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Exporting from United States to Canada Allergen Declarations


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Josharp186

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Posted 23 February 2021 - 08:50 PM

I am trying to get some clarification on the regulations for allergen declaration for Mustard from a United States producing food manufacturer? Currently my company produces many products which contain mustard seed. Most of our business is done domestically but we do export products to Canada. We currently exclaim mustard as an allergen even in the US to meet requirements for Canada. I was just curious what the regulations would be regarding this? Is it necessary to declare if we just have it listed in the ingredients? We are trying to cut down on allergen changeovers and storage and taking mustard off the list would help us tremendously. I have thought about doing runs for Canada specifically as that would cut down on a lot of our changeovers, but our storage and handling of Mustard would still need to be segregated like other allergens. I hope this accurately gets my point across and someone can help provide some insight? Thank you. 



Scampi

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Posted 24 February 2021 - 05:48 PM

I am trying to get some clarification on the regulations for allergen declaration for Mustard from a United States producing food manufacturer? Currently my company produces many products which contain mustard seed. Most of our business is done domestically but we do export products to Canada. We currently exclaim mustard as an allergen even in the US to meet requirements for Canada. I was just curious what the regulations would be regarding this? Is it necessary to declare if we just have it listed in the ingredients? We are trying to cut down on allergen changeovers and storage and taking mustard off the list would help us tremendously. I have thought about doing runs for Canada specifically as that would cut down on a lot of our changeovers, but our storage and handling of Mustard would still need to be segregated like other allergens. I hope this accurately gets my point across and someone can help provide some insight? Thank you. 

 

 

here's a link to the info

https://www.inspecti...5/1462472833650

 

You get two options (generally) regarding labelling but you MUST comply with one or the other

 

Are you talking about a "mustard free" product for Canada run on the same line???


Edited by Scampi, 24 February 2021 - 05:50 PM.

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Josharp186

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Posted 24 February 2021 - 06:09 PM

I was thinking more along the lines of treating mustard like a standard non-allergen ingredient. Though individuals from Canada are still able to purchase. We have a website which individuals all over the world are able to purchase. Would this be acceptable?

 

I think the main point I am trying to cover is, are we required as a US manufacturer to declare mustard allergen if we are not specifically producing a product for Canada though we know it could end up in Canada? (Mustard would still be part of the ingredient listing) 



Charles.C

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Posted 24 February 2021 - 06:16 PM

IMO, your legal requirement if you understand that it is to be commercialised in USA is controlled by FALCPA.

 

And (local) analogously if anywhere else.

 

I don't see how you can be expected to be telepathic.


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Charles.C


Josharp186

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Posted 24 February 2021 - 07:25 PM

Those were my thoughts for the most part. Our sales team keeps going back and forth about shipping directly to Canada through Amazon or potentially through some other distributors. In these scenarios, are we required to follow Canadian food labeling laws or do we only need to abide by the country of manufacturer food labeling requirements?



Charles.C

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Posted 24 February 2021 - 07:35 PM

Those were my thoughts for the most part. Our sales team keeps going back and forth about shipping directly to Canada through Amazon or potentially through some other distributors. In these scenarios, are we required to follow Canadian food labeling laws or do we only need to abide by the country of manufacturer food labeling requirements?

 

Sounds like a good question for your sales team to sort out.

 

IMEX (not USA/Canada) production is always for a specific buyer/nominated destination as far as labelling is concerned. What happens after that is strictly  their business.


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Charles.C


Scampi

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Posted 24 February 2021 - 08:06 PM

Now you've entered an ETHICAL dilemma---if you KNOW that some of your customers are in Canada and you KNOW what the Canadian regs are why wouldn't you???

 

 

Legally platforms like Amazon are a gray area as the legal authority becomes the Border agents on product arriving from outside the country. CFIA also mans the border stations

 

If you're product is intercepted by border agents, it will NOT make it to it's final destination if it does not meet Canadian labelling rules

 

One has to ask why your sales team is trying so hard to be illegal??????????

 

Put it to them this way.........

 

We ALL use sugar...........very few places grow sugar cane............

 

sugar cane needs pesticides...........should the sugar cane farmers just ignore international law and use pesticides that are banned in Canada and the USA (when they know that to be true) because "they don't know where the finished goods are to be sold"?????

 

This corner cutting is the very reason I WILL not purchase food stuffs from amazon. Full stop

 

 

I would also agree with Charles whole heartedly.

 

When i was in poultry slaughter it was my job to know EVERY importing countries requirements and then meet them..........period.

 

And you can tell your sales team this Canuck thinks they are being sneaky and underhanded. That's why laws exist


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Josharp186

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Posted 24 February 2021 - 08:19 PM

Just to be clear Scampi, we currently are meeting all label requirements for any country that we potentially ship. Our sales team is actually following the correct avenues in trying to find the correct answers to these questions. This is largely why I am on here asking these questions :) Nothing illegal is occurring.

 

I want to make sure we are doing everything we need to do to be compliant where ever our product goes. We currently put statements for any product with sulfites, mustard, celery, and sesame (all not required in US). 

 

The conclusion I am coming to is that we need to continue being transparent. I will be looking into some SKU differentiation and the potential for export items in particular. I will see if we can help increase our operational efficiencies while being compliant and transparent. 

 

Thank you all for your help.



Scampi

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Posted 24 February 2021 - 08:32 PM

That's great to hear!

 

Again, amazon is a gray area.......you sell to them in the USA......it's theirs to do as they see fit, but it's your brand in the end


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