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CFAI - SFCR Clarification

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#1 Beveragequestions44

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Posted 16 June 2021 - 03:52 PM

Hello, I have reached out to the CFIA offices a number of times about the following question, but have never received a clear response on exactly what is needed. We are looking into manufacturing a beverage product that will have a small amount of Fruit Puree in it.  The Puree will not come from fresh fruit, and is aseptically filled into its container prior to us using it in the proposed beverage.  The beverage is then pasteurized at 94 degrees C for 60 seconds. I know we need to apply for the CFIA SFCR that applies to "all other food products" because the product is a "beverage". Do we also need to apply for the license to include "manufacturing, preserving, processing fruit and vegetables" because the puree is in there? - They have not provided clear answer on this so hoping someone can help.  I am not sure if there is a difference in processing raw fruits and vegetables, and reprocessing a small amount of second generation purees. Thanks! 


Edited by Jacob Timperley, 17 June 2021 - 12:16 AM.


#2 Scampi

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Posted 16 June 2021 - 04:04 PM

No you do not, you are not manufacturing, preserving, processing fruit and vegetables, you are adding an ingredient into the beverage you are making that doesn't change the inherent properties of the puree, simply puts them in suspension

 

Here is a link you may not have seen yet, it spells out what licenses are for what, you should also be able to find definition that will help guide your decision

 

Did you fill out an AskMy CFIA request? or did you email your the office in the location that will inspect your facility?


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#3 Beveragequestions44

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Posted 16 June 2021 - 04:43 PM

No you do not, you are not manufacturing, preserving, processing fruit and vegetables, you are adding an ingredient into the beverage you are making that doesn't change the inherent properties of the puree, simply puts them in suspension

 

Here is a link you may not have seen yet, it spells out what licenses are for what, you should also be able to find definition that will help guide your decision

 

Did you fill out an AskMy CFIA request? or did you email your the office in the location that will inspect your facility?

 

Hi Scampi,

 

Thanks for this.  I am not seeing a link? Do you mind reposting it?

 

I spoke with a member at the CFIA head office on the phone to discuss this.  I left a voice mail and sent an email to the permissions department a few weeks back, and have followed up since then, but have still not heard back.

 

 

Your explanation does make sense though, I appreciate the insight.



#4 Scampi

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Posted 16 June 2021 - 04:56 PM

Apologies  here it is

https://inspection.c...0/1524074697425

 

If the business has already created an account with CFIA, you may have more luck with the AskMyCFIA

 

https://inspection.c...7/1466573290851

 

Unfortunately, the turnaround time with CFIA is notoriously slow


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#5 Beveragequestions44

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Posted 18 June 2021 - 01:41 AM

Apologies here it is
https://inspection.c...0/1524074697425

If the business has already created an account with CFIA, you may have more luck with the AskMyCFIA

https://inspection.c...7/1466573290851

Unfortunately, the turnaround time with CFIA is notoriously slow



Thanks again Scampi,

I went though the link and I agree that I do not need the additional license.

Just to confirm my understanding: “Processing, manufacturing, preserving fruits and vegetables” is more or less defined as processing or preserving the “raw fruit ingredient”. I know they laid out about 90 different processes but I feel that that was the main communication.

#6 Scampi

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Posted 18 June 2021 - 12:48 PM

That's correct.  You won't perform any of those steps as laid out by CFIA


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