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SFCR timelines - Unprocessed food used as grain, oil, pulse, sugar or beverage

Although the Safe Food for Canadians Regulations (SFCR) came into force on January 15, 2019, certain requirements may apply in 2020 and 2021 based on food commodity, type of activity and business size. For more information, refer to the SFCR timelines.

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Timetables for unprocessed food used as grain, oil, pulse, sugar or beverageFootnote 1

Use the timetables 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.

Timetable: Interprovincial trade of unprocessed food used as grain, oil, pulse, sugar or beverageFootnote 1

Activity Licensing PCP Preventive Controls Traceability
You manufacture, process, treat or preserve the unprocessed 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 package or label unprocessed food into consumer prepackages

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 you have 4 employees or less) Table Note 2

July 15, 2020
You package or label the unprocessed food into prepackages, other than consumer prepackages

July 15, 2020
(if the unprocessed food:

  • is not intended to be processed, or treated for use as grain, oil, pulse, sugar or beverage; and
  • is not labelled with "For Further Preparation Only")

Not required
(if the unprocessed food:

  • is intended to be processed, or treated for use as grain, oil, pulse, sugar or beverage; and
  • is labelled with "For Further Preparation Only")

July 15, 2020
(if you have a licence to conduct the activity and your gross annual food sales are greater than $100,000 and you have 4 employees or less) Table Note 2

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

Not required
(if you have a licence to conduct the activity however your gross annual food sales are $100,000 or less)

Not required
(if you do not have a licence)

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

July 16, 2021
(if you have a licence to conduct the activity and your gross annual food sales are $100,000 or less or you have 4 employees or less) Table Note 2

Not required
(if you do not have a licence)

July 15, 2020

You conduct interprovincial trade of the unprocessed food
(sole activity)

X X X July 15, 2020

You are a primary producer of the unprocessed food
(sole activity)

X X X July 15, 2020

Timetable: Export of unprocessed food used as grain, oil, pulse, sugar or beverageFootnote 1

Activity Licensing PCP Preventive Controls Traceability
You manufacture, process, treat or preserve the unprocessed food

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
You package or label the unprocessed food into consumer prepackages 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 you have 4 employees or less) Table Note 2

July 15, 2020
You package or label the unprocessed food into prepackages, other than consumer prepackages

July 15, 2020
(if the unprocessed food:

  • is not intended to be processed, or treated for use as grain, oil, pulse, sugar or beverage; and
  • is not labelled with "For Further Preparation Only")

or sooner if you would like an export certificate or other export permission from CFIA Table Note 3

Not required
(if the unprocessed food:

  • is intended to be processed, or treated for use as grain, oil, pulse, sugar or beverage; and
  • is labelled with "For Further Preparation Only")

Not required
(unless you would like an export certificate or other export permission from CFIA) Table Note 3

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

July 16, 2021
(if you have a licence to conduct the activity and your gross annual food sales are $100,000 or less or you have 4 employees or less) Table Note 2

Not required
(if you do not have a licence)

July 15, 2020

You export the unprocessed 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

You are a primary producer of the unprocessed food
(sole activity)

X X X July 15, 2020

Timetable: Import of unprocessed food used as grain, oil, pulse, sugar or beverageFootnote 1

Activity Licensing PCP Preventive Controls Traceability
You import consumer prepackaged unprocessed 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 you have 4 employees or less) Table Note 2

July 15, 2020

You import unprocessed food that are not consumer prepackaged

July 15, 2020
(if the unprocessed food:

  • is not intended to be processed, or treated for use as grain, oil, pulse, sugar or beverage; and
  • is not labelled with "For Further Preparation Only")

Not required
(if the unprocessed food:

  • is intended to be processed, or treated for use as grain, oil, pulse, sugar or beverage; and
  • is labelled with "For Further Preparation Only")

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

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

Not required
(if you have a licence to conduct the activity however your gross annual food sales are $100,000 or less) Table Note 2

Not required
(if you do not have a licence )

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

July 16, 2021
(if you have a licence to conduct the activity and your gross annual food sales are $100,000 or less or you have 4 employees or less) Table Note 2

Not required
(if you do not have a licence)

July 15, 2020

Timetable: Unprocessed food used as grain, oil, pulse, sugar or beverageFootnote 1

Activity Licensing PCP Preventive Controls Traceability
You sell the unprocessed food to consumers at retail X X X July 15, 2020

Table Notes

Table Note 1

Unprocessed food used as grain, oil, pulse, sugar or beverage arelisted in Schedule 1 of the SFCR. These are: amaranth, barley, buckwheat, camelina, canola, chickpeas, cocoa beans, coffee beans, dry beans, dry faba beans, dry peas, flaxseed, hemp, hops, lentils, maize (corn), millet, mustard seeds, oats, quinoa, rapeseed, rice, rye, safflower seeds, sorghum, soybeans, sugar beets, sugar cane, sunflower seeds, tea leaves, triticale, wheat, wild rice.

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 or other export permission from the CFIA.

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 was imported or exported, as well as sales from food that was intraprovincially or interprovincially traded.

Step 2:
Add together the money you received from sales that correspond to the criteria in Step 1.
Step 3:
Refer to the Timetables for unprocessed food used as grain, oil, pulse, sugar or beverage 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 Timetables for unprocessed food used as grain, oil, pulse, sugar or beverage 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, an importer of consumer prepackaged wild rice had the following gross sales:

Total gross annual food sales:

Between July 14, 2019 and July 14, 2020, the same importer of consumer prepackaged rice had the maximum number of employees working in October, including:

Total gross annual food sales:
Total gross annual food sales:
Total gross annual food sales:
Total gross annual food sales:
Total gross annual food sales:
Total gross annual food sales:

The food business has a total of $117,000 in gross annual food sales and a total of 560 hours worked in one month. Since the food business has greater than $100,000 in gross annual food sales and less than 640 hours worked, they qualify for additional time to comply with the PCP and preventive control requirements. They need to comply with these requirements on July 16, 2021.

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