Notice to industry: Changes to import requirements for pet supplements

2024-04-16

The Canadian Food Inspection Agency (CFIA) is modernizing and simplifying import requirements for pet supplements made of animal products and by-products. This is advance notice of changes to import requirements that will be published on June 24, 2024.

1. Simplified categorization of pet supplements

The current categories for pet supplements in the Automated Import Reference System (AIRS) do not accurately reflect the variety of options available in the market. On June 24, 2024, the CFIA will update AIRS to include only 3 categories:

• pet supplements with no animal origin ingredients
• pet supplements containing only highly processed animal origin ingredients
• pet supplements containing animal origin ingredients that are not highly processed

Highly processed animal origin ingredients

• Albumin
• Bee-derived products
• Chondroitin sulphate
• Collagen
• Dicalcium phosphate
• Egg and egg products
• Fish oils
• Gelatin and gelatin capsules
• Green lipped mussel powder
• Marine materials that are not rendered (other than fish oil and green lipped mussel powder)
• Milk and milk products
• Tallow
• Vitamin A
• Vitamin D3 from lanolin

Non-highly processed animal origin ingredients

• Meat
• Organs
• Offal
• Bone or meat meal
• Bone broth
• Spray dried plasma or other blood derivatives, including blood meal
• Products of a rendering plant (other than fish oil and green lipped mussel powder)

Pet supplements with no animal origin ingredients will be allowed from any country, with a copy of the label or manufacturer's ingredient list. Pet supplements with animal origin ingredients must be accompanied by a zoosanitary certificate (see appendices 1 and 2 below). AIRS will be updated to specify whether pet supplements will be accepted or refused from each country, making it easier for importers to find the information they want.

2. Zoosanitary certification

The zoosanitary certificates for pet supplements with animal origin ingredients will allow the official veterinarian of the exporting country to cross out ingredients that are not included in the shipment being certified. Also, different types of supplements in the same shipment will be able to be certified using the same zoosanitary certificate, as long as they are all in the same category of highly processed or non-highly processed.

3. Pet supplements made in the United States of America (USA)

For pet supplements made in the USA only (not for products made in other countries and transshipped through, or repackaged in the USA), the CFIA will require the same zoosanitary certificate currently used for thermally treated pet food (see appendix 3 below). The exporting facilities in the USA should discuss with their United States Department of Agriculture Animal Plant Health Inspection Service (USDA-APHIS) veterinarian how often facility inspections are required and what is needed for them to sign a zoosanitary certificate. If an American facility is unsure how to proceed with approval to export to Canada, they should contact their local Veterinary Services (VS) Field Office.

Appendix 1 – Zoosanitary statements for pet supplements, minerals, and vitamins, including only highly processed ingredients of animal origin

Each shipment must be accompanied by a zoosanitary export certificate endorsed by an official veterinarian of the country of origin attesting to the following conditions.

1. The finished processed pet supplements as described in the veterinary export certificate have been prepared and stored in a plant approved and supervised by the competent veterinary authority
2. The supplement does not contain any of the following ingredients : meat, organs, offal, bone or meat meal, bone broth, spray dried plasma or other blood derivatives (including blood meal), or products of a rendering plant (other than fish oil and green lipped mussel powder)
3. The exported product contains the following animal origin ingredients (for point 3, delete as appropriate):
   1. Gelatin and/or collagen derived from the following species: porcine, piscine, equine, ovine, or caprine
   2. Bovine derived gelatin and/or collagen
      1. b1. Is derived from hides/skins
         and/or
      2. b2. Is derived from bones of bovines originating in region(s) recognized by World Organisation for Animal Health (WOAH) as negligible risk for bovine spongiform encephalopathy (BSE)
         and/or
      3. b3. Is derived from bones of bovines originating in region(s) recognized by WOAH as controlled risk for BSE
         and
         1. b3a) The bones were derived from bovines that passed ante and post mortem inspection
         2. b3b) The bones did not include the skulls of bovines or the vertebral column of bovines 30 months of age or older
   3. Egg phospholipid or egg lecithin, spray-dried egg, or other egg ingredients
      1. c1. The egg ingredients originate from a country or zone recognized by Canada as free of Highly Pathogenic Avian Influenza and Virulent Newcastle Disease
         or
      2. c2. The egg ingredients have been processed in a manner sufficient to inactivate highly pathogenic avian influenza and virulent Newcastle disease viruses in accordance with the recommendations of the WOAH Terrestrial Animal Health Code

   4. Marine-origin material of finfish, mollusc and crustacean, including fish/krill oils, green lipped mussel, freeze dried shellfish, and dehydrated fish. Only fish oils and green lipped mussel powder are acceptable products of a rendering plant. If used as an ingredient, powder made from green lipped mussel has a moisture content of <10%.

   5. Lactose or lactose derivatives
   6. Other milk or milk products
      1. f1. The milk ingredient was produced in __________ [name of country or region], a country or region recognized by Canada as free of foot-and-mouth disease (FMD)
         The milk/milk product has never been in any country or region which Canada does not recognize as free of FMD, except when moving under seal.
         or
      2. f2. The milk ingredient was produced in __________ [name of country or region], a country or region not recognized by Canada as free of foot-and-mouth disease (FMD)
         It has been subjected to the following treatments:
         1. pasteurization: minimum of 72 degrees Celsius for at least 15 seconds, or
         2. ultra-High temperature (UHT): minimum of 140 degrees Celsius for at least 5 seconds, or
         3. low final pH (less than 6) for a period of 1 hour, and
         4. followed by a second treatment from the above, and
         5. every precaution was taken to prevent contamination of the product after completion of the processing with anything of a lesser status
   7. Vitamin D3 derived from sheep wool grease / lanolin
   8. Vitamin A coated with porcine gelatin
   9. Beeswax, royal jelly, or other bee-derived material
   10. Bovine dicalcium phosphate
       1. j1. The dicalcium phosphate contains no trace of protein or fat
          or
       2. j2. The dicalcium phosphate originates from a region recognized by WOAH as negligible risk for BSE (__________) (name of the region)
          or
       3. j3. The dicalcium phosphate originates from a region recognized by WOAH as controlled risk for BSE (__________) (name of the region), is derived from bovines that have passed ante-mortem and post-mortem inspections, and does not contain Specified Risk Material (SRM)^Footnote *
   11. Bovine tallow and/or tallow derivatives
       1. k1. Contains a maximum level of insoluble impurities of 0.15% by weight
          or
       2. k2. Contains greater than 0.15% insoluble impurities by weight and originates from a region recognized by WOAH as negligible risk for BSE
          or
       3. k3. Contains greater than 0.15% insoluble impurities by weight and originates from a region of controlled risk for BSE, is derived from bovines that have passed ante-mortem and postmortem inspections, and has not been prepared using Specified Risk Material (SRM)^Footnote *
4. Every precaution was taken to prevent cross-contamination of the finished product with any animal origin product or by-product derived from animals of a lesser zoosanitary status
5. The supplements have been packaged in new packaging that clearly indicates their intended use

Appendix 2 – Zoosanitary statements for pet supplements, minerals, and vitamins, including non-highly processed ingredients of animal origin such as meat, meals, and blood derivatives

Each shipment must be accompanied by a zoosanitary export certificate endorsed by an official veterinarian of the country of origin attesting to the following conditions:

1. The finished processed pet supplements as described in the veterinary export certificate have been prepared and stored in a plant approved and supervised by the competent veterinary authority
2. The exported product contains the following animal origin ingredients (for point 2, delete as appropriate):
   1. Gelatin and/or collagen derived from the following species: porcine, piscine, equine, ovine, or caprine
   2. Bovine derived gelatin and/or collagen
      1. b1. Is derived from hides/skins
         and/or
      2. b2. Is derived from bones of bovines originating in region(s) recognized by WOAH as negligible risk for BSE
         and/or
      3. b3. Is derived from bones of bovines originating in region(s) recognized by WOAH as controlled risk for BSE
         and
         1. b3a) The bones were derived from bovines that passed ante and post mortem inspection
         2. b3b) The bones did not include the skulls of bovines or the vertebral column of bovines 30 months of age or older
   3. Egg phospholipid or egg lecithin, spray-dried egg, or other egg ingredients
      1. c1. The egg ingredients originate from a country or zone recognized by Canada as free of Highly Pathogenic Avian Influenza and Virulent Newcastle Disease
         or
      2. c2. The egg ingredients have been processed in a manner sufficient to inactivate highly pathogenic avian influenza and virulent Newcastle disease viruses in accordance with the recommendations of the WOAH Terrestrial Animal Health Code

   4. Marine-origin material of finfish, mollusc and crustacean, including fish/krill oils, green lipped mussel, freeze dried shellfish, and dehydrated fish. Only fish oils and green lipped mussel powder are acceptable products of a rendering plant. If used as an ingredient, powder made from green lipped mussel has a moisture content of <10%.

   5. Lactose or lactose derivatives
   6. Other milk or milk products
      1. f1.The milk ingredient was produced in __________ [name of country or region], a country or region recognized by Canada as free of foot-and-mouth disease (FMD)
         The milk/milk product has never been in any country or region which Canada does not recognize as free of FMD, except when moving under seal.
         or
      2. f2. The milk ingredient was produced in __________ [name of country or region], a country or region not recognized by Canada as free of foot-and-mouth disease (FMD)
         It has been subjected to the following treatments:
         1. pasteurization: minimum of 72 degrees Celsius for at least 15 seconds, or
         2. ultra-High temperature (UHT): minimum of 140 degrees Celsius for at least 5 seconds, or
         3. low final pH (less than 6) for a period of 1 hour, and
         4. followed by a second treatment from the above, and
         5. every precaution was taken to prevent contamination of the product after completion of the processing with anything of a lesser status
   7. Vitamin D3 derived from sheep wool grease / lanolin
   8. Vitamin A coated with porcine gelatin
   9. Beeswax, royal jelly, or other bee-derived material
   10. Bovine dicalcium phosphate
       1. j1. The dicalcium phosphate contains no trace of protein or fat
          or
       2. j2. The dicalcium phosphate originates from a region recognized by WOAH as negligible risk for BSE (__________) (name of the region)
          or
       3. j3. The dicalcium phosphate originates from a region recognized by WOAH as controlled risk for BSE (__________) (name of the region), is derived from bovines that have passed ante-mortem and post-mortem inspections, and does not contain SRMs^Footnote *
   11. Bovine tallow and/or tallow derivatives
       1. k1. Contains a maximum level of insoluble impurities of 0.15% by weight
          or
       2. k2. Contains greater than 0.15% insoluble impurities by weight and originates from a region recognized by WOAH as negligible risk for BSE
          or
       3. k3. Contains greater than 0.15% insoluble impurities by weight and originates from a region of controlled risk for BSE, is derived from bovines that have passed ante-mortem and postmortem inspections, and has not been prepared using Specified Risk Material (SRM^Footnote *)
   12. Spray dried plasma of porcine origin
       1. l1. The plasma originates from a country or zone recognized by Canada as free from African Swine Fever, Classical Swine Fever, Foot-and-Mouth Disease, and Swine Vesicular Disease
          and
       2. l2. The plasma originates from animals that passed ante-mortem and post-mortem inspection
          and
       3. l3. The plasma was heat treated to at least 80º Celsius throughout its substance
   13. Blood meal of bovine and/or porcine origin
       1. m1. The blood meal originates from animals that passed ante-mortem and post-mortem inspection, was collected at [name and slaughter establishment number or numbers] and processed at __________ [name and address of processing plant].
          and/or
       2. m2. If bovine,
          1. m2a. The animals from which the blood was derived were killed using a non-penetrative method, in accordance with humane slaughter practices, or
          2. m2b. Were exclusively under 30 months of age at the time of slaughter, or
          3. m2c. Using a system whereby each head is trimmed, washed, or scraped to remove grossly visible brain material and the stun hole is plugged with edible grease to prevent neural leakage.
             and
       3. m3. The blood meal has been subjected to a heat treatment of at least 80º Celsius for 30 minutes
   14. Organ and offal meat
       1. n1. The meat originates from animals that passed ante mortem and post mortem inspection
          and
       2. n2. The meat has been subjected to a heat treatment of at least 70 º Celsius for 30 minutes
          or
       3. n3. Meat ingredients have been processed in a manner sufficient to inactivate all diseases of concern to Canada^Footnote ** to which the donor animal(s) is susceptible, in accordance with the recommendations of the WOAH Terrestrial Animal Health Code
          or
       4. n4. Unprocessed (non heat treated) meat ingredients originate from animals that were raised, slaughtered, and processed in a country or zone recognized by Canada as free from all diseases of concern^Footnote ** to which the donor animal(s) is susceptible
   15. Bone meal and bone broth of avian origin
       1. o1.Is derived from birds that passed ante mortem and post mortem inspection
          and
       2. o2.Originates from and was processed in a country or zone recognized by Canada as free of Highly Pathogenic Avian Influenza and Virulent Newcastle Disease
          or
       3. o3. Has been processed in a manner sufficient to inactivate highly pathogenic avian influenza and virulent Newcastle disease viruses in accordance with the recommendations of the WOAH Terrestrial Animal Health Code
   16. Meat and bone meal, bone meal, bone broth, and other rendered ingredients of ruminant origin were legally imported from only Australia and/or New Zealand
3. Every precaution was taken to prevent cross-contamination of the finished product with any animal origin product or by-product derived from animals of a lesser zoosanitary status
4. The supplements have been packaged in new packaging that clearly indicates their intended use
5. Animal origin ingredients have been processed in a manner sufficient to inactivate all diseases of concern to Canada^Footnote ** to which the donor animal(s) is susceptible, in accordance with the recommendations of the WOAH Terrestrial Animal Health Code

Appendix 3 – Zoosanitary statements and import conditions for pet supplements containing any ingredients of animal origin, made in the USA

Conditions of import

Each shipment of pet supplements from the USA must be accompanied by a zoosanitary export certificate endorsed by a USDA-APHIS veterinarian, attesting to Canada's import conditions. There is a single-shipment certificate which may only be used for 1 shipment, as well as a multiple shipment certificate which can be used for multiple shipments from the same exporting facility over a 30 day period. The multiple shipment certificate is valid for the shipment to cross the USA/Canada border for 30 calendar days after endorsement by the official USDA-APHIS veterinarian.

Each shipment imported into Canada with a USA Multiple Shipment Export Certificates must be accompanied by an Importer's Statement of Compliance, containing the shipment specific information.

Zoosanitary certification

Each shipment of processed pet food or treats manufactured in the USA or Canada and exported from the USA to Canada must be accompanied by a zoosanitary certificate issued by an official veterinarian of the USDA and attesting to the following:

I, the undersigned Official Veterinarian of the Animal and Plant Health Inspection Service (APHIS), after due inquiry and to the best of my knowledge and belief, do hereby certify:

1. The certified pet food and/or pet treats were processed in a facility or facilities located in the USA or Canada and authorized by the official competent veterinary authority in the country of origin to manufacture pet food containing animal products and by-products.
2. The certified pet foods and/or pet treats in the shipment may include the following (check all that apply):
   • Pet foods and/or pet treats with no bovine-origin ingredients except exempt ingredients (that is, milk or milk products, hide-derived gelatin or collagen, and tallow with a maximum level of insoluble impurities of 0.15% by weight).
   • Pet foods and/or pet treats with non-exempt bovine-origin ingredients.
3. In the case of pet foods or pet treats containing tallow, the tallow used is protein-free with a maximum level of insoluble impurities of 0.15% by weight.
4. In the case of pet foods or pet treats containing bovine meat, offal, or any bovine ingredients other than exempt ingredients, they meet the following requirements:
   1. Bovine-origin raw materials (meat/offals):
      1. were harvested in the United States from U.S.-origin cattle or legally imported cattle that:
         • Were not subjected to a stunning process prior to slaughter, with a device injecting compressed air or gas into the cranial cavity, or to a pithing process, and were humanely rendered unconscious prior to being bled
         • Do not contain and have not been contaminated with bovine specified risk materials (SRMs)
           and/or:
      2. Were legally imported from a country or countries recognized by the CFIA to be of:
         • Negligible BSE Risk Status
           or
         • Controlled BSE Risk Status (insert name of country or countries)

         For raw material imported from controlled risk countries, they were derived from animals that were not subjected to a stunning process prior to slaughter, with a device injecting compressed air or gas into the cranial cavity, or to a pithing process, and were humanely rendered unconscious prior to being bled

         and

         They do not contain and have not been contaminated with bovine specified risk materials (SRMs)

   2. All bovine-origin rendered protein materials originate only from countries of Negligible BSE Risk Status.
5. The certified animal origin ingredients in the pet foods, pet treats and/or compound chews or the finished products were sufficiently thermally processed to ensure the destruction of pathogens that represent a risk to public or animal health.
6. Precautions were taken to prevent cross-contamination of the finished products with any animal origin product or by-product derived from animals of a lesser zoosanitary status.