USMEF Files Comments on Canada’s Proposed Foreign Food Safety Systems Recognition Framework

As part of a comprehensive proceeding aimed at modernizing Canada’s food safety system, the Canadian Food Inspection Agency (CFIA) is accepting comments on a proposed Foreign Food Safety Systems Recognition framework.

The proceeding is still in its early stages, so the proposed framework is not yet in formal rulemaking form. But USMEF identified several key areas in need of clarification, including:

  • USMEF asks that FSIS certification of exports to Canada continue on the basis of routine systems audits, versus plant-by-plant audits or other new control measures.
  • USMEF requests that if any microbiological requirements are changed or initiated, that they are based on internationally recognized scientific standards and industry practices currently utilized in Canada and the United States.
  • Despite the launch of a pilot project on U.S.-Canada nomenclature harmonization, USMEF identified a number of prescriptive labeling requirements that remain burdensome for U.S. exporters.
  • USMEF asks that CFIA address ambiguities in Canada’s “natural” definition, which create an unnecessary burden for U.S. suppliers seeking to qualify.
  • CFIA is considering whether to allow importers to obtain an import license if they operate from the exporting country and do not have a fixed place of business in Canada. USMEF asks for clarification on what constitutes a fixed place of business.

Exporters with questions on this proceeding may email Cheyenne Dixon or call 303-623-6328. You may also contact CFIA directly at or 800-442-2342. Comments are being accepted through July 21.