Operational procedure: Procedure for maintaining food export eligibility lists

On this page

• 1. Purpose
• 2. Authorities
• 3. Reference documents
• 4. Definitions
• 5. Acronyms
• 6. Operational procedure
  • 6.1 Request initiated by a licence holder
  • 6.2 Removal request initiated by the Canadian Food Inspection Agency
    • 6.2.1 loss or voluntary surrender of Safe Food for Canadian licence
  • 6.3 Removal request initiated by a foreign competent authority
  • 6.4 Request for action to foreign competent authority – amendment, addition or removal
• 7. Annex: Eligibility verification checklist (non-meat products)

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.

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

2. Authorities

• Safe Food for Canadians Act (SFCA)
• Safe Food for Canadian Regulations (SFCR)

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

• Industry guidance – Food Export Control Policy
• Industry guidance – Exporting food: A step-by-step guide
• Industry guidance – Food export registers and lists
• Regulatory requirement: Trade (Safe Food for Canadians Regulations, Part 2)
• Industry guidance – Food-specific export requirements
• Industry guidance – Food export requirements library
• Industry guidance – What to consider before applying for a Safe Food for Canadians licence
• Meat Export Electronic Certification (accessible only on the Government of Canada network)
• Guide on how to fill out the online Electronic Request for Action Form (e-RAF) (accessible only on the Government of Canada network – RDIMS 9203397)
• Electronic Request for Action Form (e-RAF) accessible only on the Government of Canada network)
• Standard Inspection Process (SIP)
• Operational procedure: Food preventive control inspection – Implementation verification

4. Definitions

• Safe Food for Canadian Regulations: Glossary of key terms
• My CFIA glossary of terms
• Integrated Agency Inspection Model (IAIM): Glossary (Appendix F)

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

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

• Receiving the request
• Verifying the request
• Submitting the request to Food Establishment Export lists-IAB/FIED on SharePoint

Receiving the request

Licence holders must submit in writing to the CFIA inspector any request to add or amend an export eligibility list. 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 the Annex I – Application for establishment approval. They must complete Part 1 of this annex, and forward it with applicable written control procedures to the CFIA inspector.

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
• when 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.

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, or the Operational Guidance and Expertise Division.

For meat products, the inspector must also complete the relevant task in the 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 Area Operations Specialist.

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

For non-meat products, the inspector submits the request to FIED via SharePoint, using the electronic Request for Action Form (e-RAF) (accessible only on the Government of Canada network).

For meat products, the area operations specialist verifies that the documentation is compliant, signs part 3 of Annex I and submits it to FIED 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 submit only one e-RAF to add multiple fish species to an eligibility list
• For the United States, the area operations specialist must submit an e-RAF to add or remove a process category or animal species to Annex W: list of establishments eligible to export to the United States and species and processing category information

Voluntary removal from an eligibility list

• Receiving the request
• Submitting the request to Food Establishment Export lists-IAB/FIED on SharePoint

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 Establishment Export lists-IAB/FIED on SharePoint

For non-meat products, the inspector submits the request to FIED 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 area operations specialist who submits it to FIED via SharePoint, using the electronic Request for Action Form (e-RAF) (accessible only on the Government of Canada network).

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 the involved parties that a request will send to FIED. The inspector submits the request to FIED 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 in point 5(2) of the meat establishment licencing and registration requirements have 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 area operations specialist who will transfer it to FIED via SharePoint, using the electronic Request for Action Form (e-RAF) (accessible only on the Government of Canada network).

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 the request to FIED 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 area operations specialist who forward the information to FIED via SharePoint, using the electronic Request for Action Form (e-RAF) (accessible only on the Government of Canada network). FIED updates the eligibility lists on E-cert (accessible only on the Government of Canada network) once the request has been completed.

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, no 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)

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).