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Requirements to Ship a Processed Ingredient from Canada to USA

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GarethToon

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Posted 15 December 2022 - 03:13 PM

Good day everyone,

 

I work in a type of wet milling company that is going to make plant-based beverages. We will be making these in a ready to eat manner, but I was recently asked by one of the VPs what we need to send a 'concentrate' to the United States.

 

This 'concentrate' will essentially be a plant-based beverage that has not gone through a dilution step. There will be no claims of 'ready to eat' associated with this product, and it will be sold as a processed 'ingredient' to undergo further processing by a different company down in the United States.

 

It is going to be cold chain transported in bulk totes.

 

The general question of 'what do we need to cross the border' has kind of put me in a position of "where do I start?" as there is SO much information out there.

 

We have no licensing, accreditation, or even finished product as of yet, so this is my attempt at making a checklist of sorts.

 

Any advice on what to pursue or what we'll need from a shipping standpoint would be tremendous help, whether its CFIA or FDA related. 

 

Thank-you.



Scampi

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Posted 15 December 2022 - 03:45 PM

Question #1

 

Do you have a CFIA/SFCR license to operate?  


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GarethToon

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Posted 15 December 2022 - 03:57 PM

Question #1

 

Do you have a CFIA/SFCR license to operate? 

 

Thank-you for responding!

 

We are currently in the process of attaining our licenses, yes. Initially, we are going to pursue BRC accreditation.

 

My VPs are looking to export this 'ingredient', which is essentially a grain beverage, containing some dormant/deactivated enzymes, that have been decanted, as soon as possible. If they were to be on this thread, they'd be asking more of a 'what can we do without' for sending this across the border.

 

Thank-you again.



Scampi

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Posted 15 December 2022 - 04:22 PM

You cannot do anything until you receive your license from CFIA--then you need to get import approvals from FSIS

 

https://inspection.c...1/1507329098850

 

Foods with certification requirements related to animal health (aquatic or terrestrial) have been incorporated into the country export requirements below. For information on plant health certification requirements, please consult the CFIA plant export page. Food products that potentially require plant health certification include: grain and processed grain products (hemp seed, ground flax, oatmeal, flour, lentils, peas and other legumes, rice, corn, etc.); plant oils (canola, flax seed oil, etc.); frozen fruits and vegetables; fresh fruits and vegetables (mushrooms, bulbs, etc.); dried or freeze dried fruits or vegetables; dried soup mixes (particularly if they contain grains or dried vegetables); coffee and teas (including herbal teas); spices (especially spices that are whole seeds such as cardamom); and, traditional medicine ingredients. Please note that this is not an exhaustive list.

 

 

https://inspection.c...7/1539883860720

What this means for your food business

To help you understand, specific criteria and resources are provided below. Key terms throughout the text have been hyperlinked to the SFCR glossary.

Section 16: Exception - export of non-compliant food
  • Food that does not meet the requirements of the SFCR may be exported if:
    • it does not consist in whole or in part of any filthy, putrid, disgusting, rotten, decomposed or diseased animal or vegetable substance, or
    • it has been manufacturedprepared, stored, packaged and labelled under sanitary conditions, or
    • the food is imported or manufactured, processedtreatedpreservedgraded, packaged or labelled in Canada by a licence holder in compliance with the SFCA and SFCR,
    • it has a label applied or attached to the food that states "Export" or "exportation", and
      • if the foreign country where you are exporting the food has different requirements than the SFCR you must keep a document for two years from the date the food was exported, that shows how you have met the foreign country's requirements for the food.
      • if the foreign country where you are exporting the food does not have a requirement for the food, you must keep a document for two years from the date the food was exported, that outlines the specifications for the unmet SFCR requirements for the food that your foreign buyer requested.
    • The unmet SFCR requirement must be one of the requirements related to the Canadian standard for the food, the use of food additives or Canadian container sizes and labelling requirements specific to the food. These requirements are found in the following SFCR provisions:
      • subsection 9(1)
      • sections 10, 195, 197, 201, 210, 244-249, 262, 268, 272, 273, 292, 293, 306-308, 312, 313, 316, 322, 324-327, 329, 331
  • When exporting meat products that do not meet the requirements of the SFCR, there is an additional requirement to also provide a document to a CFIA inspector that demonstrates that the foreign country's requirements for that meat product have been met. You must obtain from the inspector an export certificate or other export permission for the meat product.
Resource

The Industry Labelling Tool and Labelling, standards of identity and grades can also help in clarifying the Canadian labelling requirements and food standard.

Section 17: Export certificates or other export permission
  • If you require an export certificate or other document to facilitate the export of your food commodity, you must submit an application to the CFIA.
  • The CFIA will issue an export certificate or other export permission if the applicant holds a licence to export, and:
    • for food, the manufacturingpreparing, storing, packaging and labelling of the food meets the applicable requirements of Part 4 of the SFCR
    • where the foreign country requires a certificate or other export permission for the food commodity or the prescribed food commodity to be imported into the foreign country for human consumption; the manufacturing, preparing, storing, packaging and labelling of the food commodity meets the applicable requirements of Part 4 of the SFCR, other than Division 3, as if it were a food
  • For purposes of section 17, a prescribed food commodity is any commodity derived from a plant or animal or any of it parts that;
    • does not fall into the definition food or is not any animal or plant, or any of its parts, that is used to make the food; and
    • requires an export certificate or other export permission to be imported into the foreign country for purposes of human consumption
  • The prescribed food commodities described above are exempt from any provisions of the SFCA and SFCR not necessary to meet the requirements of section 17
    • They are not exempt from section 6 of the SFCA regarding the manufacture of a food commodity that is false, misleading or giving a wrong impression of the commodity's character, quality, value, quantity, composition, merit, safety or origin.
  • Food commodities may require an inspection by the CFIA before an export certificate or other export permission is issued.
    • if an inspection is required, you must make the food commodity readily accessible to an inspector at the time of inspection
  • https://www.fda.gov/...s-united-states

 

FYI in my history, I've ALWAYS used a broker  (PM me if you want my opinion on the best of the best broker) as it is a confusing thing to manage on your own.  You prepare most of the documentation and the broker handles everything else


Please stop referring to me as Sir/sirs


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