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European Union (EU) - Export requirements for insects intended for human consumption

This directive applies to food business operators manufacturing insect food products intended for human consumption.

1. Eligible/ineligible product

EU certificate for insects intended for human consumption refers to a list of harmonized system (HS) code(s). It is the responsibility of the exporter to ensure that the product being exported will be covered by the certificates issued by the Canadian Food Inspection Agency (CFIA).

Eligible

Ineligible

2. Pre-export approvals by competent authority of importing country

Establishments

The insect based food products must come from an establishment licensed under the Safe Food for Canadian Regulations (SFCR).

The EU requires that insects originate from a Canadian establishment operating under the Hazard Analysis Critical Control Point (HACCP) principles (see Preventive control plan (PCP)) as stipulated in Commission Regulation (EC) No 852/2004 of the European Parliament and of the Council.

3. Production controls and inspection requirements

The insect products must meet the requirements as described on the EU model certificate. The manufacturer must implement an auditable specific procedure which demonstrates that the final product meets EU regulations.

Regulation of maximum levels of pesticide residues in food and feed

It is the responsibility of Canadian industry to ensure that levels of residues including pesticides in the food products for export are compliant with EU's regulations.

There are maximum residue levels (MRLs) for pesticides in food.  These are the maximum levels of pesticide residue that may remain in a food following correct use of the pesticide product in accordance with Good Agricultural Practice (GAP). MRLs must always be protective of health and they are normally well below a level of concern.

Food and Drugs Act and regulations in Canada

The PMRA specifies the maximum residue limits (MRL) on foods as per the Pest Control Products Act, and regulates the default MRL of 0.1 part per million as per DIVISION 15 Adulteration of Food B.15.002 of the Food and Drug Regulations.

The full text of the Food and Drugs Act and the Food and Drug Regulations are available on the Department of Justice website.

As per EU Regulation 396/2005, there are many different active chemical substances (such as pesticides) with MRLs defined for various food products categories intended for the EU market.

The EU establishes the MRLs for every individual food commodity. For foods where a pesticide use is not approved and there is no import tolerance (an MRL agreed upon for imported foods even if there is no approved use), a default MRL of 0.01 mg/kg, or higher if this is not achievable analytically, applies to any residue found. Any food that fails to comply with MRLs must not be placed on the market.

Note: some of the chemical substances regulated by EU are currently registered for use in Canada. The MRLs set by EU may or may not align with Canadian MRLs.

4. Labelling, packaging and marking requirements

Products need to satisfy EU labelling requirements.

5. Export documents available upon request

It is the responsibility of the exporter to ensure that the issued certificate meets the requirements of the entry border control post (BCP)/member state of destination in terms of official language.

The export certificate will be issued through TRACES. The applicant must select the EU model certificate that corresponds to the product intended for export and complete Part I.

Part II must be completed by a certifying officer (official veterinarian or an official inspector). However, some information may have to be provided by the applicant in order for Part II to be completed, if applicable. This information could be provided in the form of a manufacturer's declaration when applying for an export certificate.

Certificate

6. Additional information

Exported products transiting through a country may require transit documentation. It is the responsibility of the exporter to ensure that the shipment will be accompanied by all necessary certificates. Please work closely with your importer.

Samples (personal or commercial) of insect products may be subject to the same requirements as regular shipment. It is strongly recommended that the exporter verify these requirements with his importer and / or at the EU border inspection post where the products will be shipped.

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