Requirement to include lot code on prepacked fruits into force on January 15

The Canadian Food Inspection Agency (CFIA) has provided detailed timelines concerning the application of preventive control plans, preventive controls, and traceability requirements for fresh fruits and vegetables. The SFCR came into force on January 15, 2019, with different food commodities. SFCR provisions were phased in through a two-year implementation period. General guidance on importing fresh fruits and vegetables is publicly available on the CFIA website.

On January 15, 2020, preventive control plans, preventive controls, and remaining traceability requirements under the Safe Food for Canadians Regulations (SFCR) will come into force for the majority of fresh fruits and vegetables sold in Canada. Most prepacked fresh fruit or vegetables are required to include a lot code or a unique identifier (lot code if it is a consumer prepackaged food not packaged at retail), the common name of the food, and the name and principal place of business of the company by or for whom the food was manufactured on the label, which must be applied, attached, or accompanying the food when it is provided to another person. While the coming into force date of January 15, 2020 will apply for lot code labeling of consumer prepackaged fresh fruit and vegetables, CFIA is providing industry with a one year extension on enforcement for lot code requirements on consumer prepackaged fresh fruit and vegetables to January 15, 2021. This flexibility will enable industry to use up existing packaging material and additional time to comply with new requirements.

The term "lot code" is not specifically defined in the SFCR nor in the Safe Food for Canadians Act (SFCA), but is included in the SFCR: Glossary of key terms. CFIA has indicated that further guidance on use of growing region as a lot code will be forthcoming on their website in early 2020.

Preventive Control Plans and Preventive Controls
Importers of fresh fruits and vegetables in Canada will be required to have a preventive control plan in place as a food hazard mitigation tool under SFCR. Importers with gross annual food sales below $100,000 CAD are exempted from this requirement. Preventive control plans (PCP) are not formally defined in SFCR, but CFIA guidance informs businesses of the requirements and how comply.

CFIA also provides guidance documentation on preventive controls, which are a systematic approach to identifying, controlling, and reducing food safety risks. Some examples of preventive control approaches to food safety include Good Agricultural Practices (GAP), Hazard Analysis Critical Control Point (HACCP) programs, and Good Manufacturing Practices (GMP).

Canadian government and industry sources state that Canadian importers of U.S. fresh fruits and vegetables will likely require U.S. exporters to share documentation and implement preventive controls and PCPs to ensure that the importer is fully compliant with SFCR. CFIA provides importers PCP guidance as well as a PCP template.

In addition to requirements for preventive control plans and preventive controls, the traceability provisions of SFCR will come into force for businesses that grow or harvest fresh fruits and vegetables on January 15, 2020.1 For businesses performing other activities, these requirements came into force on January 15, 2019.2 Traceability requirements are designed to encompass a trace forward (to whom was the food provided) and trace back (from whom the food was acquired) to facilitate any necessary recall activity. SFCR requirements stipulate documents must be kept for a two-year period and must be in a format that is accessible in Canada (this includes the ability to provide CFIA with the documents within 24 hours or less if requested in either English or French).

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