Understanding the meat product exceptions under section 25 of the Safe Food for Canadians Regulations
Section 25 of the Safe Food for Canadians Regulations (SFCR) applies to meat products; imported meat products and meat products prepared within Canada. The meat products are grouped into 2 categories:
- Mixtures
- a mixture is a food that contains ready-to-eat (RTE) meat products with other non-meat ingredients (for example, meat stew, tourtière, pepperoni pizza)
- Broth/animal fat/ meat flavour or extract
- broth, lard, leaf lard, tallow or other rendered fat, suet, shortening, flavour or extract
Mixtures and broths/animal fats/ meat flavours or extracts that meet the requirements of section 25 are exempt from SFCR requirements specific to the import of meat products and the work shift requirements, including the storing and handling of meat products in its imported condition for inspection. A comparison of how some of the SFCR requirements apply to meat products that fall under section 25 to all other meat products; whether imported and prepared in Canada are found in Table 1 and Table 2 below.
If you prepare meat products that fall into the two categories in section 25, you need a Safe Food for Canadians (SFC) licence and a written preventive control plan (PCP). Licence holders who are making an RTE meat product prior to mixing it with other non-meat ingredients do not qualify for the exception under section 25.
Certain mixtures and rendered fats have specific standards outlined in the incorporated by reference document Canadian Standards of Identity Volume 7 – Meat Products. The document contains two tables that outline the standards for specific edible meat products.
- Table A outlines the standards for certain edible meat products. The meat products listed in this table are not eligible for the exemption under Section 25 of the SFCR.
- Table B outlines the standards for certain other edible meat products. The meat products listed in this table are eligible for the exemption under Section 25 of the SFCR, if the criteria in Section 25 are met.
Importing mixtures or broth/animal fat/meat flavor or extract into Canada
When you import a food that is a mixture of RTE meat and other food, or a broth/animal fat/meat flavour or extract into Canada, it must meet 4 conditions.
- It must be manufactured, processed, treated, preserved, handled, tested, graded, coded, stored, packaged or labelled, in a country with an inspection system for meat recognized under Part 7 of the SFCR. See the list of Countries from which commercial importation of meat products is permitted for a list of countries approved to export
- It must be imported from a country with an inspection system for meat recognized under Part 7 of the SFCR. See the list of Countries from which commercial importation of meat products is permitted for a list of countries approved to export
- The RTE meat used in the mixture or the meat used to make the broth/animal fat/meat flavour or extract must come from establishment that has a system for manufacturing, processing, treating, preserving, handling, testing, grading, coding, slaughtering, storing, packaging or labelling that recognized under Part 7. See the Foreign countries establishments eligible to export meat products to Canada
- An official document (such as, an Official Meat Inspection Certificate (OMIC) or an official document in a format approved by the CFIA) issued by the foreign competent authority must be provided to the CFIA before or at the time of import and kept by the importer. This document must be provided for both mixtures and broths/animal fats/meat flavours or extracts in accordance with section 25 of the SFCR and other Canadian regulatory requirements.
Requirements for preparing mixtures in Canada
When you prepare a mixture in Canada, 3 conditions may apply.
- If the RTE meat product used in the mixture was manufactured, processed, treated, preserved, packaged or labelled in Canada, the activity was conducted by a SFC licence holder.
- If the meat used to make the RTE meat came from a livestock or poultry carcass that was graded in Canada; it was graded by a grader in accordance with the SFCR.
- If the RTE meat product used in the mixture was imported, it was imported by a SFC licence holder.
Requirements for preparing broth/animal fat/meat flavour or extract in Canada
When you prepare a broth/ animal fat/ meat flavour or extract in Canada, 3 conditions may apply.
- If the meat product used to make the broth/animal fat/meat flavour or extract was manufactured, processed, treated, preserved, packaged or labelled in Canada, the activity was conducted by a SFC licence holder.
- If the meat product used to make the broth/animal fat/meat flavour or extract came from a livestock or poultry carcass that was graded in Canada, it was graded by a grader in accordance with the SFCR.
- If the meat product used to make the broth/animal fat/meat flavour is imported, it was imported by a SFC licence holder.
Exporting section 25 meat products
If you are exporting a meat product that falls under section 25, you remain responsible for the following:
- ensuring that the meat product is eligible for export to the importing country
- demonstrating the meat product meets the requirements of the importing country, including the requirements for inspections and certificates
- having a SFC licence that covers the activities that you do with respect to the meat product and exporting
Cold storage facilities that export meat products and/or store meat products intended for export to other countries may also need to meet certain requirements of the importing country. To understand the export requirements by country, consult the Export requirements library.
Keep in mind
Meat product shipments cannot be exported unless it has received a final inspection, found satisfactory and issued an export certificate or other document by the CFIA as requested by the importing country.
Application of inspection legend to meat products that fall under section 25
Whether prepackaged or not, meat products that fall under section 25 must have the inspection legend on the label when traded interprovincially or exported. If the meat product was imported, it must have the official inspection mark of the foreign state of origin. Consumer prepackaged (definition) meat products may show their inspection legend or inspection mark on any part of the label, except the bottom. For more information on the application of the inspection legends on meat products please see the Labelling requirements for meat and poultry products.
Application of SFCR requirements on section 25 meat products
Meat products that fall under section 25 are exempt from the certain SFCR requirements. The tables below are a comparison of SFCR requirements applicable to section 25 meat products and all other meat products. Please note that these tables are not an exhaustive list of the SFCR requirements; all other meat requirements found in the Safe Food for Canadians Act and Regulations remain applicable.
Section | Requirement | Applies to mixtures | Applies to broth/animal fat/meat flavour or extracts | Applies to all other meat products |
---|---|---|---|---|
Section 5: Licensing | Licence to import | Yes | Yes | Yes |
Section 7(2)(a)(ii): Additional Licensing | Licence to store and handle in its imported condition for inspection | No | No | Yes |
Section 13: Submitting import information | Can submit import information after the time of import; when permission is granted | Yes | Yes | No |
Section 14: Further inspection at the time of import | If identified for inspection, must be delivered to an establishment where the licence holder has a licence to store and handle the meat product in its imported condition for CFIA inspection | No | No | Yes |
Section 22: Return of a meat product that was previously exported | Must be returned to the person who exported it from Canada; if that person has a licence to export or returned to the last person who had possession of the product before it's export | Yes | Yes | No |
Section 22: Return of a meat product that was previously exported | Return must be authorized by an inspector | No | No | Yes |
Section 22: Return of a meat product that was previously exported | Must be returned to an establishment where the licence holder has a licence to store and handle the meat product in its imported condition and kept in the establishment until an inspector completes an inspection | No | No | Yes |
Section | Requirement | Applies to mixtures | Applies to broth/animal fat/meat flavour or extracts | Applies to all other meat products |
---|---|---|---|---|
Section 28(2) & 29(1)(d): Providing work shift for activities related to meat products | A proposed work shift to be provided with licence application and the work shift must be approved by the CFIA | No | No | Yes |
Section 31(2): Specified work shift hours | The activities related to the meat product are conducted during the approved work shift hours | No Table Note 1 | No Table Note 1 | Yes |
Section 42: Minimum hours of inspection | The CFIA determines on the minimum number of hours of inspection required per year during approved work shift | No | No | Yes |
Section 46(1)(b): Preventive controls | Preventive controls must be applied when storing and handling the meat product in its imported condition for inspection | No | No | Yes |
Section 69: Facilities for inspectors to perform their inspection duties | Furnished office, lockers, cabinets, lockable storage facility for samples must be available for CFIA inspector and a private office is provided in slaughter establishments for the CFIA inspector | No | No | Yes |
Section 167: Import | Must meet the import requirements for meat products in section 167 | No | No Table Note 2 | Yes |
Section 168: Export | Must meet the export requirements for meat products in section 168 | No | No | Yes |
Section 296: Label of edible meat products | If the meat product label does not meet the SFCR requirements and it is sent or conveyed from an establishment; it must be sealed with a tamper-resistant seal | No | No | Yes |
Table Notes
- Table Note 1
-
Although specified work shift hours are not required, licence holders must work with CFIA to ensure their working hours are known in order for CFIA to conduct domestic and export inspection.
- Table Note 2
-
An official document may still be required at the time of import in accordance with the Health of Animals Regulations
Keep in mind
While section 25 meat products are exempt from certain SFCR requirements outlined in the tables above, when exporting, you must meet all requirements of the importing country to avoid affecting your eligibility and status on export eligibility lists. For more information export eligibility lists, consult the Export registers and lists.
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