Operational procedure: Procedure for maintaining food export eligibility lists

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1. Purpose

The purpose of this document is to provide guidelines for Canadian Food Inspection Agency (CFIA) inspection staff on the procedures for maintaining food export eligibility lists.

This operational procedure is limited to the Food Import Export Division (FIED) food export lists and export lists belonging to importing countries for which a FIED recommendation is required. It also applies to the list of meat establishments handling pet food.

This operational procedure does not apply when a country has a specific process for addition, amendment or removal to an eligibility list (for example: Operational procedure: completion of CIFER registration of Canadian establishments that export high and medium risk food products to China).

This document is intended to be used in conjunction with CFIA guidance documents as referenced in section 3.

2. Authorities

The inspection powers, control actions and enforcement actions authorized by the above legislation are identified and explained in the Operational guideline – Food regulatory response guidelines.

3. Reference documents

4. Definitions

For the purposes of this document, the term "licence holder" may be used in a broad sense, and may include any legal representative of the licence holder (HACCP coordinator, for example).

5. Acronyms

Acronyms are spelled out the first time they are used and are shown in the Food business line acronyms list.

6. Operational procedure

Overview

Some foreign countries require that the Safe Food for Canadian (SFC) licence holders conducting export trade-related activities are identified on a list before they allow the import of food products into their country.

It is important that these lists are kept current to enable the export of Canadian food products. Amendments to the lists may include the addition or removal of a licence holder, establishment, food product, process categories or species exported.

Licence holders, CFIA staff or the foreign competent authority (FCA) may request amendments to the export eligibility lists. Licence holders can request to be added or removed from a CFIA export eligibility list by submitting a written request and the required documentation if applicable. The CFIA may take action to remove a licence holder from an export eligibility list if it is determined that they no longer meet CFIA requirements or those of the importing country.

6.1 Request initiated by a licence holder

6.1.1 Adding a licence holder to a list or amending an eligibility list

Receiving the request

Licence holders must submit a request to be added or to amend an export eligibility list in writing to the CFIA inspector. The request must include country-specific and supporting documentation, if applicable (for example: laboratory results, facility floor plan, production flow chart, etc.).

For meat products, the licence holder must use Annex I – Application for establishment approval. They must complete Part 1 of this annex and forward it with the applicable written control program to the CFIA inspector.

For Canadian federally licensed meat establishment producing pet food in the edible area, the licence holder must follow section Producing pet food in edible areas in Canadian Federally Licensed Establishment.

Licence holders must comply with all specific requests from the importing country (for example, a PDF colour copy of the original application). They must submit their applications in English unless otherwise instructed by FIED.

Note: The licence holder must present a request to CFIA to update the eligibility lists when:

  • their production changes and/or
  • the establishment's owner changes and the new owner intent to maintain their export activities
Verifying the request

The inspector must review the requirements and procedures specific to the program and the importing country. The requirements by countries are available in the food export requirements library for non-meat products and in Meat Export Electronic Certification (E-cert) (accessible only on the Government of Canada network) for meat products. An eligibility verification checklist for non-meat products is available in section 7.0.

The inspector ensures that the documentation provided is complete. The inspector may conduct the licence (permission) verification task in order to verify that the applicant possesses a valid SFC licence with the appropriate activities (for example preparing food for export and exporting food). The inspector will contact the licence holder if additional details are required to process the application. Where required, the inspector may liaise with their supervisor, an area operations specialist (AOS), or the Operational Guidance and Expertise Division.

For meat products, the inspector must also complete the relevant task in Annex 2: Export food-implementation verification tasks of Operational procedure: Food preventive control inspection – Implementation verification. Where the task is compliant, the inspector completes Part 2 of Annex I and forwards it with a copy of the inspection report and the documentation provided by the licence holder to the (AOS). If the inspection task(s) cannot be completed due to missing or non-compliant procedures, the inspector notifies the licence holder and keeps the inspection task(s) open until all requirements are met and part 2 of Annex I is signed. No inspection report should be issued for this situation.

For Canadian federally licensed meat establishments producing pet food in the edible area, the inspector must review the control program. The inspector will verify the control program using the applicable task in Appendix 1: PC and traceability elements and sub-elements of the Food preventive control and traceability – Compliance verification system and in Annex 2: Export food-implementation verification tasks of Operational procedure: Food preventive control inspection – Implementation verification. Where the tasks are compliant, the inspector will forward the inspection reports to the AOS with a confirmation of their assessment, indicating that the license holder's  program is acceptable.

Submitting the request to Food or Meat Establishment Export lists-IAB/FIED on SharePoint

For non-meat products, the inspector submits and assigns the request to the Food Establishment Export lists-IAB/FIED group via SharePoint, using the electronic Request for Action Form (e-RAF) (accessible only on the Government of Canada network).

For meat products, the AOS verifies that the documentation is compliant, signs part 3 of Annex I, submits and assigns it to the Meat Establishment Export Lists-IAB/FIED group via SharePoint, using the electronic Request for Action Form (e-RAF) (accessible only on the Government of Canada network).

For Canadian federally licensed meat establishments producing pet food in the edible area, the AOS will submit the request to the'Meat Establishment Export Lists-IAB/FIED' group via SharePoint, using the electronic Request for Action Form (e-RAF) (accessible only on the Government of Canada network).

An e-RAF must be submitted to FIED for each country or commodity that requires changes. For example:

The inspector must also provide the following information on the e-RAF application:

  • SFC license holder's name
  • DSDP Establishment identification number EST-XXXXX
  • Establishment ID number
  • Name and address of the establishment (also doing business if applicable)
  • Commodity (for non-meats products)

6.1.2 Voluntary removal from an eligibility list

Receiving the request

Licence holders must submit a request in writing to the CFIA inspector when they no longer wish to export to a country or can no longer meet export requirements. They may request to have their establishment, product, process category or animal species removed from an eligibility list. The holder must specify, among other things, the effective date of the change, the commodity, the animal species (if applicable) and the countries concerned.

Products produced before the licence holder surrenders their SFC licence remains eligible for export unless the importing country decides otherwise. It is the responsibility of the exporter to verify that the product remains eligible. 

Submitting the request to Food or Meat Establishment Export lists-IAB/FIED on SharePoint

For non-meat products, the inspector submits and assigns the request to the Food Establishment Export lists-IAB/FIED group via SharePoint, using the electronic Request for Action Form (e-RAF) (accessible only on the Government of Canada network).

For meat products, the inspector forwards the written request to the AOS who will submit and assign it to the Meat Establishment Export Lists-IAB/FIED via SharePoint, using the electronic Request for Action Form (e-RAF) (accessible only on the Government of Canada network).

The inspector must also provide the following information on the e-RAF application:

  • SFC license holder's name
  • DSDP Establishment identification number EST-XXXXX
  • Establishment ID number
  • Name and address of the establishment (also doing business if applicable)
  • Commodity (for non-meats products)

6.2 Removal request initiated by the CFIA

For non-meat products, an inspector may initiate a request to remove an exporter, a distribution chain or a product when a licence holder no longer meets the export requirements. The inspector notifies in writing the involved parties that a request will be sent to FIED. The inspector submits and assigns the request to the Food Establishment Export lists-IAB/FIED group via SharePoint, using the electronic Request for Action Form (e-RAF) (accessible only on the Government of Canada network).

For meat products, the manager can recommend a request for removal from an export eligibility list when export requirements have not been met and the procedure outlined in the meat establishment licencing and registration requirements bullet 5(2) has been followed. This request can affect a licence holder, an establishment, a product, a process category or an animal species. The manager will submit the request to the AOS who will submit and assign it to the Meat Establishment Export Lists-IAB/FIED group via SharePoint, using the electronic Request for Action Form (e-RAF) (accessible only on the Government of Canada network).

The inspector must also provide the following information on the e-RAF application:

  • SFC license holder's name
  • DSDP Establishment identification number EST-XXXXX
  • Establishment ID number
  • Name and address of the establishment (also doing business if applicable)
  • Commodity (for non-meats products)

For all commodities, products which were manufactured, processed or treated before withdrawal from the list are eligible for export, considering that they meet SFC and importing country requirements.

Note: Animal health restrictions may also lead to removal from an export eligibility list.

6.2.1 Loss or voluntary surrender of SFC licence

When a licence holder loses or surrenders their SFC licence (for example when an establishment is closed), the CFIA Inspector must immediately request the removal of the establishment from the eligibility lists where it appears.

For non-meat products, the inspector submits and assigns the request to Food Establishment Export lists-IAB/FIED group via SharePoint, using the electronic Request for Action Form (e-RAF) (accessible only on the Government of Canada network).

For meat products, the inspector submits the request in writing to the AOS who will forward the information to the Meat Establishment Export Lists-IAB/FIED group via SharePoint, using the electronic Request for Action Form (e-RAF) (accessible only on the Government of Canada network). FIED will update the eligibility lists on E-cert (accessible only on the Government of Canada network) once the request has been completed.

The inspector must also provide the following information on the e-RAF application:

  • SFC license holder's name
  • DSDP Establishment identification number EST-XXXXX
  • Establishment ID number
  • Name and address of the establishment (also doing business if applicable)
  • Commodity (for non-meats products)

For all commodities, products produced before removal dates from eligibility list remain eligible for export, however the FCA may decide otherwise.

6.3 Removal request initiated by a FCA

FCA may contact FIED directly to request the removal or the temporary suspension of a licence holder, establishment, product, a process category or species from the export eligibility list.

FIED will update the export list maintained by the CFIA and will inform operations staff and industry as applicable.

6.4 Request for action to FCA – amendment, addition or removal

FIED will make recommendations to the FCA regarding the request for changes to the specific export eligibility list.

FIED enters the date on which the request was sent to the FCA in SharePoint. The inspector can check the status of the request using the SharePoint enquiry identification number received via email.

Where an eligibility application is submitted to the FCA, the time required for an establishment to become eligible to export can vary significantly from country to country. Products will not be eligible for export until the list has been updated. Any production prior to this date will not be eligible for export.

The eligibility list will be updated by the foreign country or by FIED, depending on who owns the list.

Note: For export eligibility lists owned by FCAs, not always a notice is given when these lists are updated. Licence holders are responsible for liaising with their contact person to check the status of their application in the importing country or for consulting the link to the export lists on the external website.

7. Annex

Eligibility verification checklist (for non-meat products)

Request to add or modify an eligibility list

Select, if applicable:

  • Box The written request submitted to CFIA contains the information (name of country, commodity, etc.) and the amendments are clearly stated.
  • Box Country specific application (if required) submitted
  • Box All supporting documents are provided (for example, HACCP compliance checklist for export of dairy products to EU)

Eligibility requirements

Select, if applicable:

  • Box Product intended for export is processed by a SFC licence holder.
  • Box The exporter (if requesting certificate) has a valid SFC licence and a preventive control plan (PCP) including:
    • Box export controls
    • Box certificate controls
    • Box controls on stamps, seals and stickers
    • Box traceability controls
  • Box The product intended for export meets the specific commodity requirements of the importing country. For example:
    • Box Product is eligible for export
    • Box Product is labelled in a language required by the importing country
    • Box Product is stored in an establishment that appears on the approved list

e-RAF submission

Select, if applicable:

  • Box One e-RAF is submitted per country/commodity
  • Box e-RAF title contains: [Action: addition, amendment or removal][establishment name & number ID] to [Country][Commodity list].
  • Box Supporting documents are attached to e-RAF.

For general inquiries related to this operational guidance document, please use the established communication channels, including submitting electronic Request for Action Form (e-RAF) (accessible only on the Government of Canada network).

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