be a lot for their products. Lot numbers are already required on some livestock feeds and on all feeds considered animal food under the Health of Animals Regulations. For bulk animal food, a "lot" is a single batch or multiple batches that make up an order, and must be identified by a lot number. For bulk animal food ingredients such as meat and bone meal, the usual approach is that a day's production is one lot. However the manufacturer may decide an appropriate lot size for their business practices. If a problem is found with a feed, the entire lot may be subject to enforcement actions.

Prescribed documents to support traceability must be kept for at least 3 years, be accessible in Canada, and be provided to the CFIA upon request.

Additional records

Under the proposed Feeds Regulations, 2022, additional record-keeping requirements related to the manufacture of feeds are outlined and are dependent on the types of feeds being manufactured. These are updates to the current regulatory requirements.

Single ingredient feed

If a feed establishment manufactures a single ingredient feed, documents must be kept that include the name of the feed, lot number, date of manufacture, quantity manufactured and a copy of any mix formula.

Mixed feed

If a feed establishment manufactures a mixed feed, copies of the mix sheet and mix formula must be kept. Copies of the customer formula or veterinary prescription are also required for feed establishments that manufacture a customer formula feed or custom medicated feed.

These records must be kept for at least 3 years from the last date of manufacture of the feed, be accessible in Canada, and be provided to the CFIA upon request.

Request for documents

Records may be requested and reviewed during routine inspection activities. In addition, if there is an event where there is reasonable grounds to believe there is a risk of harm to human or animal health or the environment, traceability related documents may be requested from anyone required to keep them. These documents generally must be provided within 24 hours unless additional time is granted. This ensures information is provided in a timely manner when responding to feed recalls and feed safety investigations.

Please note that this fact sheet does not outline all record-keeping requirements being proposed under the new Feeds Regulations, 2022. Other record-keeping requirements (for example, record-keeping requirements for preventive control plans), will be discussed in other guidance documents.

Benefits of traceability

While many feed establishments in Canada already have traceability records in place, others may not. The new traceability and updated record-keeping requirements provide more detailed information to better support risk management approaches along the feed and food supply chain, especially where timely responses to feed safety investigations, or feed recalls, are needed to address risks to animal health, human health or the environment.

If you can trace the source of each single ingredient feed or mixed feed supplied to you (one step back) and its next destination (one step forward), you can access timely and precise information as needed. This can significantly reduce the time it takes to remove unsafe feed from the Canadian marketplace. An effective traceability and record-keeping system protects the Canadian feed industry and increases confidence in Canada's feed safety system.