Guide for preparing an Export Control Plan (ECP): Developing your ECP
1. Controls for meeting Canadian export requirements and conditions
In order to demonstrate compliance with the requirements outlined in the SFCR, exporters must prepare, keep, and maintain the following:
1.1 Preventive control plan (PCP)
The PCP is the written document that outlines how you ensure that food is safe and fit for consumption and conforms to consumer protection requirements. You are required to have a PCP that meets the applicable requirements detailed in Part 4 of the SFCR, if you request food export certificates or endorsement to an export eligibility list. The activities you conduct, relative to the food being exported, will determine the content of the PCP. You may integrate ECP elements into your PCP or keep the ECP elements in a separate document if you choose.
A licensed exporter that does not manufacture their own products needs their PCP to address how they source the food that they export. A domestic food preparer needs their PCP to encompass the food safety controls in place for their operations. See Preventive control plan (PCP).
Product compliance
When you do not prepare the products you export
You must source your food commodities from an SFC licence holder.
To verify that the food commodity meets the domestic requirements for consumer protection and food safety, you source from a valid SFC licence holder. Your plan describes how you verify that the licence is valid, and includes the frequency of how often you verify.
Example of PCP controls that verify that the food commodity meets domestic food safety and consumer protection requirements:
Your PCP details, the name, address, and licence number of the licence holder that prepares the food commodities you export. The exporter verifies that the supplier has provided proof of a valid SFC licence with appropriate activities and commodities.
Example of documents/records:
A copy of the licence summary with the activity and commodity details, a search of the SFC licence registry, or a letter of guarantee.
You verify that the SFC licence of the preparer:
- is not expired, cancelled or suspended when the products were prepared
- lists the licensable activities conducted on the exported product
- lists the commodity group that is being exported, for example Dairy, in relation to the "preparing food for export" activity
Your PCP also describes in detail how and how often you verify that the licence holder that prepared the food commodity has identified and controlled the food safety hazards related to their process.
Examples of PCP controls that verify that the preparer is meeting the food safety requirements:
Conduct your own evaluation of your supplier, or receive an evaluation report from a third party, showing that your supplier continues to meet the requirements set out in section 89 of the SFCR.
Example of records: current supplier evaluation checklist or 3rd party evaluation report
or
Receive an assurance, such as a supplier agreement, from the supplier indicating the product was prepared under conditions which meet the requirements set out in SFCR 89.
Example of records: current agreement from the supplier
Storage Activities
Export consignments that require an export certificate must be stored at a facility that meets Part 4 of the SFCR. It is the responsibility of the exporter to verify the storage activities related to export (receiving, storing, shipping) meet Part 4. When the importing country has a requirement for the storage to be licenced, section 2 of this document describes how to develop controls for this export condition.
SFC licenced storages:
When you use a storage with an SFC licence that includes the activity of storing food, your PCP will detail how and how often you verify that the licence is valid. (see above)
Unlicensed Storages:
If you (the exporter) store the product yourself, you will follow the domestic PCP templates to identify and control the hazards related to receiving, storing, shipping to meet Part 4 of the SFCR. (See below, for examples)
If you use a 3rd party unlicensed storage, you will either:
Conduct your own evaluation of the storage, or receive an evaluation report from a third party, showing that the storage continues to meet the requirements set out in Part 4 of the SFCR.
or
Receive an assurance, such as a supplier agreement, from the storage indicating the storage meets the requirements set out in Part 4 of the SFCR.
For the products that you prepare and also export
Your PCP would include controls for the preparation activities conducted on the product. The PCP must meet the preventive control requirements found in Part 4 of the SFCR. If more than one person prepares the food commodity, follow the guidance under: Food business activities that require a licence under the Safe Food for Canadians Regulations.
Example of a PCP for preparation activities (refer to the following guidance):
For products that you import and plan to export
If you export products that you import, you must verify that the product is considered eligible by the importing county.
Example of a PCP when an exporter is importing products for re-export (refer to the following guidance):
- Importer guide: prepare your preventive control plan
- Preventive control plan (PCP) templates – for importers
CFIA may endorse export certificates or other documents for food commodities that are not prepared in Canada (imported) if the exporter can provide evidence to verify that the export requirements and conditions have been met. This is only possible when not prohibited by the competent authority of the importing country.
For example, if the importing country has a requirement for heat treatment, the exporter is responsible to provide evidence from the manufacturer that verifies the export condition has been met. (see section 2.Controls for meeting Importing country conditions)
More information
1.2 Traceability
Traceability requirements are set out in Part 5 of the SFCR. To meet these requirements you have to trace the movement of the food you export one step back and one step forward. For the activity of exporting, this includes preparing and keeping records that:
- identify the common name of the food, the name and address of the person who manufactured, prepared, stored, packaged or labelled the food and tracking information that traces back to the lot code(s)
- trace the food to the person who provided you with the food, including the date on which the food was provided to you
- trace the food to the person to whom you provided the food, including the date on which you provided the food
- trace the food to each place you moved it before you provided it to another person
Examples of traceability within an ECP
The ECP must include all of the traceability elements listed above. The distribution of the exported food products must be traceable to the first shipping destination and to the preparer of the food commodity to allow for a food recall.
Examples of food traceability records for exporters
- copy of the export certificate
- purchase invoice
- bill of lading
- lot accountability record
An example of information contained within your documents/records:
- country of import
- certificate type(s)
- location of the consignment
- date the consignment is available for inspection
- date the certificate is required (date of departure)
- total units and unit size of each lot in the consignment
- product description (size, grade, type)
- scientific name (where appropriate), and common name(s)
- consignee name and address (name and address of each person/company (consignee) receiving the food)
- consignor name and address
- licence number(s) of manufacturing establishment(s)
- establishment ID numbers (if applicable) that conducted activities to the product (for example slaughter, processing)
- processing/packing date(s)/codes
- net weight of each unit
- total net weight of the lots
- storage condition of the product
- date CFIA signed the certificate
- product identification marks
- date the consignment was exported
- mode of transportation and container number (for example by air, by ship)
More information
1.3 Export documents
There are various sections of the SFCR that describe export related documents that must be maintained, and which can be incorporated into your ECP. Some of these documents are described below.
1.3.1 Export of non-compliant Food (SFCR 16)
As described in the Policy on the export of non-compliant food, you can export a food that does not meet certain requirements detailed in SFCR 16, provided that you mark your food with the word "export". You will also be required to keep written documents of the foreign requirements and/or specifications and how the product meets them, for example:
- proof that the container and markings comply with the conditions of the importing country
- the contract with the importer clearly stating the quality specifications of the food product
- the lot number or lot code of the shipment marked on the label or embossed on the container
- the label on the container does not misrepresent the quality, quantity composition, character, safety, or value of the food product
- materials and incoming ingredients sources approved by the country of destination (if applicable), and any unique processes or establishment information which would impact the product compliance
- foreign food safety and compositional standards that differ from Canadian standards
- attestations for any animal health disease status in the area
- documentation of a Supplier Food Safety Assurance Program (SFSAP) which would describe the measures taken to ensure the food meets the importing country standards
Non-compliant product should never jeopardize Canada's trade reputation. The CFIA will not certify food that was processed under unsanitary conditions or marketed in a fraudulent manner.
1.3.2 Documents that prove an exported meat product meets the importing country conditions (SFCR 168)
As per section 168 of SFCR, the operator of the exporting meat establishment bears full responsibility for ensuring that all applicable importing country conditions are met and for providing satisfactory information to the CFIA before the CFIA can authorize the export and issue the required certificates.
More Information
1.3.3 Certificate controls
You must provide complete, accurate and truthful information when requesting an export permission from the CFIA, such as an export certificate or amendment/addition to an export eligibility list.
Demonstrating that you have effective certificate controls in place will streamline the process for obtaining export certificates and endorsement for incorporation onto an eligibility lists. Misrepresentation of an export consignment on a CFIA certificate will result in enforcement actions in line with the compliance and enforcement policy.
Certification requests must be made and approved before shipping your food products. Only certificates that are recognized by the CFIA may be requested. All lots identified on the certificate must be available for inspection by the CFIA.
Please visit the Export certification page for more information about export certificates.
The certificate controls in this section must be implemented and effective in order to meet the outcome of having export documents that are factual, accurate, and complete.
Example of controls that demonstrate that your export certificate process results in export documents that are factual, accurate, and complete
- Describing the person responsible for the accuracy of your export documents, for example the export manager
- Describing how the consignment details are verified on the export documents, for example, the certificate request is compared to the production records, and shipping details
- Providing export documentation that matches the traceability information from the consignment, for example showing an export certificate that matches the traceability records.
- Demonstrating the process that the responsible person goes through to verify the export documentation. For example, a verification process to ensure the issued certificate matches the consignment details, and meets the attestations on the certificate, even if this activity is conducted by a third party.
- Showing how an in-process export load is verified to ensure the export documents are factual, accurate, and complete. For example, having a process to confirm that the loaded consignment (product information, packaging information, shipping information) matches the certificate issued.
- Final review of the endorsed certificate to verify that it is the correct certificate for the destination country, and that the consignment details, including attestations are accurate.
Documents/records that demonstrate certificate controls
Certificate records must be maintained in order to meet the traceability requirements.
The export food commodity and destination country will determine the information required to complete the certificate request. Examples of certificate record details can be found in section 1.2 Traceability.
Replacement certificates
Situations may happen where you need to replace a certificate for a product that has already been exported. Replacement certificates (or a letter of explanation) may be issued by the CFIA in certain circumstances, provided that you have an ECP that describes your export controls and documents involved in such situations.
Replacement certificates received from the CFIA must be linked to the original certificate that was cancelled.
More information
2. Controls for meeting importing country conditions
Some importing countries have requirements that exceed or differ from the SFCR. The CFIA refers to these foreign country requirements as additional export conditions. They must be met by the Canadian exporter in order for their product to be eligible for export to these specific countries.
As described in section 8.2.2.2 of the Food export control policy, exporters must prepare and implement effective written controls that demonstrate compliance with applicable additional export conditions. These additional export conditions can be found in the CFIA's Food export requirements library. If you know of additional export conditions that are not referenced in the export requirements library, it is your responsibility to notify CFIA, so that they can be verified with the authorities in the importing country and added to the library.
These controls apply regardless of where the exporter sources their products (for example, if they manufacture the products themselves, import the products, or source from a licence holder).
In this section of your ECP you describe:
- 2.1 the importing country conditions
- 2.2 the controls you have in place to ensure you are meeting the importing country conditions including:
- 2.2.1 product controls
- 2.2.2 establishment controls
2.1 Description of importing country conditions
It is your responsibility to comply with importing country conditions that exceed or differ from Canadian regulatory requirements, or for which there is no Canadian regulatory requirement. In your ECP you describe and substantiate the importing country conditions for the product(s) you wish to export.
The ECP indicates the importing country conditions the food must comply with, for example:
Product Conditions:
- food safety conditions, such as:
- processing temperatures
- processing times
- chemical residue or contaminant standards
- microbiological standards
- food animal disease status
- consumer protection conditions, such as:
- specific labelling conditions
- specific grades, packaging, standards, or net quantity conditions
- specific seals, stickers or stamp conditions
Establishment Conditions:
- eligibility list requirements
- establishment specifications
- method of production
- licencing requirements for all establishments that prepared or stored the export consignment
To describe the importing country conditions for a specific country you can reference, for example:
- CFIA's Food export requirements library
- foreign country's website
- documentation provided by a foreign competent authority
- documentation from the importer in the importing country
- a copy of the export certificates needed (which has the conditions identified on it)
- A link to the eligibility list information
2.2 Description of the controls that you have in place to ensure you are meeting importing country conditions
2.2.1 Product controls
Examples of controls for product conditions:
Controls for food safety conditions:
- Sampling – exported products may need to be sampled for laboratory analysis, by lot, or by using a sampling matrix based on risk when:
- there are foreign standards which are more stringent than Canadian standards, or for which a Canadian standard does not exist;
- the importing country has previously rejected product from the exporter
- the manufacturer has not provided adequate proof that the product meets the importing country condition
- supplier assurance records from the manufacturer
- reports of analysis from the manufacturer
- processing records from the manufacturer
- historical sampling data (for example, harvest site data provided by government agencies)
- records of specific control measures that were applied to the product
The CFIA recognizes microbiological and chemical analyses conducted by laboratories accredited by the Standards Council of Canada (SCC) or by the Canadian Association for Laboratory Accreditation (CALA).
Example of controls for consumer protection conditions:
- controls that ensure stickers, stamps and seals are applied accurately, if applicable (only applicable to certain commodities)
- describe in your plan the correct procedures relating to the use and request for export stickers, stamps and seals and keep records accordingly.
- describe how the stickers, stamps, and seals are stored and controlled, when required.
- records of verifying controls for additional labelling conditions
- records that verify controls for additional grading, packaging, and standards
More information
2.2.2 Establishment Controls
Eligibility list Conditions
Addition to an eligibility list can be an additional export condition imposed by an importing country. Please refer to CFIA's Food export requirements library to determine if the country where you wish to export your product requires the establishment that prepared the food to be on an eligibility list.
Indicate in your ECP how you meet this requirement for each applicable country.
For example:
- when you don't prepare the food you export, you ensure that you only source food from an SFC licensed establishment that is on the list of eligible establishments for the importing country
- when the food has been imported for export, you ensure that the imported food was sourced from an establishment eligible to export to the importing country
- if the importing country has a requirement that a specific activity, such as storing, is conducted by a licence holder on the eligibility list, this must be verified by the exporter
Other establishment related conditions
When the importing country requires that all preparation steps be conducted by a licence holder, the exporter will verify and demonstrate in their ECP how this condition has been met.
Inspection coverage or other CFIA oversight
Sometimes an importing country requires that a product be prepared for export under direct CFIA supervision, or another type of regulatory oversight. If you export to such a country, your ECP will include the frequency of inspection and details of the oversight.
For example:
The controls should include how you notify the CFIA (when required) in advance of certain commodities being produced and/or shipped, and the requirements of the importing country in relation to inspection coverage.
More information
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