Improved Food Inspection Model
Revised Draft

5.0 Imports

The licensing conditions proposed under the model apply equally to importers.

Some example strategies can be found in see Annex B sub-element 1.3 of Element 1: Import control outcome: Performance criteria.

5.1 Preventive control plans

Food products entering Canada must meet all regulatory requirements for safety, nutrition, composition, labelling, packaging and quality, as applicable. Importers do not have direct control over food production and would therefore need to develop other strategies to address risks.

Importers would need to include elements of the preventive control plan that apply to their operation (see Annex B). For example, importers without facilities would not be expected to address physical structure and maintenance. However, all importers would, at a minimum, need to include the following elements in their preventive control plans:

  • Element 1: Product and Process
  • Element 7: Traceability, recall and complaints

Importers who are involved in further handling or repackaging of food would need to address all seven elements of the preventive control plans.

5.2 Inspection

The proposed inspection approach in section 4.2 would be used to verify the effectiveness of the importer’s preventive control plan. The CFIA would use product surveillance and foreign country audits as a tool to determine the level of compliance for products entering Canada.

When notified by an importer of non-compliant product, the CFIA would take steps appropriate to the nature and severity of the issue to prevent further product from entering the country until corrective action had been taken at the source. The CFIA would notify all known importers of the affected product through an import alert and the competent authority in the exporting country.

The importer would also be required to submit evidence of compliance before the CFIA would give permission to resume importation of a food commodity.

Depending on the nature and severity of non-compliance, the CFIA might review technical arrangements or other bilateral agreements to determine whether amendments would be required.

5.3 Surveillance

Surveillance of imported food is a key activity when

  • food is prepared outside the country where requirements or competent authority oversight is not comparable, or
  • on-site verification of the processing controls cannot be conducted by the CFIA.

The CFIA would use product surveillance as a tool to identify gaps and trends, to determine sector performance, or to provide baseline information such as the level of chemical contaminants in certain foods. Analysis of this type of information would provide a mechanism for continuous improvement through activities such as adjusting the level of oversight priorities, changing standards or requirements, and planning work.

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