Fact sheet - Feed importers
The information in this document is based on requirements set out in the proposed Feeds Regulations, 2022 (the "regulations"). The information is intended to help regulated parties understand the requirements within the regulations once they come into force. The proposed requirements are subject to change as the regulatory process advances through its various stages. In the interim, current laws applicable to livestock feed in Canada continue to apply.
The proposed Feeds Regulations, 2022 will impact a variety of stakeholders, including:
- single ingredient feed manufacturers and suppliers
- mixed feed manufacturers and suppliers (for example, commercial feed mills, specialty feed manufacturers, etc.)
- rendering facilities manufacturing livestock feed ingredients
- feed retail outlets
- livestock producers (on-farm feed mills)
- feed importers
- feed exporters
Feed importers are businesses that import feed into Canada. The proposed Feeds Regulations, 2022 will apply to those who import, export, manufacture and sell feed. Depending on the scope of their business, a feed importer may be involved in more than one feed-related activity.
All imported feeds must either be registered or must be imported by a licence holder. If the imported feed is registered, the importer may also choose to get a licence. The imported feed must meet Canadian standards and labelling requirements. In addition, the importer of a feed must be able to demonstrate that it was manufactured under a preventive control plan.
The Feeds Act sets out the authority for licencing, while the proposed Feeds Regulations, 2022 set out exactly who needs a licence. Imported feeds will fall into 2 categories:
This fact sheet applies to you if:
- you import feed for commercial use into Canada and you directly sell that feed or you store, process, package, label or deliver the imported feed
- you import a feed for feeding to your own livestock
Feeds that are imported for commercial use
The authority for licencing is limited to feeds that have been imported for sale (that is, imported for commercial use). This would include feeds imported to be directly resold, or feeds that will be used to make other feeds that will be sold.
Given this authority, licences are required for conducting activities (store, process, package, label or deliver) with a feed that has been imported for sale. There is an exception to this for registered feeds, which means that in the case of feeds imported for commercial use, the importer may choose to either register the feed or obtain a licence.
New regulatory requirements that apply to you
- Hazard analysis and preventive control plans
- Licences
- Traceability and record-keeping
- Product registration
- Product labelling
Hazard analysis and preventive control plans
You must prepare, keep, maintain and implement a written preventive control plan (PCP) for any activities you perform with the imported feed. In addition, you must be able to demonstrate that the imported feed was manufactured, stored, packaged and labelled under conditions which provide the same level of protection as if those activities took place domestically under a preventive control plan.
This is a new requirement. Please refer to the preventive feed safety controls fact sheet and hazard identification and analysis fact sheet for additional information.
Licences
If the feed you are importing is not registered, you will require a licence.
This is a new requirement. Please refer to the licensing fact sheet for additional information.
Traceability and record-keeping
You will be required to keep records of the feeds you import for sale, including when and where they came from, as well as who you ship or sell the feed to. The records must include the name of the feed, the lot number, the date, and contact information.
This is a new requirement. Please refer to the traceability fact sheet for additional information.
Product registration
It will depend on the types of feeds you import into Canada, as you will still be required to register certain types of mixed feeds under the proposed Feeds Regulations, 2022. Therefore, it is your responsibility to verify, prior to importation, if the imported feed requires registration.
In addition, you may choose to register a feed in order to import it without a licence.
This is an amended requirement, and will reduce the number of mixed feeds requiring mandatory product registration.
Please refer to the feed approval and product registration guidance for the proposed Feeds Regulations, 2022 for additional information.
Product labelling
You will need to ensure the feeds you import meet all labelling requirements outlined in the proposed Feeds Regulations, 2022. Feeds that are manufactured outside of Canada and imported into Canada must meet the same labelling requirements as a feed that is produced domestically. You will be responsible for labelling the imported feed properly, in collaboration with the foreign manufacturer.
This is an amended requirement. Please refer to the labelling guidance for the proposed Feeds Regulations, 2022 for additional information.
Feeds that are imported for feeding your own livestock
Feed that is imported for feeding your own livestock is not subject to the licencing requirements. However, it must be registered before it can be imported. Note that a licence may be issued on a voluntary basis.
Feed that is imported for research or experimental purposes is not subject to the licencing requirements, but must be approved before it can be imported.
New regulatory requirements that apply to you
- Hazard analysis and preventive control plans
- Licences
- Traceability and record-keeping
- Product registration
- Product labelling
Hazard analysis and preventive control plans
You must prepare, keep, maintain and implement a written preventive control plan (PCP) for any activities you perform with the imported feed fed to your own livestock. In addition, you must be able to demonstrate that the imported feed was manufactured, stored, packaged and labelled under conditions which provide the same level of protection as if those activities took place domestically under a preventive control plan.
This is a new requirement. Please refer to the preventive feed safety controls fact sheet and hazard identification and analysis fact sheet for additional information.
Licences
You are not required to have a licence if the feed is imported for feeding to your own livestock. This is not a change from the current requirements.
Traceability and record-keeping
You will be required to keep records of the feeds you import for feeding to your own livestock, including when you received the feed and where it came from. The records must include the name of the feed, the lot number, the date, and contact information.
This is a new requirement. Please refer to the traceability fact sheet for additional information.
Product registration
Feeds that are not imported by a licence holder must be registered. This is not a change from the current requirements.
You are responsible for verifying if the imported feed requires registration prior to importation.
Please refer to the feed approval and product registration guidance for the proposed Feeds Regulations, 2022 for additional information.
Product labelling
You will need to ensure the feeds you import meet all labelling requirements outlined in the Feeds Regulations, 2022. Feeds that are manufactured outside of Canada and imported into Canada must meet the same labelling requirements as a feed that is produced domestically.
Please refer to the labelling guidance for the proposed Feeds Regulations, 2022 for additional information.
Benefits
The proposed Feeds Regulations, 2022 will introduce an outcome-based and risk-based approach to feed safety and compliance through modernized regulatory requirements (hazard identification and analysis, preventive control plans, traceability and labelling requirements) and permissions (feed ingredient assessments and approvals, product registration and licences). The benefits that this new regulatory framework will provide are to:
- safeguard feed and the food production continuum
- attain the most effective and efficient balance between fair and competitive trade in the market; and
- minimize regulatory burden
As an importer of feed, it is your responsibility to make sure that the feed you import into Canada meets the same regulatory requirements outlined in the proposed Feed Regulations, 2022 as a feed produced within Canada. Ensuring that imported feeds meet the same standards as feeds manufactured domestically helps to protect animal health and contributes to food safety in Canada. Whether imported feeds are registered or imported by a licence holder, the same conditions apply with respect to identifying hazards, putting in place preventive control plans, meeting safety standards, and proper labelling.
Feed being imported into Canada may need to meet other import requirements related to plant health and animal health. These import requirements are in place to prevent the spread of diseases and pests that could be introduced into Canada through the importation of feed. The specific requirements for the importation of commodities regulated by the CFIA can be found in the Automated Import Reference System (AIRS).
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