Food Importers May Soon Need a License: KPMG Trade and Customs Tax Alert

Sep 23, 2010 | Corporate Member News

The Canadian Food Inspection Agency (CFIA) recently proposed regulatory changes to enhance Canada’s import controls on food products. These proposals include establishing minimum food safety and labelling requirements for imported foods and licensing of certain food product importers. The CFIA is seeking feedback on the proposed changes by October 4,  2010.

Importers of the following food products may be affected by the proposed changes:

  • Alcoholic and non-alcoholic beverages    
  • Confectionary
  • Fats and oils
  • Infant formula
  • Coffee and tea
  • Cereals
  • Spices and seasoning
  • Juices
  • Bakery products.

These changes do not apply to importers of:

  • Processed fruits and vegetables
  • Meat and poultry
  • Dairy products
  • Egg products
  • Honey and maple products
  • Seafood
  • Fresh fruit and vegetables
  • Synthetic colours
  • Bottled water.

KPMG’s observation
The CFIA has confirmed that non-resident importers cannot hold an import licence under the proposed regulations.

The changes would affect importers who import food products in the Non-Federally Registered Sector, which includes all food and food ingredients regulated solely under the Food and Drugs Act. Once the proposed regulations come into force, Non-Federally Registered Sector products that fall within this scope would be known as the Imported Food Sector.

The proposal has two parts— general provisions to establish minimum food safety and labelling requirements for imported foods, and licensing provisions to make it mandatory for anyone importing food products in the Imported Food Sector to have a license to do so.

To obtain a license, affected importers will be required to implement a written policy demonstrating that they have food safety systems in place that will help reduce the risk of a foodborne incident linked to the products they import and process. Implementing such a policy will ensure that their products comply with the requirements of the Consumer Product Packaging and Labelling Act and regulations.

Along with these requirements, importers of products in the Imported Food Sector would also have to maintain records at an address in Canada, notify the CFIA within 24 hours if they become aware of a product that may constitute a risk to the public, and have a written recall plan.

The CFIA is recommending a 2-year phased-in approach after the regulations come into force. 

Consultations are open for comment from August 16 to October 4, 2010. The online consultation and background information can be found on the CFIA website at

We can help
For more information regarding these proposed changes to the food industry, contact your KPMG adviser or one of our Trade & Customs professionals. 

More Information?

For more information on any of these subjects, or any trade or customs issue, please contact one of KPMG’s Trade & Customs professionals:

Joseph Brick
National Practice Leader
(416) 777-8413

John Pajek
Senior Manager
(416) 777-8329

Angelos Xilinas
Senior Manager
(604) 691-3479

Click here to visit our website.

© 2010 KPMG LLP, a Canadian limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.

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