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CFIA Registration for Printing Meat Inspection Legend

Printing food containers

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#1 PackPro77

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Posted 25 January 2019 - 04:10 PM

Hi, we are trying to get our meat inspection legend registration renewed.  In looking at the law, it is not clear that we need to do this.  We are in the US and export containers to Canada with the legend on them.  Do I need to go through the CFIA portal to do this?  If so, how?  I tried yesterday and it wasn't clear at all whether I even need to do this any more.  Thanks...



#2 Watanka

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Posted 25 January 2019 - 04:28 PM

We have asked the same question.  The interactive guide to determine if your food item qualifies for the program told us we need a CFIA license.  A review of question 13 on their FAQ page says: 

13. I manufacture food in the US and export it to Canada. Do I need to apply for an SFC licence?

 

You do not need a licence to prepare food for export to Canada. Only the person importing the food in Canada will require a licence to import under the Safe Food for Canadians Regulations (SFCR) and will be responsible for meeting the other requirements of the SFCR. This includes having a PCP and meeting traceability requirements. The importer could be located in Canada or in the US.

The US is a country recognized by the CFIA as having a food safety system that provides the same level of protection as Canada's regulatory system. As per Subsection 12(1) of the SFCR, if the person importing the food is a non-resident importer (NRI) with a fixed place of business in the US, they will be eligible to hold an import licence. In this case, the US business will need to meet the same requirements as Canadian importers, including:

  • having a licence to import;
  • having a preventive control plan;
  • maintaining procedures and processes for handling and investigating complaints and recalls, and
  • keeping clear and complete traceability records that show who the food was obtained from and to whom it was sent

 

We followed up with a call to CFIA to get a reading on whether or not we need a license.  The folks there were very nice, took time to round table the question and replied they didn't know.  They suggested we write an email to CFIA asking the question in the hopes it would be routed to someone with the knowledge and authority to provide an accurate answer.  We received an acknowledgement from CFIA, but no answer.

 

Nice to know we are not the only ones stuck in this bureaucratic circle.  Will let you know if we ever hear anything from CFIA.  Good Luck!



#3 PackPro77

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Posted 25 January 2019 - 05:02 PM

I also had a discussion with the CFIA folks who also looked around within and were unable to answer.  They could only tell us to submit a question as well, which I did.  We are SQF Level 2 with ISO 9001:2015, so I would think we would meet all their requirements, but the change in the law makes it so murky (I honestly am not sure whether they considered this when writing the law) that it is impossible to gauge how to proceed. 

 

The person I spoke with at CFIA told me they should reply within 24-48 hours, but the stock email I received back said up to 15 days!  If I do hear something I will let you know.  Good luck to you as well!



#4 Scampi

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Posted 25 January 2019 - 05:11 PM

I know I heard this answer on a CFIA webinar. 

 

 

There was something about the NEED to keep the reg #'s they hadn't thought of.........let me track down the slide deck


Because we always have is never an appropriate response!


#5 Scampi

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Posted 25 January 2019 - 05:31 PM

Yes, operators can keep their previous registration or licence numbers against their new SFC licence to avoid disruption to trade. These are considered your unique establishment identifiers and may continue to be used on export certificates, export eligibility lists and packaging.

 

As far as I can tell, your establishment number will continue to be attached to the new SFCR license, but you will not need to apply for it as you used to.

 

The establishment # still needs to be used on packaging and export certificates

 

Please don't quote me!  I'm using my memory here. 

 

It was my understanding that the IMPORTER is the one that needs the license, but again don't quote me. Below is a link to some Q&A that may help

 

http://www.inspectio...6/1492029286734

 

For the record, we may start exporting and I'm having the same troubles getting FDA to answer me (i know they're not working but the website is challenging to get a clear answer)


Because we always have is never an appropriate response!


#6 PackPro77

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Posted 25 January 2019 - 05:57 PM

The interesting thing is that we print for the food packagers.  We just make the food packaging containers with the meat inspection legend on them for the individual packagers (different legends for different packagers).  Previously it looked like the onus was on the printers to make sure that the food packaging was printed with the MIL and distributed correctly to the packagers.  As I read it now, it looks like the onus is on the packagers themselves to use the meat inspection legends correctly.  Am I reading this incorrectly? 



#7 Scampi

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Posted 25 January 2019 - 06:33 PM

That is correct.........it is up to the owners of said packaging to make sure they are licensed to use the registration. However, it is no longer a "legal entity" like it was previously and will now only be used as an identifier (especially for the big guys with 12 different meat plants in 12 different geographic locations, but may only get 1 license for the lot)


Because we always have is never an appropriate response!


#8 PackPro77

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Posted 05 February 2019 - 04:36 PM

For all who are interested, the CFIA no longer requires registration to print the meat inspection legend for Canada.  I received the following from a person with the title:

Acting Operations Specialist, Quebec Operations Area

Canadian Food Inspection Agency / Government of Canada

 

She replied to me:

"With the new Safe Food for Canadians regulations effective January 15, 2019 the requirements have changed. The Centre of administration does not issue authorisations to print inspection legends any longer."

 

I hope this makes you as happy as it makes me.

 

 



#9 Scampi

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Posted 05 February 2019 - 05:03 PM

thanks for the update!


Because we always have is never an appropriate response!


#10 Watanka

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Posted 06 February 2019 - 10:39 PM

Received a reply from CFIA.  It appears exporters into Canada do not have to obtain a CFIA permit.  See below.

 

 

Response

 

As per the “Attention Foreign supplier’s” box on the Importing food web page and question #13, foreign businesses preparing foods for export to Canada do not need a licence under the Safe Food for Canadians Regulations (SFCR).

 

A SFC licence is required for the direct importer i.e. the company that imports the food into Canada (see Section 3.3 Import Trade of the web page Food business activities that require a licence under the Safe Food for Canadians Regulations).



#11 Scampi

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Posted 07 February 2019 - 05:58 PM

NOTE:  That only applies if you are not ALSO the importer


Because we always have is never an appropriate response!


#12 PackPro77

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Posted 13 February 2019 - 07:42 PM

Finally got a truly definitive answer from CFIA:

 

Response

 

As per section 282 and section 287 of the Safe Food for Canadians Regulations (SFCR), the inspection legend set out in Figure 1 of Schedule 2 of the SFCR must appear on the label of an edible meat product when traded inter-provincially or exported (whether prepackaged or not), provided the conditions set out in subsections 180(1), (3) and (4) of the SFCR are met.

 

According to subsection 184(1) of the SFCR, the following persons are authorized to use the inspection legends that are set out in Figures 1 and 2 of Schedule 2:

 

(a) printers of labels, other than printers of official export labels, and manufacturers of packages, if the labels and packages that bear the inspection legend are provided to any person who is authorized under any of sections 180 to 182 to apply and use the inspection legend;

 

(b) printers of official export labels, if the labels that bear the inspection legend are provided to an inspector;

 

© publishers of documents on the subject of the inspection of meat products, processed egg products or fish;

 

(d) publishers of documents that advertise meat products, processed egg products or fish; and

 

(e) manufacturers of stamps, if the stamps that bear the inspection legend are provided to any person who is authorized under any of sections 180 to 182 to apply and use the inspection legend.

 

Under the SFCR, the Canadian Food Inspection Agency (CFIA) is no longer maintaining a list of authorized printers and as such printers of labels and manufacturers of packaging material do not need to register with the CFIA to utilize the inspection legends set out in Schedule 2 of the SFCR. Printers of labels and manufacturers of packages are authorized to use the inspection legends set out in Schedule 2 of the SFCR if the labels and packages that bear the inspection legend are provided to any person who is authorized under any of sections 180 to 182 of the SFCR to apply and use the inspection legend.

 

For detailed information on how the inspection legend should appear on the label of an inter-provincially traded or exported edible meat product, please consult the section entitled Inspection legend under the Labelling Requirements for Meat and Poultry section of the CFIA’s Food Labelling for Industry tool. The Inspection legend section includes a high resolution image of the inspection legend which may be downloaded for use.

 

**Disclaimer: This response is based on CFIA's understanding of the particular facts provided in your request and the applicable provisions of the law within CFIA’s mandate.  Other relevant laws, including federal, provincial, territorial and municipal, may apply as well. 

 

Information in this response may be used to inform future CFIA guidance and policy that might be made available to industry and to the inspectorate. 

 

 

Your Enquiry

 

Hi, we were issued a meat inspection legend registration and I need to renew this, but with the new law I cannot seem to find the proper area in which to do this. We produce packaging materials for poultry and ship them to Canada. However some of our customers require the meat inspection legend on them. We need to get this registration renewed to move forward. Do I need to register through MyCFIA to do this?  If so, please let me know where to go or who to contact to do this.  I tried going through the licensing interactive tool, but none of the choices seemed to apply.






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