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The Strengthened Fish Import Program
Importer Information Session

PDF (356 kb)

Purpose of the Session

  • To explain the strengthened Canadian Fish Import Program (IP).
  • Help you understand your responsibilities as a fish import licence holder.
  • Clarify the requirements which must be met by fish import licence holders.
  • Identify the tools available to assist you in meeting these requirements.

Outline

  • Background
  • Documents
  • Policy
  • Regulatory Responsibilities
  • Regulatory Verification
  • The Inspection of Imported Fish
  • Implementation of the Strengthened IP

Background

In 2006, CFIA conducted a review of the Fish IP and noted the following:

  • The regulations for importing fish into Canada are sound.
  • Imports of fish product have shifted to farmed, ready-to-eat and specialty products.
  • Importer responsibilities were not clearly defined and understood.
  • Policy manuals were not clear and needed updating.

From this review, the CFIA determined that:

  • The IP needed to be strengthened.
  • The IP could be strengthened without regulatory changes.

The first step in the process was to re-write documents:

  • To clarify importer responsibilities and CFIA's role.
  • Outline the IP requirements based on the intent of the current regulations.
  • To include tools for assisting importers in meeting the requirements.

Documents - Regulations

  1. Fish Inspection Act and Regulations
  2. Food and Drugs Act and Regulations
  3. Consumer Packaging and Labelling Act and Regulations
  4. Canadian Food Inspection Agency Act and Fee Notice

Documents

The IP is now described through a series of new documents that are:

  • Tailored to specific audiences such as: basic importers, QMPI importers, CFIA inspectors or all interested parties.
    • Regulatory directives
    • Process documents
    • Guidance documents
    • Procedural documents
    • Standards
  • Web-based so they can be easily updated and linked to other useful information.
  1. Canadian Regulatory Requirements for Fish Import Licence Holders (Basic Importers).
  2. Canadian Regulatory Requirements for Quality Management Program Import (QMPI) Licence Holders.
  3. QMPI Reference Standard.
  4. Process Control Document Requirements.
  5. The Fish Import Program Policy.
  6. The Fish Import Program Regulatory Verification Process.
  7. Product Inspection of Imported Fish (process).
  8. Food Program Enforcement Strategy: Fish and Seafood.

Policy

Policy Statement

The objective of the Fish Inspection Act and Regulations is to provide reasonable assurances that fish and seafood products imported into Canada for human consumption and commercial purposes are safe and meet regulatory requirements.

Key Principles

  • Licenced importers are responsible to ensure that they import fish and seafood products that meet all applicable regulatory requirements.
  • CFIA verifies compliance and works with Canada's major trading partners to provide reasonable assurances of product safety and compliance.
  • The Canadian Fish Import Program incorporates a risk based approach and provides importers with flexibility to demonstrate product compliance.

Regulatory Responsibility Structure

Click on image for larger view
Schematic of responsibility structure for Fish Import Program
Schematic - Fish Import Program Responsibility Structure

Importer Responsibilities

Import Licence Holders are required to know and comply with the import licence requirements.

For Basic Importers these requirements are outlined in:

  • The Canadian Regulatory Directive for Fish Import Licence Holders (Basic Importers).

For QMPI Importers these requirements are outlined in:

  • The Canadian Regulatory Requirements for Quality Management Program Import Licence Holders (QMPI).
  • The QMPI Reference Standard.

Licensing

  • Importers must request and receive a licence from CFIA to import fish into Canada.
    • Importers must comply with all requirements.
    • Importers are responsible to import product that is safe and compliant.
    • Importers must understand the product risks.
  • Licences are valid for one year and may not be assigned to another person or company.

Application for a Fish Import License

Sourcing Products

Importers must take affirmative actions to source products that meet Canadian requirements.

Some restrictions may apply to certain species, molluscan shellfish, fish containing meat products, novel fish or endangered species.

What are Affirmative Actions?

Actions taken by importers to obtain confidence that products being imported meet Canadian requirements.

Examples

  • Verifying the Mandatory Inspection List (MIL) (formerly named the Import Alert List).
  • Sourcing from HACCP facilities.
  • Selecting processors regulated by a foreign country competent authority and eligible for exporting fish.
  • Providing processors with a written description of all applicable Canadian standards.

Product Notification, Control, Storage and Identification

  • Importers must notify CFIA and the Canada Border Services Agency (CBSA) of all imports of fish.
  • Importers must ensure product is held for CFIA inspection and is properly stored, packaged and labelled.

Product Inspection Process

  • Importers must make product available for inspection and hold product until released by CFIA.
  • Importers may appeal a CFIA decision or request re-inspection of product.

Service Fees

  • Importers must pay service fees based on the type and quantity of imported fish and the licence type.
  • Failure to pay may result in licence sanctions.

Health and Safety Investigation and Notification

  • Importers must investigate information that questions the safety of an imported product and report confirmed health and safety issues to CFIA within 24 hours.

Records

  • Importers must maintain records for product distribution, complaints, investigations and process control documents.
  • The records must be in English or French and be maintained in Canada for at least 3 years.

Fish Program Updates

  • Importers are responsible for keeping up-to-date on requirements for importing fish.
  • Updates are delivered electronically to those who sign-up at www.inspection.gc.ca.

Requirements Specific to the QMPI

  • QMPI importers must develop and implement a quality management program that meets the requirement of the QMPI Reference Standard.
  • The QMPI program includes responsibilities for performing product inspections on imported products.

Regulatory Responsibility

CFIA's Role

The role of the CFIA is to administer and enforce the regulations pertaining to the importation of fish and fish products.

Part of this role includes assessing importer compliance and program effectiveness as described in the Fish Import Program Regulatory Verification Process Document.

Regulatory Verification Process

The Regulatory Verification Process consists of:

1) The verification of importer compliance through:

  • System Verification
    Verification activities include: review of documents, interviews.
  • Compliance Verification
    Verification activities include: audits, review of records, product inspections.

2) The Verification of the Fish Import Program through:

  • Program Verification and Program Integrity
    Verification activities include: monitoring and surveys, review of CFIA's level and consistency of the program delivery.

Regulatory Verification Process - Compliance Verification

How will the CFIA enforce compliance?

Prior to issuing an initial basic import licence?
By interviewing applicants to verify that they understand the licensing requirements and their responsibilities.

After initial licensing?
By reviewing records, importer compliance history and inspecting products. This review occurs annually when licences are to be renewed or on an issue-driven basis.

What happens when an importer fails to meet regulations?
Importers will be required to take corrective measures.

The CFIA may take enforcement actions such as:

  • Warning letters.
  • Suspension, revocation or refusal to issue a licence.
  • Prosecution.
  • Product action (eg; refused entry, removal, seizure).

These measures are described in the Food Program Enforcement Strategy: Fish and Seafood Document.

The Inspection of Imported Fish

All imported fish is subject to inspection.

The CFIA inspects imported fish to:

  • Verify that importers are importing compliant product.
  • Identify emerging product issues.
  • Verify the effectiveness of the Fish Import Program.

The Inspection of imported fish products is a risk based inspection regime and takes into consideration:

  • The risks associated with the product based on the species and processing method.
  • The compliance history of the product and processor.
  • The compliance history of the importer.

Species and Processing Risk Groups

Under the product inspection regime, species groups and processing groups have been created based on commonly associated risks/hazards.

These groupings are used to:

  1. Determine testing requirements.
  2. Determine required process control information.
  3. Identify products on the Mandatory Inspection List MIL.

Species Risk Groups

Risks/Hazard based on Species Group and Production method
  Scom- broids Carni- vores Carni- vores/
Scombroids		 Sal- monids Crustaceans Molluscan Shellfish Tropical Reef Fish Other Fish
Meat/Organ, Oil, Roe
Contaminants/ Heavy metals		   X X          
Meat/Organ, Oil, Roe
Therapeutants (Farmed Production only)		   X X X X     X
Meat
Histamine		 X   X          
Meat
Marine Toxins		           X X  
Meat
Sanitary waters		           X    

The Inspection of Imported Fish

Product Risk Groups

Product Type/Processing

  • Canned - Sterilized
  • Ready to Eat (RTE)
    • RTE - Cooked
    • RTE - Pasteurized in a container
    • RTE - Safety parameters
    • RTE - Without safety parameters or heat and without heat treatment
  • Non RTE
    • Non RTE - Live
    • Non RTE - Raw
    • Non RTE - With multiple Species or feed commodities
    • Non RTE - Breaded/Battered

Hazard / Risk Structure

Schematic of Product Hazard Structure
Schematic - Fish Import Program Product Hazard Structure

Inspection Components

The product inspection regime consists of the following:

  1. Risk-based sampling of good order product.
    The Annual Sampling Plan
  2. Mandatory inspection of previously rejected product.
    Mandatory Inspection List (MIL)
  3. Mandatory proof of compliance for product that present a potential risk.
    Enhanced Inspection List (EIL)
  4. Monitoring, surveys and special projects.

Annual Sampling Plan

Sets out the number and type of tests to be conducted annually on products (excluding MIL).

Targets inspection of approximately 5% of lots imported annually.

Higher risk products are inspected more often based on:

  • Species and Product Risk.
  • The importer's product compliance history.
  • Product history (processor, country of origin, etc.).

A 5% frequency is reasonable because importers are required to take affirmative actions.

Annual Sampling Plan Process

Click on image for larger view
Schematic of Annual Sampling Plan
Schematic - Annual Sampling Plan

Mandatory Inspection List (MIL)

The MIL lists imported fish products which were found to be non-compliant with Canadian requirements following an inspection.

Subsequent imports are subject to mandatory inspection for the test(s) indicated on the MIL.

Inclusion on MIL is linked to Species Risk Group or Product/Processing Risk Group and the processor.

Found on CFIA website at: www.inspection.gc.ca

Adding a Product on the Mandatory Inspection List (MIL)

Schematic of Adding a Product on the Mandatory Inspection List
Schematic - Adding a product on the Mandatory Inspection List

Mandatory Inspection List Inspection Process

Schematic of Mandatory Inspection List Inspection Process

Schematic - MIL Inspection Process

Enhanced Inspection List (EIL)

Lists imported fish products which may be unsafe or unwholesome based on information collected by the CFIA.

Imports subject to the EIL require mandatory proof of product compliance or to be tested by the CFIA or an SCC accredited lab for the test(s) identified.

The CFIA may still inspect a product for which proof of compliance has been provided.

EIL will be posted on the CFIA website.

EIL Inspection Process

Click on image for larger view
Schematic of Enhanced Inspection List
Schematic - Enhanced Inspection List

How the inspection components fit together

Click on image for larger view
Schematic of Decision Making Process
Schematic - Decision Making Process

Fish Import Notification FIN

Accurate information on the FIN form is mandatory and necessary in order to:

  • Determine whether the product is to be inspected and;
  • Determine the testing requirements.

Updates have been made to the FIN form to help ensure all required information is received from importers. Example:

  • Species and Product Risk Categories
  • Taxonomic Serial Number
    • Will be available through the CFIA Fish List and can be found on the Canadian Biodiversity Information Facility website at: http://www.cbif.gc.ca

CFIA Testing Priorities

Reason for Inspection Priority
Annual Sampling Plan Standard
Mandatory Inspection List Low
Enhanced Inspection List - no proof of compliance Low
Enhanced Inspection List - with proof of compliance (verification) Standard

This does not include complaint samples or investigation samples which are always the highest priority.

Implementation of the Strengthened Fish Import Program

The transitional documents currently on the website will be finalized on April 1 2009.

As of April 1, all importers must fully comply with the requirements as outlined in the new fish import program documents.

Starting October 1 2009, importers must be able to demonstrate compliance to these requirements in order to renew their import licences.

Date Modified: 2009-07-22

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