Policy on the export of non-compliant food
Food does not always have to meet all the requirements of the Safe Food for Canadian Regulations (SFCR) if it is intended to be exported. SFCR section 16(1) outlines the requirements that must be met for the export of food non-compliant to the SFCR.
If you manufacture food that does not meet the SFCR, you will be required to keep written documents of the foreign requirements and/or specifications which the food is being manufactured to and the associated lot information. Please consult A guide for preparing an Export Certification Control Program (ECCP) plan for more information on the type of documents you must keep.
When you are manufacturing food where there is no requirement in the foreign country, the only unmet SFCR requirements allowed are those related to product standards, grades, food additives or Canadian container sizes and labelling as specified in SFCR section 16(1)(b).
The CFIA will not permit the export of foods that are marketed in a deceptive, false or misleading manner. It is mandatory to apply or attach a label to the food with the word "Export" or "exportation." Exporters must be able to trace the product to ensure that it will not end up in the Canadian marketplace.
Even though you can manufacture food that does not meet SFCR requirements, the food product must always be manufactured in Canada by a SFC licence holder under sanitary conditions in compliance with the Safe Food for Canadian Act (SFCA) and SFCR.
Non-compliant product should never jeopardize Canada's trade reputation. Canada protects countries without food safety requirements with a minimum requirement that permits only products compliant with Canadian regulations to be exported.
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