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Overview: importing fish and shellfish

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.

As of March 31, 2020, CFIA fees are subject to an annual adjustment based on the Consumer Price Index (CPI). Please refer to CFIA's Fees Notice for updated fee amounts.

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Introduction

This document outlines requirements specific to importing fish. In order to ensure that you will also meet the general import requirements for importing food and the preparation of your preventive control plan, please refer to the Importing Food: A Step by Step Guide and A guide for preparing a preventive control plan – For importers.

The specific import requirements for importing fish can be found in the Automated Import Reference System (AIRS). AIRS information is updated frequently so prior to importing you should verify AIRS to ensure that the import requirements have not changed.

General requirements

Importers are responsible for ensuring that they import fish that meet all applicable food safety and consumer protection requirements outlined in the Safe Food for Canadians Regulations (SFCR) as well as any applicable requirements of the Health of Animals Regulations.

The CFIA verifies compliance to Canadian regulatory requirements and works with the competent authorities of Canada's major trading partners to provide reasonable assurances that imported products are safe and meet regulatory requirements.

Certain aquatic animal species from certain countries may be classified as "susceptible" to diseases of concern in Canada and may require an Aquatic Animal Health Import Permit. For more information on susceptible fish and aquatic animal health import requirement refer to Susceptible species of aquatic animals and Aquatic animal imports web pages.

Specific requirements for imported fish

Specific requirements for shellfish

Resources

Refer to the CFIA web page Food-specific requirements and guidance – Fish to view various guidance documents including:

Regulatory requirements: Fish explains the SFCR requirements related to fish and shellfish, including specific requirements for importing

Preventive controls for food – Fish provides information on select preventive control practices to mitigate food safety risks associated with the processing of fish and shellfish.

What's new for fish importers under the SFCR

The CFIA, under SFCR, is adopting a risk-based approach to inspection, which will result in changes to current processes. Importers will be required to adopt and follow these changes.

The information presented below is intended to highlight the main changes to CFIA's fish import processes under the SFCR compared to established processes under the Fish Inspection Regulations (FIR).

Summary Table
Fish Inspection Regulations
(to be repealed January 15, 2019)
Safe Food for Canadians Regulations
(effective January 15, 2019)
Import notification and release of shipments Importers use Fish Import Notification (FIN) form Importers use Single Window – Electronic Data Interchange (EDI)
Import notification and release of shipments Importers notify within 48 hours after importation Importers notify before or at time of import
Import notification and release of shipments

Once fish shipment is released by CBSA:

  • Basic importers hold all shipments until CFIA release notification before further distribution
  • Quality Management Program for Importers (QMPI) importers are permitted to distribute immediately
Once fish shipment is released by CBSA, all fish shipments can be distributed immediately
Importer licences and associated import fees Two types of licences; basic and QMPI. Product import fees determined by type of licence One type of licence; a preventive control plan (PCP) is mandatory. Refer to CFIA's Fees Notice for licence fee and product import fees
CFIA Inspection

Mandatory CFIA product inspection triggers in place:

  • first imports
  • random imports
  • Mandatory Inspection List (MIL) and Enhanced Inspection List (EIL)

MIL and EIL will cease to exist.

Product inspection and sampling by CFIA continue through the ongoing compliance verification by inspectors of importer PCPs

CFIA Inspection Compliance verifications of QMPI importers and their documented plans Compliance verification of licensed importers and their PCPs
CFIA Inspection Fish products subject to CFIA inspector sampling/inspection are normally held Fish products subject to CFIA inspector sampling/inspection are not generally held (unless inspector suspects an issue)
Requests for re-inspections Re-inspections offered when a lot fails an inspection test that does not present a health and safety concern Re-inspections are no longer offered. The importer is required to take corrective actions

Fish Import Notifications (FIN) and the release of shipments

Under the FIR, importers were required to provide information on their imported shipments via a FIN that is submitted to a regional CFIA office up to 48 hours post import.

Under SFCR:

Importer licences and associated import fees

Under the Fish Inspection Regulations (FIR) there were two levels of fish import licences: basic and QMPI. The requirements and nature of CFIA compliance verification activities varied for each level.

QMPI Basic
Importers were responsible for the compliance of the fish they import. They developed a Quality Management Program (similar to a PCP). In addition, they were required to follow the same product inspection frequencies as the CFIA (prescribed by the FIR) and had to submit an inspection report of all results to the CFIA every 6 months Importer requirements were simplified and there was no PCP-like documents required

Import licences under SFCR:

Import fees under SFCR:

CFIA inspections

The CFIA's inspection scheme established under the FIR focused on obtaining reasonable assurance that imported fish products consistently met Canadian standards and requirements. The CFIA inspections were tied to product type and producer, with the following inspection triggers:

The MIL and EIL allowed the CFIA to identify non-compliant fish to ensure that subsequent imports of these products were subject to analysis/product inspection before being sold or distributed in Canada.

For basic importers, CFIA oversight was largely based on the inspection triggers listed above as well as lot-by-lot tracking/assessment of the need for product analysis/inspection (based on risk factors). For QMPI, CFIA current oversight was largely based on compliance verification of their documented QMPI plan (similar to a PCP under the SFCR).

Under SFCR:

Re-inspections

Under the FIR, importers could request CFIA to conduct a re-inspection of non-compliance issues that did not present a health and safety concern. It enabled importers to:

Under SFCR:

Standards of identity and grades for fish

There are grades and standards referred to in the regulations for fish. These standards of identity and grades have been combined into a collection of Documents incorporated by reference – Safe Food for Canadians Regulations. Imported fish that declare a common name as stated in the Canadian Standards of Identity document must meet the corresponding standard and any grade declarations must be in accordance with the grades set in the Canadian Grade Compendium. Refer to:

Labelling requirements

The label of imported prepackaged fish must bear the name of the foreign state of origin in addition to the core labelling requirements outlined in the Industry labelling tool. The Industry labelling tool is a food labelling reference for all industry that outlines the requirement for food labelling and advertising

Labelling Requirements for Fish and Fish Products outline the labelling requirements specific for fish and fish products.

Organic fish

Imported organic fish may be certified to the Canadian Organic Standard by a CFIA accredited Certification Body or be certified in accordance with an equivalency arrangement established between Canada and the exporting country. Where an equivalency arrangement is in place, organic products may be certified by a certification body accredited by that country and recognized by Canada. Imported certified organic products with 95 per cent or more organic ingredients may display the Canada organic logo on the labels. All relevant Canadian legislation would also continue to apply for the imported product.

Any person who imports a product or markets it in Canada as an organic product must be able to demonstrate, at all times, that the product meets one of the requirements set out above and must retain the documents attesting that the product is organic.

For further information about organic products refer to Organic products.

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