Preventive Control Plan Importers of Foods Into Canada

Description

Complete Preventive Control Plan for Canadian Food Importers.

Included:

Hazard identification. For every food product imported, the plan must identify the biological, chemical, and physical hazards that could reasonably contaminate it — both hazards inherent to the food itself (Salmonella in spices, aflatoxin in tree nuts) and hazards specific to the supplier’s process. The plan also has to show that the foreign supplier has identified and is controlling those same hazards; the importer isn’t required to run the foreign facility but is accountable for knowing controls exist.

Foreign supplier evaluation and monitoring. This is the core of an importer PCP and goes well beyond a contact list. It needs to document how new suppliers are selected and evaluated before the first shipment, how often existing suppliers get re-evaluated, what documentation is collected (certificates, audit reports, COAs), what happens when a supplier’s standing changes (lapsed certification, a foreign regulator’s warning), and what import controls are used for high-risk commodities (sampling, arrival testing, verification testing).

Consumer protection / labelling compliance. The plan must show how imported food meets Canadian labelling and packaging standards: bilingual requirements, accurate ingredient statements, allergen declarations, correct net quantity, and applicable grade or identity standards. This is flagged as a common gap — importers often document food safety thoroughly but skip labelling verification, which CFIA treats as a plan deficiency.

Verification that the plan is actually working. A procedure for confirming the PCP is implemented and effective, typically through periodic review of supplier documentation and audit records.

Q1 Do all Canadian food importers need a Preventive Control Plan?

A1 Most commercial food importers holding a Safe Food for Canadians (SFC) licence are required to maintain a written PCP under Part 4 of the SFCR. Exemptions apply to certain low-risk or small-volume activities. The CFIA’s interactive PCP tool can confirm whether your specific import activity requires a written plan.

Q2 What is the difference between an importer PCP and a manufacturer PCP?

A2 A manufacturer’s PCP focuses on the food safety controls applied within the facility — temperature controls, sanitation, CCP monitoring, and so on. An importer’s PCP focuses primarily on foreign supplier assessment and verification, because the importer does not directly control what happens at the production facility overseas. The importer is accountable for ensuring those foreign controls are adequate, and the PCP documents how that assurance is obtained and maintained.

Q3 What happens if my SFC licence is not declared at the border?

A3 Since February 2024, import transactions submitted through the CFIA’s Integrated Import Declaration (IID) system are automatically rejected if a valid SFC licence is not declared. Your shipment will be denied entry into Canada until the licensing error is corrected and the import declaration is resubmitted. The licence must be active, issued for ‘Importing Food,’ and cover the specific commodities being imported.

Q4 How do I verify that my foreign supplier meets Canadian food safety requirements?

A4 SFCR accepts several approaches: conducting on-site audits of the foreign facility (yourself or through a third party), relying on internationally recognized certification schemes (SQF, BRC, FSSC 22000) if the supplier is in good standing, or sourcing from suppliers in countries that CFIA has recognized as having equivalent food safety systems (such as the US or EU member states). Your PCP must document which approach you use for each supplier and product category.

Q5 Does my importer PCP need to cover labelling compliance?

A5 Yes. Your PCP must describe how you ensure that imported food meets Canadian consumer protection requirements, including labelling and packaging standards. This means verifying that products meet bilingual labelling requirements, correct allergen declarations, net quantity declarations, and applicable Canadian grade or identity standards before they enter the Canadian market. Missing this element is a common gap that CFIA inspectors identify during importer inspections.

Q6 How long do I need to keep importer PCP records?

A6 Section 89(2) of the SFCR requires importers to retain records showing the PCP has been implemented for a minimum of two years. This includes supplier evaluation records, import documentation, test results, complaint logs, recall records, and corrective action documentation.

Q7 How long does it take to develop an importer PCP?

A7 For a typical importer covering multiple product categories and suppliers, expect four to eight weeks to develop a complete, inspection-ready PCP. The timeline depends largely on how many commodities and suppliers are involved, whether those suppliers have internationally recognized certifications, and how much existing documentation (specifications, supplier questionnaires, quality agreements) is already in place.

Q8 Can FTC International help me develop or review my importer PCP?

A8 Yes. FTC International has developed Preventive Control Plans for Canadian food importers across a wide range of commodity categories. We offer a free 30-minute initial assessment to evaluate whether your existing plan meets current SFCR requirements, or to scope a new PCP development engagement. Contact us through our website to arrange a consultation.

Q9 Does my importer PCP need to be updated when I add new suppliers or new products?

A9 Yes. Your PCP must be kept current and must reflect your actual import operation. Adding a new food category, sourcing from a new supplier, or importing from a new country of origin typically requires a plan update — including a new or updated hazard analysis and supplier evaluation for the new product or source. CFIA expects your PCP to be a living document, not a static file.

Q10 What is a non-resident importer and do they need a PCP?

A10 A non-resident importer is a foreign company that imports food into Canada without a physical Canadian business address. Non-resident importers are subject to the same SFC licensing and PCP requirements as Canadian-resident importers. Their SFC licence must be issued specifically for the activity of ‘Importing Food’ — selecting ‘Exporting Food’ is a common error that results in rejected import transactions.