An explanation of the preventive control plan exception for food businesses with gross annual food sales of $100,000 or less.
On this page
- Overview of who needs a preventive control plan
- Exception for businesses with gross annual food sales of $100,000 or less
- How to calculate your gross annual food sales
Overview of who needs a preventive control plan
Most food businesses subject to the Safe Food for Canadians Regulations (SFCR) are required to prepare, keep, maintain and implement a written preventive control plan (PCP) to demonstrate how hazards to food are controlled.
The PCP requirements generally apply if you:
- hold a Safe Food for Canadians (SFC) licence to:
- import food
- manufacture, process, treat, preserve, grade, package, label or store food for interprovincial trade
- manufacture, process, treat, preserve, grade, package, label or store meat products or fish for interprovincial trade or export
- slaughter food animals from which meat products are derived
- store and handle edible meat products in their imported condition for inspection by the Canadian Food Inspection Agency (CFIA)
- grow or harvest fresh fruits or vegetables for interprovincial trade; and
- request an export certificate from the CFIA
The PCP interactive tool can help you determine if your business needs a plan.
Exception for businesses with gross annual food sales of $100,000 or less
Sections 86 and 87 of the SFCR provide an exception from the PCP requirements for some small businesses whose gross annual sales from all food are $100,000 or less.
- The exception only applies to:
- activities identified in a SFC licence related to a food other than dairy products, eggs, processed egg products, fish, processed fruit or vegetable products, meat products or food animals
- for example, fresh fruits or vegetables, honey or maple products
- businesses who grow or harvest fresh fruits or vegetables for interprovincial trade
- activities identified in a SFC licence related to a food other than dairy products, eggs, processed egg products, fish, processed fruit or vegetable products, meat products or food animals
- The exception does not apply to:
- any activities identified in a SFC licence related to dairy products, eggs, processed egg products, fish, processed fruit or vegetable products, meat products or food animals
- businesses who request an export certificate from the CFIA
Note: Businesses who have a PCP exception must still comply with the preventive control requirements under Part 4, Divisions 1 to 5 of the SFCR.
Example 1
A food business holds an SFC licence to:
- package and label fresh fruits and vegetables for interprovincial trade, and
- process, package and label processed fruit and vegetables products for interprovincial trade
Their gross annual sales from all food are less than $100,000.
In this scenario, the PCP exception only applies to the fresh fruits and vegetables the food business packages and labels for interprovincial trade. They are still required to prepare, keep, maintain and implement a written PCP for the processed fruit and vegetable products they process, package and label for interprovincial trade.
Example 2
A food business holds an SFC licence to:
- process, treat, package and label honey for interprovincial trade, and
- manufacture, package and label cookies for interprovincial trade
Their gross annual sales from all food are less than $100,000.
In this scenario, the PCP exception applies for the activities the food business conducts in respect of both the honey and the cookies since they are both foods other than dairy products, eggs, processed egg products, fish, processed fruit or vegetable products, meat products or food animals.
Example 3
A food business holds an SFC licence to:
- manufacture, grade, package and label maple products for export, and
- export the maple products, for which they have requested an export certificate from the CFIA
Their gross annual sales from all food are less than $100,000.
In this scenario, the PCP exception would not apply for the maple products the food business manufactures, grades, packages and labels for export because they have requested an export certificate from the CFIA.
How to calculate your gross annual food sales
To calculate your gross annual food sales, add the total revenue from any food you sold in exchange for money over a one-year period.
For this calculation, a one-year period means:
- the 12 months before the day on which you most recently made an application for the issuance, renewal or amendment of your licence, or
- the 12 months before you began growing or harvesting fresh fruits or vegetables for interprovincial trade
As applicable, include all revenue from:
- food you imported or exported
- food you sold intraprovincially or interprovincially
- any food-related services you provided (for example, manufacturing or packaging a food on behalf of another company)
- sales earned outside of Canada
Example 1
You applied for an SFC licence on August 26, 2023 to import various foods other than dairy products, eggs, processed egg products, fish, meat products or processed fruit or vegetable products.
You run a restaurant with a store front and also sell food to other local businesses within your province.
To determine if you need to comply with the PCP requirements for the food you import, you must calculate the revenue you generated from all food sales during the 12 month period before the day on which you applied for your licence.
Between August 25, 2022 and August 25, 2023, you generated revenue from the following food sales:
- $268,000 from restaurant food sales
- $67,000 from store front food sales
- $42,000 from intraprovincial food sales to other retailers
Your gross annual food sales are $377,000 ($268,000 + $67,000 + $42,000)
Since you made more than $100,000 in gross annual food sales, you are required to prepare, keep, maintain and implement a written PCP for the food you import.
Example 2
You grow and harvest fresh strawberries and began your operation for interprovincial trade on April 15, 2020.
You sell the strawberries at your farm and local farmers markets, to grocery retailers within and outside your province, and to local restaurants and caterers.
To determine if you need to comply with the PCP requirements, you must calculate the revenue you generated from all food sales during the 12 month period before the day on which you began operating.
Between April 14, 2019 and April 14, 2020, you generated revenue from the following food sales:
- $5,000 from on farm sales
- $20,000 from farmers market sales
- $50,000 from intraprovincial and interprovincial food sales to grocery retailers
- $12,000 from sales local restaurants and caterers
Your gross annual food sales are $87,000 ($5,000 + $20,000 + $50,000 + $12,000)
Since you made less than $100,000 in gross annual food sales, you are not required to prepare, keep, maintain and implement a written PCP for the strawberries you grow and harvest for interprovincial trade. However, you must still comply with the preventive control requirements under Part 4, Divisions 1 to 5 of the SFCR.