Guide for Preparing an Export Certification Control Program Plan
Requirements for the Safe Food for Canadians Regulations
Although the Safe Food for Canadians Regulations (SFCR) came into force on January 15, 2019, certain requirements may apply in 2020 and 2021 based on food commodity, type of activity and business size. For more information, refer to the SFCR timelines.
What are foreign country certification requirements?
Foreign country certification requirements are the conditions outlined on a Canadian Food Inspection Agency (CFIA) recognized certificate that must be met to satisfy a foreign country's import requirements.
For definitions of other terms in this guide, please see the Safe Food for Canadians Regulations (SFCR): Glossary of key terms.
Anyone who wants to export a food needs to determine if there are unique requirements imposed by the foreign country, and if an export certificate is required from the Canadian Food Inspection Agency (CFIA). In order to receive an export certificate, the CFIA requires exporters to demonstrate that they have control measures in place to ensure the safety of the foods they export, and that they meet all Canadian and / or foreign country requirements.
Roles and responsibilities
Regulated parties are responsible for complying with the law. They demonstrate this commitment by ensuring that the food commodities and processes for which they are responsible meet the specified regulatory requirements. When a regulated party requests an export certificate, they are responsible for identifying the foreign country's requirements for their food commodity and must demonstrate how they meet those requirements.
The CFIA verifies the regulated party's compliance through activities that include inspection and surveillance. When non-compliance is identified, the CFIA takes appropriate compliance and enforcement action.If you do not require a certificate to export your food product, an Export Certification Control Program (ECCP) or any of the export certificate controls are not required. An ECCP is also not required for personal export shipments, for example, sport-caught fish.
Using the guide
The CFIA created this guide to help food businesses comply with the requirements set out in the Safe Food for Canadians Regulations (SFCR).
What is covered
- outlines steps for documenting an ECCP plan, which demonstrates how export requirements are met; and,
- allows for flexibility in approaches due to differing requirements and certification procedures for different countries depending on the food product.
What is not covered
While the guide provides examples of export certificate controls, it is not exhaustive – the certificate controls required will be unique for each business and will depend on the food commodity and foreign market.
Refer to the Tell me more! section below for other useful references related to exports, as well as links to other CFIA guidance that provide more details of preventive control plans (PCPs) and record keeping.
You may use other guides that have been developed by provincial counterparts, industry associations, international partners, or academic bodies as long as they can achieve the same outcome. You may also choose to incorporate these controls into your PCP or records instead of a standalone ECCP plan.
Always ensure that the guide you choose is tailored for your particular business, product or products, and market requirements.
Export Certification Control Program (ECCP)
Developing an ECCP plan will provide you with the ability to demonstrate with confidence that your products are acceptable to foreign markets and will reach them successfully.
A well-developed ECCP plan allows the CFIA to facilitate the certification process. These controls also help to protect the Canadian food industry's reputation and maintain trading partnerships with other countries.
Elements of the ECCP plan
You should incorporate all elements of the export certification controls into your food safety system. The ECCP plan is the written document that describes the procedures and processes used to capture the following elements:
- Preventive control plan (PCP)
- Exporting roles and responsibilities
- Foreign country requirements
- Product compliance
- Eligibility lists
- Inspections and fees
Element 1 – Preventive control plan (PCP)
You are required to have a PCP in place if you request export certificates for food. The activities in relation to the food being exported conducted by you will determine the extensiveness of the PCP. The PCP is the written document that demonstrates how hazards and risks to food products are controlled. The maintenance of records and documents within the PCP may include export certification controls if you wish to integrate the PCP and ECCP plan.
Note: A licensed export broker would need their PCP to cover the sourcing of food, for which they would like to obtain an export certificate or other export permission from the CFIA. A domestic food manufacturer and / or processor would need their PCP to be reflective of the food safety controls in place for their operations.
Integration of the Export Certification Control Program (ECCP) plan elements into a preventive control plan (PCP)
You may integrate ECCP plan elements into your PCP or keep them separate if you chose.
Element 2 – Export roles and responsibilities
Identify the name(s) and title(s) of the person(s) responsible for the implementation and maintenance of the export plan and documents. You are responsible for meeting all of the requirements of the importing country, and for making sure your products and establishments are eligible to export.
If you are exporting a meat product, you must also identify all qualified and legally responsible personnel who:
- prepare and sign the attestations and supporting documents required, and,
- confirm the eligibility of product for export to the country in question.
Note: The operator of the exporting meat establishment bears full responsibility for ensuring that all applicable requirements of the importing country are met and for providing satisfactory information to the CFIA before the CFIA can authorize the export and issue the required certificates.
Element 3 – Foreign country requirements
Describe how you determine the foreign country requirements. This could include:
- the webpage or link to the foreign country's website where the food commodity requirements are shown;
- documentation with the importing country's inspection body or through their embassy/consulate/trade commission who provided the requirements;
- documentation with the importer of the foreign country; and/or,
- a copy of the export certificates needed (which has the requirements identified on it).
You must provide the CFIA with information about the foreign country's requirements, so that the CFIA can evaluate against Canada's minimum product standards to see if a mutually acceptable certificate can be negotiated, if one does not already exist.
Element 4 – Product compliance
Your written ECCP plan must describe how the product complies with the foreign country's requirements. If your food meets Canadian requirements and that is the foreign country requirement (or equivalent), you can refer to your written preventive control plan (PCP).
Compliance with foreign certification requirements for food standards that exceed or differ from Canadian standards, or for which there is no Canadian standard, is your responsibility. You may be eligible to export a food that does not meet the Safe Food for Canadians Regulations (SFCR) requirements if the ECCP plan includes:
- proof that the container and markings comply with the requirements of the importing country;
- the contract with the importer clearly stating the quality specifications of the food product;
- the lot number or lot code of the shipment marked on the label or embossed on the container;
- the label on the container does not misrepresent the quality, quantity, composition, character, safety, or value of the food product;
- documentation of materials and incoming ingredients sources approved by the country of destination (if applicable), and any unique processes or establishment information which would impact the product compliance;
- documentation of health and safety requirements for chemical and microbiological standards including any foreign standards that exceed Canadian standards, or for which there is no Canadian standard, if applicable;
- attestations for any animal health disease status in the area; and / or,
- documentation of a Supplier Food Safety Assurance Program (SFSAP) which would describe the measures taken to ensure the food meets foreign country standards.
Note: Non-compliant product should never jeopardize Canada's trade reputation. The CFIA will not certify food that was processed under unsanitary conditions or marketed in a fraudulent manner.
Element 5 – Certification
You must provide complete, accurate and truthful information when requesting a certificate from the CFIA, or other export permission such as addition to an export eligibility list. An example of a CFIA certificate is the certificate of free sale.
Certification requests must be made before shipping your food products and you must use Canadian certificates that are recognized by the CFIA. All lots identified on the certificate must be available for inspection by the CFIA.
Please visit the Export certification page for more information about export certificates and how to complete them.
You should keep records of the certificate requested and shipments which will help demonstrate the product compliance to foreign requirements. The food commodity and foreign country will determine the information required to complete the certificate. Examples of information provided to the CFIA when requesting a certificate to be signed by the CFIA may include, though not limited to:
- country of import;
- recognized certificate type(s);
- location of the consignment;
- date the consignment is available for inspection;
- date the certificate is required (date of departure);
- total units and unit size of each lot in the consignment;
- product description (size, grade, type);
- scientific name;
- consignee name and address;
- consignor name and address;
- registered establishments and establishment numbers that conducted activities to the product (i.e. slaughter, processing, etc.);
- processing dates;
- net weights;
- product identification marks (production code);
- container and seal numbers; and / or,
- transport information.
Note: Consignments for countries or products that do not have negotiated certificates and known requirements may be certified with standard CFIA certificates (where applicable) but are at commercial risk.
Commercial risk means acceptance by you that the CFIA certificate is given in good faith based on your written assurances that all due enquiries have been made and that there is no known impediment to entry of the product into the country concerned. Commercial risk does not mean that the CFIA will provide certificates at request, if the request is contrary to known requirements. The CFIA assumes no liability if the company takes on commercial risk.
If you need to request a replacement certificate (or a letter of explanation), you must describe the control measures in your ECCP plan to capture the documentation involved.
The request for a replacement certificate should include an explanation of the event resulting in the need for a replacement certificate. Reasons could include:
- an administration error on a certificate;
- a certificate has been lost or damaged;
- the consignee of the food product certified has changed; and / or,
- there is a change in the quantity of product certified.
The procedures relating to the preparation of export documentation must aid in maintaining accurate export certificate preparation, and any implemented corrective action (if applicable).
The original certificate must be returned to the CFIA, where possible.
For a change of country of destination for a shipment still in Canada, the lot must comply with the requirements of the new country of destination at the time of processing.
If the product has been imported into the foreign country, a replacement certificate can only be issued if the consignment information, consignor and consignee on the replacement certificate are exactly the same (with the exception of meat product shipments).
Stickers, stamps and seals
You should describe in your plan the correct procedures relating to the use of export stickers, stamps and seals and keep records accordingly.
The SFCR requires that you retain, for 2 years (not 36 months), the records you generate to show that the control measures are implemented and effective. Records on the treatment of low-acid foods packed in hermetically sealed package, that are not kept refrigerated or frozen, have to be retained for 3 years.
Products shipped without an export certificate
You should describe in your plan the measures taken to ensure there were no known certification requirements. If there are no known certification requirements in an importing country, then you may export product at your own commercial risk. Meat products and shell or processed egg products for export must be certified.
Element 6 – Eligibility lists
You should indicate in your ECCP plan for each country of export the particular country's establishment eligibility requirements, as applicable, and identify how you meet the requirements. For example:
- only sourcing food from a federally registered or licensed establishment that is on the list of eligible establishments;
- identifying the establishment on the list of establishments approved to export to the foreign country, as applicable; and / or,
- by sourcing imported food from an establishment eligible to export to the foreign country, as applicable.
Please refer to each food commodity and country requirement to determine if this is relevant.
Element 7 – Inspections and fees
Your plan should include the frequency of inspection according to the food commodity and type of inspection required – some products must be prepared for export under continuous supervision of an inspector and other countries may only require pre-operational inspection frequency weekly or daily, etc. You should also be aware of the associated fees charged for the inspection, grading and/or issuance of an export certificate as prescribed by the Canadian Food Inspection Agency Fees Notice.
Notification of production and shipments
The plan should include how you notify the CFIA (when required) in advance of certain commodities being produced and/or shipped, and the requirements of the foreign country in relation to inspection coverage.
Element 8 – Traceability
Your plan must include information on the distribution of the food you exported.
The ECCP plan should outline how you identify all the certificates issued by the CFIA, the food product certified by each certificate, and the status of the lots certified (in inventory or exported). The distribution of the exported food products must be traceable to the first shipping destination to allow for the rapid recall.
For this purpose the following information must be maintained for each consignment certified by the CFIA (as applicable per food commodity):
- the country of import;
- the certificate type(s) received;
- the certificate number(s);
- description of the lots;
- the scientific and common names of the food;
- the method of production
- the name and registration/licence number of the establishment from which the food was sourced, if applicable;
- processing/packing date(s)/codes;
- the net weight of each unit;
- the total net weight of the lots
- the storage conditions of the product;
- the name and address of each person /company (consignee) receiving the food;
- the date the CFIA signed the certificate;
- the date the consignment was exported; and,
- the mode of transportation and container number (e.g. by air, by ship).
Replacement certificates received from the CFIA must be linked to the original certificate that was cancelled.
Traceability requirements are in Part 5 of the SFCR and not in Part 4 with the PCP requirements. To meet these requirements you have to trace the movement of the food (or other ingredients) you use. This includes preparing and keeping records that:
- identify the common name of the food the name and address of the person who manufactured, prepared, stored, packaged or labelled the food and tracking information that would trace back to lot code(s);
- trace the food one step back to the person who provided you with the food, including the date on which the food was provided to you;
- trace the food one step forward to the person to whom you provided the food, including the date on which you provided the food;
- trace the food to each place you moved it before you provided it to another person; and,
- if applicable, identify and trace back to the ingredients you used to make the food, including the date on which they were provided to you.
Health and safety verification and notification
Your plan should describe the procedures used when information or complaints are received that questions the safety of food products exported, how you verify the validity of the information to determine if the food products constitute a hazard to the public and if it does, how you notify the CFIA.
The following information must be kept on file and provided to the CFIA:
- the date and time the information was received;
- the date and time the information was determined to be valid or not;
- the date and time the CFIA was notified about valid information;
- the name, address and telephone number of the person who provided the information;
- a description of the investigation conducted;
- a description of the results of the investigation; and,
- the actions taken by the exporter in response to a confirmed health and safety issue.
The requirements found in Part 4 of the SFCR (preventive control requirements) and your procedures for receiving, investigating and responding to complaints in relation to your food do not need to be captured in your PCP; however, you can continue to include them there.
Note the requirements to:
- immediately investigate a complaint when you suspect on reasonable grounds that a food presents a risk of injury to human health;
- immediately notify the CFIA of the results of your investigation and take immediate actions to mitigate any risk of injury to human health when the results indicate that the food presents a risk; and,
- conduct a recall simulation, based on your procedures, once every 12 months, document the results of the simulation, and keep that document for two years.
Tell me more!
- Preventive controls for food business
- Preventive control plan (PCP)
- Traceability for food
- Labelling, standards of identity and grades
- Food safety standards and guidelines
- Supplier Food Safety Assurance Program
- Canadian Food Inspection Agency Fees Notice
Other further reading
Certain foods may require certification related to animal health (aquatic or terrestrial) or plant health. Information on animal and plant health certification requirements can be found at the following web addresses:
Information on the Canadian animal health status and OIE listed diseases in Canada can be found at the following web addresses:
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