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SFCR timelines - All other foods (manufactured foods)

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Note

Foods not specified in any of the other timetablesFootnote 1 are covered in this table. Examples could include confectionary, snack foods, beverages, oils, dried herbs and spices, nuts and seeds, coffee and tea, processed grain-based foods such as baked goods, cereals and pasta.

Use the timetable below to find out when you will need to comply with those requirements of the Safe Food for Canadians Regulations (SFCR) related to licensing, preventive control plans (PCP), preventive controls and traceability.

The timeframes can vary based on your business activity and level of trade.

Refer to the activities that apply to your business to determine the relevant dates. The « X » is used to indicate when the requirements are not applicable or not required.

Please note: the CFIA is not prioritizing compliance activities with regard to SFCR requirements for the MFS at this time due to the COVID-19 pandemic. For more information, consult the update on Safe Food for Canadians Regulations requirements for the manufactured food sector.

Timetable: All other foods (manufactured foods)Footnote 1

Activity Licensing PCP Preventive Controls Traceability
You manufacture, process, treat, preserve, grade, package or label the food for interprovincial trade July 15, 2020

July 15, 2020
(if your gross annual food sales are greater than $100,000 and you have more than 4 employees) Table Note 2

July 16, 2021
(if your gross annual food sales are greater than $100,000 and you have 4 employees or less) Table Note 2

Not required
(if your gross annual food sales are $100,000 or less) Table Note 2

July 15, 2020
(if your gross annual food sales are greater than $100,000 and you have more than 4 employees) Table Note 2

July 16, 2021
(if your gross annual food sales are $100,000 or less or if you have 4 employees or less) Table Note 2

July 15, 2020
You conduct interprovincial trade of the food
(sole activity)
X X X July 15, 2020
You manufacture, process, treat, preserve, grade, package or label the food for export July 15, 2020 or sooner if you would like an export certificate or other export permission from CFIA Table Note 3 Not required
(unless you would like an export certificate or other export permission from CFIA) Table Note 3

July 15, 2020
(if your gross annual food sales are greater than $100,000 and you have more than 4 employees) Table Note 2

July 16, 2021
(if your gross annual food sales are $100,000 or less or if you have 4 employees or less) Table Note 2

July 15, 2020 or sooner if needed to meet the conditions of an export certificate or other export permission Table Note 3
You export the food
(sole activity)
Not required
(unless you would like an export certificate or other export permission from CFIA) Table Note 3
Not required
(unless you would like an export certificate or other export permission from CFIA) Table Note 3
X July 15, 2020 or sooner if needed to meet the conditions of an export certificate or other export permission Table Note 3
You import the food July 15, 2020

July 15, 2020
(if your gross annual food sales are greater than $100,000 and you have more than 4 employees) Table Note 2

July 16, 2021
(if your gross annual food sales are greater than $100,000 and you have 4 employees or less) Table Note 2

Not required
(if your gross annual food sales are $100,000 or less) Table Note 2

July 15, 2020
(if your gross annual food sales are greater than $100,000 and you have more than 4 employees) Table Note 2

July 16, 2021
(if your gross annual food sales are $100,000 or less or if you have 4 employees or less) Table Note 2

July 15, 2020
You sell the food to consumers at retail X X X July 15, 2020

Table Notes

Table Note 1

For the purposes of this table, ‘all other food’ refers to any food that does not fall under the SFCR timelines for:

Return to table note 1  referrer

Table Note 2

To help you determine your gross annual food sales and number of employees, refer to Calculating your gross annual food sales and Calculating your number of employees.

Return to table note 2  referrer

Table Note 3

You need a licence and PCP prior to obtaining an export certificate, including the Certificate of Free Sale (CFIA/ACIA 5786). If you are exporting the food, regardless if you manufactured the food or not, you are also responsible for ensuring that: the food was manufactured by a licence holder; the food meets the foreign country requirements; and, the manufacturer and/or exporter (as applicable) is on the export eligibility list for the country you are exporting to (if required).

Return to table note 3  referrer

Calculating your gross annual food sales

Step 1:
Consider all food that you sold in exchange for money between July 14, 2019 and July 14, 2020, regardless of the level of trade.

Include sales from food that you imported or exported, as well as sales from food that you sold intraprovincially or interprovincially.

Step 2:
Add together the money you received from sales that correspond to the criteria in Step 1.
Step 3:
Refer to the Timetable: All other foods above, considering both your gross annual food sales and number of employees, to determine whether you qualify for additional time or the PCP exception.

Calculating your number of employees

For the purposes of subsection 371(2) of the SFCR, four employees or less at any one time is considered to be equal to a total of 640 hours or less worked at a food business in one month.

Step 1:
Consider your business activities between July 14, 2019 and July 14, 2020 and focus on the month when you employed the most people and / or had employees work the most hours.
Step 2:
Add together the hours worked by each employee that month.

Include employees that are involved in managing the food business (for example administrative staff, marketing/sales, managers, owners) and activities directly related to the food (for example staff involved in preparing the food or maintaining your establishment, such as berry pickers, equipment maintenance staff, processing engineers).

Do not include employees that are involved in other tasks, for example parking management, landscapers, and security guards.

Step 3:
Refer to the Timetable: All other foods above, considering both your gross annual food sales and number of employees to determine whether you qualify for additional time or the PCP exception.

Example

Between July 14, 2019 and July 14, 2020, a bakery that manufactures muffins and cookies for interprovincial trade had the following gross sales:

Total gross annual food sales:

Between July 14, 2019 and July 14, 2020, the same bakery had the maximum number of employees working in April, including:

Hours worked by the labourers in April:

Hours worked by the administrative staff in April:

Hours worked by the owner/manager in April:

Total hours worked by all staff in April:

Conclusion:

The food business had a total of $86,000 in gross annual food sales and a total of 720 hours worked in one month. Since the food business has less than $100,000 in gross annual food sales and greater than 640 hours worked, they qualify for the PCP exemption and additional time to comply with the preventive controls requirements. This means the food business is not required to have a written preventive control plan and that they will need to comply with the preventive controls requirements on July 16, 2021.

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