Importing dairy products for re-export

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Introduction

The Import for re-export program (IREP) allows Canadian dairy processors to import dairy products from the United States (USA) for processing or repackaging to manufacture dairy or food products for re-export. The products imported under IREP are not subject to tariffs charged under Global Affairs Canada (GAC); however, importers still must pay the applicable dairy fees (see Canadian Food Inspection Agency Fees Notice). Inspection and sampling of the imported products may occur.
More information on the GAC IREP program can be found on Controlled Products.

Raw milk and/or cream

Canadian dairy processors wishing to import raw milk or cream into Canada to be processed into dairy products and subsequently re-exported from Canada must be federally registered or licensed under the Safe Food for Canadians Regulations (SFCR). To assist GAC, the Canadian Food Inspection Agency (CFIA) performs compliance verifications of dairy plants. A list of establishments participating in this program will be provided by GAC. The CFIA may sample raw milk and cream coming from the USA for chemical residues. Inspectors are to use the sample bottles provided for raw milk sampling. Sample size and program requirements are found in the annual sampling plan.

Non-dairy facilities importing butter, cheese and/or other dairy products

Inspection staff may sample other dairy products such as butter and cheese imported under IREP but this type of sampling is given a low priority. The annual sampling plan guidelines are followed. Under the SFCR, licensed importer/re-exporter facility inspections may be required for non-dairy processing facilities, for example bakeries. When unsatisfactory analytical results are received, CFIA personnel in food safety and consumer protection are contacted for follow up.

Requirements

Only CFIA federally registered and/or licensed establishments are eligible to export dairy products. The following requirements will apply to Canadian dairy processors under the IREP:

  1. Raw milk/cream coming from the USA must be from a United States Food and Drug Administration (USFDA) recognized Bulk Tank Unit (BTU) and be listed in good standing on the National Conference on Interstate Milk Shipments(NCIMS) and meet Canadian animal health import requirements.
  2. Interstate milk shippers reports along with relevant laboratory test results must be made available upon request for assessment by CFIA staff.
  3. All bulk milk/cream haulers/graders must be licensed and in good standing with the licensing authority. Furthermore, individual farm samples must be made available for testing upon request of a Canadian regulatory authority.
  4. No person in a registered and/or licensed establishment shall use, in the preparation of a dairy product for which grades or standards are established by Canadian regulations, any milk or cream that does not meet the quality standards established for milk or cream by the appropriate authority, provincially or federally. The provincial standards are the standards that the federal government accepts in a specific province. See Canadian Dairy Information Centre Acts, Regulations and Standards and CFIA Good manufacturing practices: Dairy processors for more information.
  5. Every bulk milk/cream tanker entering Canada from the USA must be accompanied by a document signed by a USFDA Official indicating that the milk/cream in the tanker meets the specific specifications as set out in point 1. above.
  6. The finished product must be labelled Product of Canada as set out in regulations.
  7. All requirements set out in the Food exports must be met for exporting the final product.
  8. CFIA reserves the right to carry out audits of those involved in the IREP; the frequency will be based upon random selection to determine that the policy is being followed as outlined. Deviations from the policy may affect participation in IREP.

Note: GAC requires that all milk/cream imported into Canada as part of the IREP must be kept segregated. All participants in the IREP must have a Preventive control plan (PCP) in place that can be audited to clearly demonstrate that the IREP milk/cream has been kept segregated.

Worksheet

Date:

Registered/licensed establishment: (name and number)

Please check only one box for each item.

  1. The participant has its Import for re-export program (IREP) letters from Global Affairs Canada (GAC) and holds records clearly stating that the milk/cream came from a United States Food and Drug Administration (USFDA) recognized Bulk Tank Unit (BTU).
    • Complete
    • Incomplete
  2. The participant demonstrates that the raw milk/cream meets the requirements for dairy products as indicated in section 94 of the Safe Food for Canadians Regulations (SFCR). For each load received the establishment has checked and recorded: temperature and aerobic colony count (ACC).
    • Complete
    • Incomplete
  3. The participant demonstrated that every bulk milk/cream tanker load brought in to Canada from the United States was accompanied by a document signed by an official of the USFDA certifying that the milk/cream is from a USFDA recognized Bulk Tank Unit (BTU) and be listed in good standing on the National Conference on Interstate Milk Shippers (NCIMS) and meet Canadian animal health import requirements.
    • Complete
    • Incomplete
  4. The participant was able to demonstrate that the finished product was labelled Product of Canada as set out in the SFCR.
    • Complete
    • Incomplete
  5. The establishment has submitted a plan to the Canadian Food Inspection Agency (CFIA) outlining how the milk/cream will be kept segregated. The plan has been implemented as written in the establishment Preventive control plan (PCP).
    • Complete
    • Incomplete
  6. The establishment has records demonstrating that the product produced with IREP milk/cream was re-exported.
    • Complete
    • Incomplete
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