What we heard report – Consultation on proposed changes to Part XV of the Health of Animals Regulations (Identification and Traceability), Canada Gazette Part I

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The Canadian Food Inspection Agency (CFIA) undertook an online consultation in Canada Gazette, Part I (CGI) from March 18, 2023 to June 16, 2023, on the proposed amendments to Part XV of the Health of Animals Regulations (Identification and Traceability).

The goal of updating the Health of Animals Regulations (Identification and Traceability) is to help governments and stakeholders efficiently and effectively prepare and respond to animal diseases, food safety issues and natural disasters. The amendments to the regulations would benefit the Canadian livestock sector, which includes livestock producers, operators of intermediate sites, abattoirs, importers, exporters, and governments. As well as the objective of mitigating the risks and impact from disease outbreaks and protecting Canada's food supply and animal resource base, the enhancement of the regulations would also strengthen the ability for Canadian livestock businesses to access and maintain international markets.

Over the last decade, industry and government representatives have been working together extensively on the livestock traceability file. Multiple rounds of consultations with stakeholders have been conducted to discuss and obtain feedback on possible options to improve Canada's livestock traceability system. Feedback received set the foundation for proposed regulatory changes, which would:

  1. add goats and farmed cervids (such as deer and elk) to the national traceability requirements

    This would address the issue that species that share diseases are not all subject to traceability requirements, putting all species that share diseases at risk.

  2. modify existing traceability requirements to improve on identification and traceability requirements that are currently insufficient in preventing and responding efficiently to a disease outbreak

    Modifications include:

    • introducing movement reporting requirements for all regulated species
    • amending the time to report requirements from 30 to 60 days to 7 days for all species
    • introducing the requirement to report the provincially assigned premises ID number
    • various changes to requirements related to the use of animal indicators
  3. increase agility and efficiency in the regulations and across the system by:
    • modernizing the definition of animal indicators to make it technology neutral
    • incorporating by reference the list of approved indicators

Most recently, the CFIA undertook an online consultation on the proposed regulatory changes, to:

  • gather feedback and confirm ongoing support from stakeholders on the proposed regulatory changes to livestock identification and traceability
  • determine potential effects on business decisions and activities, industry, market access and consumer confidence

This report summarizes the comments received via Canada Gazette, Part I, Volume 157, Number 11: Regulations Amending the Health of Animals Regulations (Identification and Traceability) and the CFIA's clarifications to some of the comments. The participants' views expressed in this report do not reflect those of the CFIA or the Government of Canada.

The CFIA would like to thank everyone who participated in the consultation process for contributing their time and sharing their views.

Consultation overview

  • the 90-day comment period ran from March 18 to June 16, 2023
  • the CFIA consulted on the draft regulatory text and the proposed incorporation by reference (IBR) documents
  • the CFIA published guidance documents on its website to support the CGI consultation
  • during the consultation period, the CFIA held sector specific webinars in both official languages to help stakeholders understand the content and impacts of the proposed regulatory changes
  • over 700 participants attended these online sessions
  • the CFIA notified its international partners about this consultation through the World Trade Organization (WTO) notification process and will respond to any comments through the WTO process
  • stakeholder comments were mainly received via the Canada Gazette's online commenting feature – these comments have been published in the Canada Gazette, Part I, Volume 157, Number 11: Regulations Amending the Health of Animals Regulations (Identification and Traceability)
  • some additional comments were not published as they were submitted via email (without the appropriate permission to publish) or from government partners, however all have been considered in this report

Who we heard from

The CFIA received 1299 comments from 778 submitters expressing support, outlining concerns, requesting clarifications and proposing changes to the regulatory text during the consultation comment period from:

  • national, provincial and municipal associations representing livestock producers and operators of livestock sites
  • businesses
  • private individuals
  • importers and exporters of livestock
  • veterinarians
  • livestock transporters
  • indigenous organizations
  • federal, provincial, and municipal governments

What we heard

All submissions were reviewed and feedback was grouped into main themes when possible. In general, feedback was supportive of the traceability program and its objectives, with many respondents indicating that they were pleased to see the proposed regulations published for consultation.

Stakeholders provided constructive feedback on specific sections where the proposed requirements may present undue burden, be out of alignment with current practices, or do not provide enough flexibility. Industry stakeholders also noted that they anticipate an increase in resources to adhere to the  new movement reporting requirements, reading indicators, and in some cases the manual input of data. Some stakeholder groups felt the regulatory changes could go even further and  include additional requirements to ensure an even stronger traceability system.

The comments received also indicated that some stakeholders did not fully understand some of the proposed requirements, and in some cases, specifically requested additional guidance and education before the regulatory changes are implemented. An appendix has been added to this document to expand on some areas where further clarification is needed.

Elements well supported

The following elements were well supported by stakeholders:

  • the update of the Health of Animals Regulations (Identification and Traceability): stakeholders expressed general support for the livestock traceability program, the regulatory amendment, and its overall objectives
  • introduction of new regulated species: the majority of stakeholders were supportive of including new species, specifically goats and cervids in the proposed regulations
  • introduction of documents incorporated by reference (IBR): stakeholders supported the introduction of IBR documents for approved indicators as they allow flexibility for their adoption
  • modernizing the definition of animal indicators: stakeholders were pleased with replacing the word "tag" with "approved indicator" making the proposed regulations more technology neutral
  • adding premises identification numbers, also known as PID numbers, as a traceability reporting requirements: majority of stakeholders support the incorporation of premises identification with some reservations about the readiness of the provincial programs
  • the repeal of the record keeping requirements: most stakeholders supported the repeal, however some commented that the reduction of burden associated with the repeal of record keeping requirements was overestimated

Elements not well supported

The following elements were not well supported and resulted in stakeholders requesting that certain regulatory provisions be removed or modified:

  • restricting approved identification sites to assembly points only: stakeholders expressed concerns that veterinary clinics and feedlots would no longer be eligible to be approved identification sites
  • the requirement to report "time" and "licence plate" for livestock movements: stakeholders questioned the usefulness of reporting this information and expressed  concerns with the administrative burden it would create
  • new requirements for fairs and exhibitions to report movements of livestock and the existing requirement to apply approved indicators to unidentified livestock: stakeholders expressed significant concerns with these requirements, noting that most smaller agriculture fairs do not have the resources to comply
  • the removal of slap tattoo identification for the movement of market hogs to slaughter by way of an assembly point: stakeholders expressed a number of significant concerns on the impact of removing this option as much of the hog industry relies on this specific provision to operate efficiently
  • the requirement to report the departure of pig carcasses: stakeholders expressed numerous concerns with the feasibility of reporting the departure of pig carcasses from their site
  • the requirement for the operator of the destination site to report the date and time of departure of pigs: stakeholders requested that the operator of the destination site not be required to report this information since the pig industry has double  movement reporting
  • the prohibition of unauthorized selling or distribution of approved indicators: some stakeholders expressed concerns with limiting the practice of sharing/transferring approved indicators to other regulated parties

Elements with mixed reactions

The following elements in the proposed regulations received mixed reaction. In some cases there were stakeholders who supported the change while others did not. In other cases stakeholders supported part of the proposed provision but not the whole provision.

  • the allowable time to report an event or movement: some stakeholders were supportive of 7 days as the allowable time to report, while others requested it be extended. A few stakeholders felt the time to report should be shorter
  • group movement reporting for operators of assembly points: stakeholders impacted by this requirement were supportive, but some stakeholders expressed concerns with the gaps in traceability data it would cause
  • group movement reporting for operators of departure sites sending livestock to community pastures: some stakeholders supported group movement reporting, while others felt that individual identification numbers should be reported for movements to community pastures as livestock from more than 1 farm are commingled
  • the responsibility for veterinary clinics to report move-in of livestock: some stakeholders agree with the move-in model for veterinary clinics, while others were concerned with the burden this would cause and suggested that the owners of the livestock should bear the  responsibility for reporting movement of livestock
  • allowing the import of livestock for immediate slaughter without approved indicators: the majority of stakeholders did not comment on allowing the import of unidentified livestock into Canada for slaughter as it is a current regulatory exemption. However, some stakeholder associations expressed concerns with the risks this exemption creates with respect to disease control
  • the incorporation of the passive reading principle for reporting approved indicators: some stakeholders were supportive of the flexibility of the passive reading principle, while others  were concerned this would significantly compromise the goals of the traceability program
  • the requirement to individually identify young dairy goats that will be raised for meat: some stakeholders were concerned with the burden of this requirement due to the market value of these animals, while others support the individual identification of all goats
  • the 1-year transition period after publication for producers/owners of livestock: some stakeholders agree the transition period would provide sufficient time to adjust their current business operations, while others felt that it should be extended

Elements that require clarification or adjustments to the regulatory text

The following elements resulted in questions from stakeholders. They were either seeking clarification on specific  requirements or indicated a need for additional guidance. In some cases, stakeholders indicated a need for adjustments to the regulatory text to provide clarity and support regulatory compliance.

  • clarification of the intent in the wording "care or control" of livestock in the regulatory text
  • clarification of the definition of "community pasture"
  • requests for the wording be refined in the regulatory text regarding movement reporting to leased pastures
  • requests for more flexibility regarding the definition of dangerous animals that are allowed to be moved to an approved identification site
  • requests for movement reporting between the same farm or to leased pastures when a certain distance is reached
  • questions about which sites are allowed to be an approved identification site and who is responsible for the approval of these sites
  • requests for clarification on the requirement to provide your premises identification number when purchasing approved indicators when your operation has several premises identification numbers
  • concerns with the logistics of obtaining inspector approval before the removal of an approved indicator
  • clarification on what types of equipment apply to the passive reading principle
  • questions on how to maintain identification of a carcass when the head is separated from the body and sent for testing
  • clarification on the exemptions when you are able to remove livestock from a site during an emergency or welfare issue without an approved indicator
  • requests for cervids kept in zoos to be exempted from bearing 2 approved indicators
  • clarification regarding when a regulated party is considered to have reported their movement
  • clarification on reporting events by proxy (industry, associations, provinces etc.)
  • questions on what reporting is required at feed, water, and rest stations
  • concerns about the requirement to report individual identification numbers when pigs are exported from assembly points for immediate slaughter
  • clarification on reporting disposal when carcasses move through several different carcass collection sites
  • questions on whether compliance with the proposed regulations will be linked to compensation in a disease response

Next steps

The CFIA thanks everyone who participated in the consultation process. We will consider all input as we work to update the Health of Animals Regulations (Identification and Traceability). For some aspects, the CFIA will be actively re-engaging with stakeholders to work on solutions to their concerns. The CFIA anticipates publishing the final amendments in the Canada Gazette, Part II in 2024. At that time, additional guidance and information sessions will be held to support stakeholders as the new regulations are implemented.


The following has been included to respond to some specific comments that were raised during the consultation and to provide feedback on the direction the CFIA will take moving forward. Comments that were considered to be outside of the scope for this consultation may not be addressed here.


Comments related to tag costs and concerns with tag retention


The CFIA heard from many stakeholders that a lack in retention of current approved animal indicators used by industry is a significant concern. Standards for tag quality are not covered within the Health of Animals Regulations, however, the list of approved animal indicators will be incorporated by reference in the proposed regulations. The approval of animal indicators is guided by the Animal Indicator Approval and Revocation Framework (Framework) which sets out standards for tags, including tag retention. This Framework is developed and maintained by the National Identification and Methodology Advisory Committee, whose membership includes national industry associations representing each regulated sector, the CFIA, and administrators under the livestock traceability program. These standards are intended to ensure approved animal indicators are suitable for livestock practices in Canada along with the Canadian environment. Furthermore, these standards exceed the International Committee for Animal Recording (ICAR) standards, which are internationally recognized. The CFIA is always ready to evaluate new animal indicator technology put forward by manufacturers and the recommendations for the approval of animal indicators made by responsible administrators.

The CFIA also heard many concerns from stakeholders regarding the high cost of tags. Approved animal indicators are issued to industry by the responsible administrator of each species. It is important to note that these responsible administers are not for profit organizations and are responsible for setting the cost of tags on a cost recovery basis.


Comments related to herd marks for goats


Questions and comments were received in relations to the added option for the goat sector to use herds marks as approved indicators. The regulations simply allow the use of herd marks for certain species (pigs, sheep and goats), however, the actual use of herd mark indicators is subject to consultations between CFIA and industry before they can be used. For instance, the goat industry hasn't yet sought the pre-approval of those indicators. The approval of herd marks can only be accomplished with industry support, the recommendations from the responsible administrator of that species, and the appropriate steps followed to be placed on the approved animal indicator page. The approved animal indicator page will be incorporated by reference. The CFIA Incorporation by Reference Policy sets out the CFIA's roles and responsibilities related to IBR. Any changes made to these IBR documents, whether adding or removing approved indicators, will be consulted on before the change is made. Only when herd marks are listed on the approved animal indicator page would they be an option for industry.


Comments related to pig identification for exports


Stakeholders indicated that the proposed removal of ear tags bearing herd marks and ear tattoo herd marks as approved methods of identifying exported pigs would pose a significant burden on the industry as it is common practice currently.

The CFIA recognizes that these forms of identification is standard practice for exports that has been working well for stakeholders and acknowledges that these changes were an oversight in the regulatory proposal.

The CFIA recognizes the implication of those changes and intends to update the proposed regulations to again allow ear tags bearing a herd mark to be a valid method for identifying all categories of exported pigs and ear tattoo herd marks to be a valid method of identifying isowean and feeder pigs exported to farms in another country. This change will be reflected in the incorporated by reference document – Approved Animal Indicators. It is also important to recognize that the importing country may have further identification requirements.


Comments related to herd inventory and the repeal of the Cervid Movement Permit (CMP)


Industry expressed concern with the CFIA proposal to repeal section 76 of the Health of Animals Regulations, the requirement to obtain a permit before moving cervids, as the CMP is currently being used by industry for herd inventory purposes.

CMPs are documents used by stakeholders to facilitate inter-provincial movements, shipments to slaughter, and exports, among other uses. With the proposed regulatory changes, identification and movement reporting will be reported into a centralized database accessible to authorized users, some of this information (movement reporting with herd of origin, herd of destination, identification numbers, dates) would be accessible through this different mechanism. When further information is needed by industry that is not captured by movement reporting requirements in the regulations, alternative approaches will need to be developed. This initiative will be lead by industry with the involvement of the CFIA, other federal departments, and provincial/territorial government as needed.


Comments related to brucellosis, bovine tuberculosis and CWD programs with the repeal of the CMPs


Cervid stakeholders were concerned about how the repeal of the CMPs would affect the surveillance done for brucellosis, bovine tuberculosis and CWD programs. The CFIA is working with industry and provincial/territorial governments to design a cervid surveillance system for brucellosis and bovine tuberculosis that is independent of cervid movement permits. There is currently no link between CMPs and CWD surveillance. CWD surveillance is mandated by provincial and territorial agriculture and environment departments as well as the Chronic Wasting Disease Herd Certification Programs (for enrolled herds). Mandatory provincial surveillance for CWD exists in Alberta, Saskatchewan, Manitoba, Ontario, Quebec and Yukon.

Stakeholders were also concerned about how the movement of CWD positive herds would be controlled if CMPs were repealed. The only CWD condition currently linked to CMP issuance restricts the movement of cervids from confirmed CWD positive premises to terminal locations (abattoirs or hunt farms) where mandatory provincial CWD testing programs exist. At this time, hunt farms are only permitted by provincial authorities in Saskatchewan and Quebec. In the absence of CMPs, section 11 of the Health of Animals Act still applies. Under this section, a license or permit issued by CFIA will still be required to move a CWD-exposed cervid or a cervid from a CWD positive premises. This license/permit may look different than the current CMP, but the conditions for movement will remain the same.


Comments related to the proposed requirements for wild or "unmanaged" herds


The CFIA received comments on whether the Health of Animals Regulations (Identification and Traceability) apply to wild herds. To clarify, the proposed regulations only apply to farmed or captive bison, cattle, sheep, pigs, goats and cervids. As such, there would be no requirement to identify wild herds. This reasoning also applies to some wild herds under human supervision, such as caribou that typically remain within the lands of an indigenous community and are not moved to another site or abattoir, in which there would be no traceability requirements to comply with.


Comments related to the obligations of livestock transporters with regards to the Humane Transport Regulations and Livestock Traceability Regulations and the concern of duplication in recording of information


A number of comments were received regarding the overlap of information required to accompany transported animals as written in the Humane Transport Regulations and Livestock Traceability Regulations. It is important to clarify that livestock transporters can keep the required information on the same document or form (paper or electronically) in whatever mean they choose as long as it is readily available to CFIA inspectors. This means there would be no duplication, livestock transporters may keep 1 record to comply with both the humane transport requirements and livestock traceability requirements.

Additionally, livestock transporters expressed concern that they would be required to report traceability information to the responsible administrators. It is important to understand that the livestock transporter is only required to ensure the required information is provided to the operator of the destination site within 24 hours after the arrival of the animal or carcass at the destination site and to keep a record of that information for a period of at least 2 years. Livestock transporters are not required to report the information to the responsible administrators.


Comments related to the collection and access of livestock traceability information


With regards to questions and comments related to the collection and access of livestock traceability information, the elements of livestock traceability information are deemed personal information, that is information that on its own or combined with other pieces of data, can identify an individual. As such, livestock traceability information is subject to the Privacy Act, the law that governs the personal information handling practices of federal government institutions, such as the CFIA. The act applies to all of the personal information the federal government collects, uses and discloses.

Livestock traceability information is collected by responsible administrators which are organizations authorized by the federal government to receive this information and administer a national identification program in relation to certain species that are located in 1 or more provinces. The responsible administrators then send the traceability information to the CFIA through the Traceability National Information Portal (TNIP). Livestock traceability information may be disclosed to:

  • inspectors of the CFIA for the purpose for which the information was obtained or compiled by the CFIA, for example to administer the livestock identification and traceability program
  • inspectors of a provincial government that signed a data sharing agreement with the CFIA for the purpose for which the information was obtained or compiled by the CFIA, and
  •  an investigative body specified in the Privacy Regulations, on the written request of the body, for the purpose of enforcing any law of Canada or a province or carrying out a lawful investigation, if the request specifies the purpose and describes the information to be disclosed


Comments related to the cost-benefit analysis report


The CFIA heard from many stakeholders concerned with the assumptions made in the cost-benefit analysis report. Stakeholder associations expressed that the predicted costs to industry, the CFIA, and the responsible administrator resulting from the proposed regulatory changes were significantly underestimated. In particular, stakeholder associations commented that the price of approved indicators, the wage rates used, the time required to learn about the proposed regulatory requirements, the time and labour associated with the repeal of record keeping requirements, and the time and resources required to report events were not accurately represented in the report.

The cost-benefit analysis was prepared using data and industry input available at the time of publication. The CFIA will be updating the cost-benefit analysis report for the final publication of the regulatory proposal at Canada Gazette II (CGII) with more current data and information.


Comments related to requests for government funding in order for industry to implement the proposed Regulations


A number of comments were received requesting support from the government with respect to the additional costs associated with implementing the proposed changes to the regulations. Many stakeholders felt that funding will be required in order for them to comply with the regulatory proposal.  

Agriculture and Agri-Food Canada (AAFC) has provided consistent funding to livestock sectors for the development and implementation of livestock traceability systems and tools. This funding has been available in multiple, 5 year policy frameworks and initiatives (for example Growing Forward, Growing Forward 2, the Livestock Auction Traceability Initiative, the Canadian Agricultural Partnership, the Sustainable Canadian Agricultural Partnership, etc.), and continues today under the current AgriAssurance Program. This funding is available to National Industry Associations to develop, verify, and integrate traceability and assurance systems to address market and regulatory requirements. Similarly, there is a complimentary small- and medium-sized enterprises component that covers market and regulatory requirements as well. Complimentary funding has also been available to livestock producers to meet traceability requirements through provincial/territorial programs.


Comments related to the need for inspector resources to ensure adequate inspection and enforcement activities


Many stakeholders indicated they have significant concerns regarding the absence of inspections and subsequent lack of enforcement of the Health of Animals Regulations. Industry has expressed a desire for consistency in compliance and enforcement actions by CFIA inspectors.

With respect to the concerns regarding inspector resources, it is important to note that inspection tasks are site specific (for example abattoir, assembly point) and tasks for current inspectors will be amended to include inspections of the proposed traceability requirements when on site performing other tasks. It is also important to note that most compliance verification tasks for movement events can be done through the responsible administrators databases and the Traceability National Information Portal (TNIP). The CFIA will modernize inspection activities to focus on risk based inspections and ensure resources are directed to sites at high risk for non compliance to ensure adequate enforcement of the proposed regulations. The CFIA will also ensure effective communication of the regulatory changes to CFIA inspectors as well as provide updated guidance and training.


Comments related to administrative monetary penalties (AMPs) under the Health of Animals Regulations


The Health of Animals Act and regulations are included in the Agriculture and Agri-Food Administrative Monetary Penalties Act (AAMPA) and regulations which establishes a fair and efficient administrative monetary penalty system for the enforcement of the agri-food acts. Under the AAMPA, the CFIA may pursue enforcement measures to encourage compliance with the Health of Animals Act and regulations. Industry and consumers have both indicated that they want CFIA to deal effectively and consistently with instances of non-compliance. This involves issuing administrative monetary penalties (AMPs) as notices of violation with warning or with financial penalty, depending on the nature of the violation. After updates to the Health of Animals Regulations (Identification and Traceability) are published in CGII, the CFIA will make the relevant updates to the Agriculture and Agri-Food Administrative Monetary Penalties Regulations and notify stakeholders of the changes.

The CFIA's Compliance and Enforcement Policy outlines how it conducts enforcement, including the application of AMPs in a consistent, fair and transparent manner. CFIA selects the appropriate control and enforcement actions based on risk and the gravity of the non-compliance. As specific facts relating to cases of non-compliance may vary considerably, the enforcement actions applied may not be the same in each instance. CFIA has the flexibility and authority to select the appropriate enforcement actions based on risk and the nature of the non-compliance. Gravity of non-compliance is determined by considering the potential or actual harm associated with the non-compliance, the compliance history of the regulated party, and the intent associated with the non-compliance. These factors also help determine whether an AMP is issued as a notice of violation with warning or with financial penalty.


Comments related to the coming into force of the proposed Regulations


A number of comments were received requesting clarification on which transition period applies to them. Also, there were a number of comments requesting that the transition period be consistent among all stakeholders and thus, be extended to 2 years for everyone.

For most stakeholders who are already familiar with regulations or with traceability in general, the proposed regulations would provide a 1-year transition period before coming into force to the livestock industry. But to further support all stakeholders, after the proposed regulations come into force, there will be a period where CFIA inspectors will be focused on education and communication. This will allow further time for stakeholders to adjust and comply with the new requirements.

Recognizing some stakeholders may be unfamiliar with the livestock traceability program, the proposed regulations would provide them a 2-year transition period before coming into force. This would apply to owners of livestock animals that are kept for a person's company (for example companion goats), that are used for research purposes, and that are used for entertainment purposes. It is anticipated that this transition period would provide sufficient time to engage and educate these stakeholders on the new regulatory requirements and their responsibilities.


Comments related to guidance materials for Canada Gazette, Part II (CGII) publication


The CFIA appreciates the comments received regarding the importance of proper communication, and the development of helpful guidance materials, to assist industry to become aware of the changes to the regulations and support regulatory compliance. The CFIA will reach out to industry associations to determine the best way to engage with various sectors on the distribution of guidance materials. Working with industry on outreach initiatives will allow us to effectively communicate the proposed requirements to stakeholders, including those with limited internet access.

Industry guidance will be available when the proposed regulations are published at Canada Gazette, Part II. Initial guidance will include sector specific materials (for example goat sector), site specific materials (for example assembly points), webinars, and online decision making tools. Further guidance materials may be developed as needs are identified by stakeholders.