The Regulation of Imported Fish and Seafood Products in Canada

Under the CFIA's Fish Import Inspection Program, importers of fish and seafood for human consumption and for commercial sale must hold either a Fish Import Licence or a Quality Management Program Import Licence from the CFIA.

Importers are responsible for ensuring that their products meet Canadian regulatory requirements including the food safety standards established by Health Canada. Non-compliant shipments are not permitted to be sold in Canada.

The CFIA regulates over 1000 fish and seafood importers, and audits and inspects importers to ensure they are meeting the conditions of their licence.

If a shipment fails to meet Canadian regulatory requirements and the product cannot be brought into compliance by the importer, the entire shipment is removed from Canada or destroyed. In addition, the foreign processor is put on CFIA's Mandatory Inspection List (MIL) and incoming products are inspected at a rate of 100% until four consecutive shipments comply with Canadian requirements.

If the CFIA identifies products that were not properly dealt with by an importer, enforcement action is taken which may include recalling the product from the market, revoking the import licence and/or prosecution under the Fish Inspection Act and Regulations and/or Food and Drug Act and Regulations.

CFIA Inspection

Fish and seafood products imported into Canada are inspected to prevent the marketing of unsafe, unwholesome or mislabelled products.

Canada carries out risk assessments on specific products and is responsible for enforcing the guidelines set by Health Canada.

The CFIA uses a risk-based approach in developing an annual sampling plan for the inspection of imported fish and seafood products. The annual sampling plan is based on an overall sampling target of 5 per cent of the estimated annual imported lots and is developed based on a review of the following information:

• Food safety risk
• History of compliance of a particular product
• Environmental scanning information.

Imported products are randomly selected for testing in accordance with the annual sampling plan targets. In addition the first shipment from a producer who has not shipped product in the past 2 years will be inspected. This risk-based approach provides the CFIA a high rate of confidence in the compliance level and safety of imported products.

Shipments selected for inspection are sampled according to internationally recognized procedures and standards of CODEX Alimentarius. The CODEX Alimentarius Commission is the organization responsible for setting international food safety standards. This approach provides assurance that the sampling is representative of the shipment.

Expert CFIA and accredited private laboratory staff use state-of-the-science technology to provide specialized testing. These food laboratories test for a wide range of chemical and biological contaminants such as veterinary drug residues, pesticides, metals, bacterial pathogens, marine toxins, and food additives.

When the CFIA is made aware of problems in exporting countries or when test results show the emergence of a problem related to a particular product, processor, or country of origin, the CFIA may put the particular product on CFIA’s Enhanced Inspection List (EIL). For product on the EIL, the importer must provide proof of product compliance or the product will be held and tested by CFIA.

All licenced fish importers must meet the following requirements:

• Import product that is safe and meets all Canadian regulatory requirements;
• Notify the CFIA of every import shipment within 48 hours of arrival;
• Make every shipment available for inspection prior to distribution and sale in Canada;
• Keep accurate and complete records of imported shipments so that shipments can be easily traced;
• Obtain information on the manufacturing processes and controls used in the production of all ready to eat and canned products which they import;
• Investigate any potential problems with the safety of their product and notify CFIA within 24 hours of confirmed health and safety issues; and
• Pay an annual import licence and inspection service fees for their imported product.

Additionally, importers holding a Quality Management Program Import (QMPI) licence must meet the following requirements:

• Develop an acceptable quality management program import (QMPI) plan,  describing the controls applied by a QMPI importer to meet the requirements of the Fish Inspection Regulations;
• Implement and comply with their written QMPI Plan, once the CFIA determines that it meets all the requirements of the QMPI Reference Standard; and
• Forward all product inspection results to the CFIA.

P0579E-07
June 29, 2009