Replacement certificates for foods other than meat

Once an export certificate is issued by the Canadian Food Inspection Agency (CFIA), no corrections are allowed. If errors are identified, an inspector may issue a replacement certificate under certain circumstances.

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When is a certificate eligible for a replacement

Ineligible circumstances

The CFIA will not issue replacement certificates when:

  • the exporter requests 1 certificate be replaced by 2 or more certificates
  • the exporter requests 2 or more certificates be replaced by 1 certificate
  • issuing a replacement certificate would contravene CFIA's export certification policy and/or the requirements or conditions of the importing country
  • issuing a replacement certificate requires information or details that the inspector cannot verify (for example, a change in container or seal number after the product has left Canada)

Export stamp and shipping mark errors

A replacement certificate cannot be issued for shipments with packages bearing incorrect shipping marks or stamps.

If the shipment is still in Canada and the shipping marks do not match the corresponding information on the certificate, the errors on the packages and labelling must be corrected. The CFIA requires that either:

  • the incorrect stamp or shipping mark on the packages are blacked out and new information labelled over it, or
  • the product is repackaged with the correct shipping marks

Once corrections to packages and labels have been verified by CFIA, the original certificate may be cancelled and a new certificate requested provided the product is still in Canada and available for inspection at the time of the request.

If the shipment has left Canada and the incorrect shipping marks were submitted in the request for the original certificate, a replacement certificate cannot be issued.

Eligible circumstances

Lost certificate

The CFIA may issue a replacement certificate if the original certificate is lost. The inspector will review the written explanation and determine if the exporter has made all reasonable efforts to retrieve the lost certificate. If the inspector identifies that there are repeated instances of lost certificates, which indicate a lack of export controls over official government documents, the request for a replacement certificate may be denied.

Administrative errors

The CFIA may issue a replacement certificate due to an obvious "administrative error" identified on an issued certificate. This may include typographical errors. The following situations are not considered to be administrative errors:

  • identification of different or additional product lot numbers
  • identification of additional species, or
  • identification of additional product variations that were not presented on the original certificate request

The inspector may ask the exporter to provide documentation to support the requested correction and will review such documentation to determine if an administrative error has occurred.

In all cases, the issuance of a replacement certificate due to an administrative error will depend upon the exporter's ability to provide the following information based on product traceability and shipping documentation:

  • full and accurate description of the consignment
  • compliance with regulatory and importing country conditions
  • explanation as to how the administrative error occurred

The documentation provided may be pictures of the actual information (for example, lot numbers, container number, seal number, product labels, loaded containers). Other documents such as shipping documents/bills of lading which verify the contents of the container may be considered if these documents clearly identify the missing or incorrect information.

Failure to provide complete and accurate documentation will result in a denial of the replacement certificate request.

Change in quantity

A replacement certificate with a change in quantity (for example, change in number of packages or change in total weight) may only be issued if the following criteria are met:

  • The request does not identify new product types or new product lot numbers
  • The applicant provides verification that their mistake in quantity on the original certificate
    • was due to an administrative error (see above)
    • the identity of the lot that was originally inspected and certified has not changed
    • the request for replacement certificate does not contravene an import requirement of the importing country

Change to destination country

A replacement certificate may be requested for a change to the country of destination due to reasons such as a change in consignee or unforeseen international circumstances, such as an embargo or natural disaster.

However, for a request to be considered, the product must be compliant with the import requirements of the new destination country.

The applicant must provide documentation to the inspector that the product complies with the new destination country's public health and animal health requirements at the time of product processing or manufacture.

If the new destination country is in the European Union (EU), the border control post of the importing EU country must confirm that they will accept a new certificate validated after the date of departure, as TRACES NT does not allow the creation of a replacement certificate when no original certificate exists in the system.

Change to destination country when requirements also change

If the import requirements of the new destination country differ from or require different or additional health attestations than the original country of destination, CFIA may not be able to issue a replacement certificate.

However, inspectors may consider such requests on a case-by-case basis if the exporter is able to provide written confirmation from the foreign competent authority that identifies import requirements and export certification requirements. In addition, CFIA must be able to verify that import requirements have been met.

When the new destination country has different import conditions for animal health that did not appear on the original certificate, a replacement certificate cannot be issued unless the consignment meets the new import conditions and the foreign competent authority confirms that CFIA may issue the replacement certificate.

Change to container or seal numbers

A request for a change to container/seal number for a replacement certificate may only be considered by CFIA if the inspector is able to verify the requested change to that number.

Shipment needed to be split or consolidated

Generally, CFIA will not issue a replacement certificate when an applicant requests 1 certificate be replaced by 2 or more certificates or 2 or more certificates be replaced by 1 certificate.

Split shipments due to quantity issues caused by transportation

CFIA understands that due to cargo weight limitations, shipments may need to be split. When a split is due to transportation issues, that is, only a portion of consignment identified on the original certificate can be shipped, the exporter must provide documentation to the inspector (for example, copy of waybill) quantifying the portion of the consignment shipped. If the information submitted is acceptable, a replacement certificate may be issued with the revised information. Alternatively, or in addition to the replacement certificate, a "letter of explanation" may also be issued by the inspector, if requested by the importing country.

For the remaining portion of the shipment that did not fit into the original cargo space, a new certificate may be issued on a case-by-case basis, provided the product is available for inspection in Canada at the time of the request.

Shipment has already cleared foreign customs

If the product has already been imported and has cleared customs in the destination country, an official copy of the original certificate may be provided by CFIA if confirmation is received that it will be accepted by the importing country.

After border clearance in the foreign country, a replacement certificate can only be issued by CFIA if it is intended to replace a lost or damaged certificate, and the following criteria are met:

  • the border control post or the foreign competent authority requests a replacement certificate be issued
  • the official correspondence from the border control post or foreign competent authority is provided to the inspector and includes the
    • name of the border control post or foreign competent authority
    • name and contact information of the requesting official in the destination country
    • details regarding the request for the replacement certificate
  • the product information on the replacement certificate is identical to the information on the original certificate
  • the CFIA inspector accepts the disposition of the original certificate

Shipment has arrived but not cleared foreign customs

If the product has not cleared customs in the destination country and has been detained by a border control post, a replacement certificate can only be issued if the following criteria are met:

  • the border control post or foreign competent authority requests that a replacement certificate be issued
  • the official correspondence is provided to the inspector and includes the
    • name of the border control post or foreign competent authority
    • name and contact information of the requesting official in the destination country
    • details regarding the request for a replacement certificate and exact details on what the border control post or foreign competent authority will accept to clear the shipment
  • the applicant is able to provide CFIA with sufficient information to support the request
  • the CFIA inspector accepts the disposition of the original certificate

How to request a replacement certificate

In all instances, applicants must provide a written request to the CFIA inspector, which includes sufficient support for a replacement certificate and identifies the:

  • reason a replacement certificate is needed
  • specific information on the original certificate that needs to be changed and details of the necessary revision
  • disposition of the original certificate, and
  • location and current status of shipment

The CFIA will consider requests for replacement certificates on a case-by-case basis. The inspector may request additional documentation to verify the information provided by the applicant.

Applicant responsibilities

Disposition of original certificate

When the CFIA issues a replacement certificate, the original certificate becomes void. The original certificate and all accompanying export documents must be either:

  • returned to the CFIA or confirmed by the applicant that they will be returned
  • in the possession of a recognized foreign competent authority, or
  • in the possession of a Canadian embassy or consulate

The CFIA recognizes that in certain exceptional circumstances, export certificates and additional export documents may become lost or damaged. All effort should be made by the applicant and the parties involved to recover them before a replacement certificate is requested.

Applicants must provide in writing to the inspector the reason why a certificate cannot be returned and what efforts were made to locate a missing certificate.

Export controls

As per CFIA's Food Export Control Policy, an applicant must have control measures in place as part of their preventive control plan or export control plan for the preparation of applications for export certificates and associated record keeping. These plans must take into account potential requests to CFIA for replacement certificates.

Follow up by applicants

The applicant should initiate follow up after each replacement request and implement corrective actions and/or modification to export controls to prevent reoccurrence. The applicant must develop and maintain supporting documents and provide to the inspector upon request.

Requests for replacement certificates should not become routine. Repeated requests may indicate a lack of control over government issued documents and could result in the denial of future certificate requests until follow up activities are completed.

Fees

A fee may be charged for the replacement certificate and any inspection activities conducted by the CFIA in support of issuing the certificate.

Other documents

The applicant is required to provide confirmation in writing from the border control post or foreign competent authority of what document is required to release the shipment. The original communication from the border control post or foreign competent should be provided to the inspector for review.

Cancellation of the original certificate

An original certificate can only be cancelled by a CFIA inspector. When a certificate is cancelled and the "VOID" overprint is applied:

  • the certificate can no longer be used, and
  • a replacement certificate cannot be issued

The original certificate will be kept on file at the local CFIA office.

When a replacement is issued electronically in MyCFIA, the original certificate in the CFIA's Digital Service Delivery Platform is voided automatically and can no longer be retrieved in the CFIA Certificate Authenticator. When a replacement certificate is requested, then the CFIA may require the applicant to:

  • provide a written explanation, and
  • return the original certificate to the CFIA, or
  • provide evidence of the destruction of the original certificate

This cancellation process does not apply to certificates for exports to the European Union issued in TRACES NT.

CFIA letter of explanation

On a case-by-case basis, the CFIA may issue a letter of explanation instead of, or in addition to, a replacement certificate. A letter can be issued if the applicant provides reasonable indication that the letter will be acceptable to the country of destination and submits adequate supporting documentation for the requested change. Typically, a letter or email from the border control post or foreign competent authority of the importing country addressed to CFIA provides confirmation that a letter of explanation will be accepted and indicates what specific information is required in the CFIA letter. The applicant must provide the original communication from the border control post or foreign competent authority to the inspector for review.

Annex 1. Replacement certificates in TRACES NT (European Union)

In the EU's TRACES NT system, a replacement certificate is a new electronic certificate that legally replaces an already "validated" certificate when certain information must change after issuance, typically while the consignment is in transit or before it clears border controls. For shipments that have arrived but have not cleared customs, replacement certificates can only be issued if requested by the foreign competent authority or border control post. For more information, consult the Shipment has arrived but not cleared foreign customs section.

Similarly, letters of explanations may also be issued at the request of the foreign competent authority or border control post. For more information, consult the CFIA letter of explanation section.

In accordance with Article 6 of Regulation (EU) 2020/2235, replacement certificates for consignments of animals and goods intended for human consumption can only be issued in the case of administrative errors in the initial certificate. A replacement certificate cannot be issued for errors in the initial certificate concerning the identification of the consignment, its traceability and the guarantees provided for in the initial certificate for the consignment.

Written requests for replacement certificates are submitted to the local CFIA office by the applicant. The request must contain sufficient supporting information. For more information, consult How to request a replacement certificate section. The replacement request must also identify the Information Management System for Official Controls number of the original certificate.

CFIA evaluates the request and, if accepted, retrieves the original certificate from TRACES NT, generates a replacement with the requested changes and "validates" (issues) the replacement certificate. Once the original certificate is put into a "Replaced" status it is no longer legally valid. The new replacement certificate becomes the legally valid certificate for the consignment.

If a common health entry document has been cloned, it must be deleted before a replacement certificate can be generated by CFIA in the TRACES NT system. Canadian exporters must contact their EU importer to initiate the deletion of the cloned common health entry document.

Despite the differences in how replacement certificates are issued in TRACES NT, the applicant's obligations regarding export controls, follow‑up, fees, and other required documents outlined in the applicant responsibilities section remain applicable.

TRACES NT maintains a link between the original certificate and the replacement certificate, so users can navigate from one to the other and trace the history of issuance.

Annex 2. Replacement certificates in MyCFIA

For more information on how to request a replacement certificate when the original certificate was issued via MyCFIA, please refer to Food export certificate in My CFIA: Modify, amend, print or replace.