Possible Back-Door FSMA Surprise for Canadian Food Businesses

FDA Recognizes Canada (Health Canada and CFIA) as “Having a Comparable Food Safety System to the U.S.” and Canada recognizes the U.S back.

You may read the full text of the Agreement:

What are the implications of this agreement? For example, should food companies in Canada and the U.S. rejoice or regret? Will meeting the Canadian food safety modernization requirements under the Safe Food for Canadians Act (SFCA) exempt food companies in Canada from needing to meet the U.S. Food Safety Modernization Act (FSMA)?

While the SFCA implementation regulations are still being drafted, the U.S. FSMA Compliance Dates have been published:

Will the development and enforcement of the SFCA regulations now be hastened in honour of this agreement?

For any food business that conducts interprovincial trade in Canada but is not exporting food to the U.S. and therefore thinks that the FSMA is a distant rumble, this agreement will soon change that perception. The logic is simple: Every food business engaged in interprovincial trade must meet SFCA requirements. The SFCA needs to be equivalent to the US-FSMA in honour of this agreement. Therefore, food businesses in Canada that conduct interprovincial trade must meet FSMA requirements. This back-door FSMA imposition is so predictable that it is even a joke to say it will be a surprise. 

Posted by Felix Amiri

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Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.