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, a CFIA inspector may subsequently issue a replacement certificate under certain circumstances.

On this page

• Requests for replacement certificates
• Replacement due to administrative errors
• Replacement due to change in quantity
• Replacement due to split or consolidated shipments
  • Split shipments due to quantity issues caused by transportation
• Change to destination country
  • Change to destination country when requirements also change
• Change to container or seal numbers
• Export stamp and shipping mark errors
• Shipment has already cleared foreign customs
• Shipment has arrived but not cleared foreign customs
• Applicant responsibilities
  • Disposition of original certificate
  • Export controls
  • Follow up by applicants
  • Fees
  • Other documents
• CFIA Letter of Explanation

Requests for replacement certificates

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.

Replacement due to 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.

Replacement due to 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

Replacement due to split or consolidated shipments

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. However, such requests may be considered by inspectors on a case-by-case basis.

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 is able to 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 second replacement certificate may be issued on a case-by-case basis, provided the product was available for inspection in Canada at the time of the original request.

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, including the label, 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, animal health and labelling requirements at the time of product processing or manufacture.

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 (FCA) 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 FCA 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 can verify the requested change.

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. Requests for replacement certificates due to minor administrative errors may be considered on a case-by-case basis.

Shipment has already cleared foreign customs

If the product has already been imported into and cleared customs in the destination country, a replacement certificate can only be issued if the replacement certificate is intended to replace a lost or damaged certificate, and following criteria are met:

• the Border Control Post (BCP) or the FCA requests a replacement certificate be issued
• the official correspondence from the BCP or FCA is provided to the inspector and includes the
  • name of the BCP or FCA
  • 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 BCP, a replacement certificate can only be issued if the following criteria are met:

• the BCP or FCA requests that a replacement certificate be issued
• the official correspondence is provided to the inspector and includes the
  • name of the BCP or FCA
  • 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 BCP or FCA 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

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 confirmation 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 (PCP) or export control plan (ECP) (see Guide for preparing an Export Control Plan (ECP)) 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 BCP or foreign competent authority of what document is required to release the shipment. The original communication from the BCP or foreign competent should be provided to the inspector for review.

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 BCP or FCA 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 BCP or FCA to the inspector for review.