Annex Q: Procedures for Importation of Foods that Contain Fish and Meat Products

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1. Scope

This document outlines the regulations, policies and procedures governing the inspection of foods containing both meat and fish ingredients.

2. Regulations

Fish Inspection Regulations
Meat Inspection Regulations, 1990

Fish Inspection Regulations

3. (2) Subject to subsections (3) and 6(4), these Regulations do not apply to

  • (a) fish that is imported or exported for personal consumption or use; or,
  • (b) a food that meets the following specifications, namely,
    • (i) the food is a mixture of a fish product and a meat product,
    • (ii) the food is commonly recognized as a meat product, having regard to:
      • (A) the relative proportions and type of the fish and meat ingredients present in the food,
      • (B) the common name of the food,
      • (C) the type of processing applied to the fish and meat ingredients, and
      • (D) the historical recognition of the food as a meat product,
    • (iii) the food is processed in an establishment registered in accordance with the Meat Inspection Regulations, 1990 or a foreign establishment authorized to export meat products to Canada in accordance with those Regulations, and
    • (iv) the fish product used in the preparation of the food originates from an establishment registered in accordance with these Regulations or the fish product has been imported into Canada in compliance with these Regulations.

3.1 No person shall prepare in a registered establishment a food that is a mixture of a fish product and a meat product unless:

  • (a) the establishment is also registered in accordance with the Meat Inspection Regulations, 1990; or,
  • (b) the food is exempt from the application of sections 7 to 9 of the Meat Inspection Act because of paragraph 3(1) (l) of the Meat Inspection Regulations, 1990.

Meat Inspection Regulations, 1990

The following foods containing a meat product are exempted from the operation of sections 7, 8 and 9 of the Meat Inspection Act:

  • (1) a food that meets the following specifications, namely;
    • (i) the food is a mixture of a fish product and a meat product;
    • (ii) the food is commonly recognized as a fish product, having regard to:
      • (A) the relative proportions and type of the fish and meat ingredients present in the food;
      • (B) the common name of the food;
      • (C) the type of processing applied to the fish and meat ingredients; and,
      • (D) the historical recognition of the food as a fish product,
    • (iii) the food is processed in an establishment registered in accordance with the Fish Inspection Regulations or has been imported into Canada in compliance with those Regulations, and
    • (iv) the meat product used in the preparation of the food originates from an establishment registered in accordance with these Regulations or a foreign establishment authorized to export meat products to Canada in accordance with these Regulations.

43.1 No person shall prepare in a registered establishment a food that is a mixture of a fish product and a meat product unless

  • (a) the establishment is also registered in accordance with the Fish Inspection Regulations; or,
  • (b) the food is exempt from the application of the Fish Inspection Regulations because of paragraph 3(2) (b) of those Regulations.

3. Policy

3.1 A person may send an application to the Canadian Food Inspection Agency (CFIA) requesting exemption from either the Meat Inspection Regulations, 1990 or Fish Inspection Regulations for a food containing meat and fish ingredients.

3.2 The application will be evaluated by the Fish, Seafood and Production Division and the Meat Programs Division to classify the food as either a fish product or a meat product.

>3.3 Foods containing both meat and fish ingredients that are classified as a fish product will be exempt from the requirements of the Meat Inspection Regulations, 1990. Factors to classify the food as a fish product include, but are not limited to:

  • the proportion of the fish and meat ingredients;
  • description of the food;
  • common name;
  • level of processing applied to the components to manufacture the food; and,
  • historical (commercial and/or public) recognition of the food as a fish product.

3.4 Foods containing both meat and fish ingredients that are classified as a meat product will be exempt from the requirements of the Fish Inspection Regulations. Factors to classify the food as a meat product include, but are not limited to:

  • the proportion of the fish and meat ingredients;
  • description of the food;
  • common name;
  • level of processing applied to the components to manufacture the food; and,
  • historical (commercial and/or public) recognition of the food as a fish product.

3.5 When a fish processing establishment processes a food containing both meat and fish ingredients that is classified as a fish product, the processor will be required to use meat ingredients that are ready to be incorporated into the final product. Processing of the meat ingredients will be limited to trimming or cutting boneless meat products (e.g. sliced bacon, bacon slabs, cooked ham, roast beef, chicken meat, etc.) to allow the processor to incorporate the meat into the product and any actions needed to assemble the final product. Other processes, including actions such as deboning, cooking or curing meat products will not be permitted.

Processes including, but not limited to cooking or breading, may be performed on the food in its final assembled form. Details on accepted processes can be found in the list of exempted products in section 5 of this annex.

3.6 When a meat processing establishment processes a food containing both meat and fish ingredients that is classified as a meat product, the processor will be required to use fish ingredients that are ready to be incorporated into the final product. Processing of the fish ingredients will be limited to trimming or cutting the fish meat (e.g. fillets, smoked fish fillets, fish pastes, shellfish meats, lobster/crab meat, peeled shrimp, etc.) to allow the processor to incorporate the fish into the product and any actions needed to assemble the final product. Other processes, including actions such as heading and eviscerating, filleting, shucking shellfish or the removal of crustaceans from the shell will not be permitted.

Processes including, but not limited to cooking or breading, may be performed on the food in its final assembled form. Details on accepted processes can be found in the list of exempted products in section 5 of this annex.

3.7 A fish establishment can process food containing meat and fish ingredients only if:

  • the food is commonly recognized as a fish product and is exempt from the Meat Inspection Regulations, 1990; and
  • the meat ingredients originate from an establishment registered under the Meat Inspection Regulations, 1990, or a foreign establishment eligible to export meat products to Canada.

3.8 A meat establishment can process food containing meat and fish ingredients only if:

  • the food is commonly recognized as a meat product and is exempt from the Fish Inspection Regulations; and
  • the fish ingredients originate from an establishment registered under the Fish Inspection Regulations, or were imported into Canada in compliance with the Fish Inspection Regulations.

3.9 Foods containing meat and fish ingredients that cannot be classified as either a fish product or a meat product following the conditions described under items 3.3 and 3.4 above, must be processed and/or imported in accordance with both the Meat Inspection Regulations, 1990 and Fish Inspection Regulations.

4. Procedures

4.1 Applications for exemption shall include a label of the product and, on the manufacturer's letterhead, the recipe indicating the percentage of every ingredient used as well as the method of preparation of the product. Detailed composition of any prepared meat or fish product ingredients must also be provided to assess the compatibility of the meat or fish product with the Canadian legislation related to the composition of the food. The request for exemption along with the relevant documents shall be addressed to the Director, Meat Programs Division, Canadian Food Inspection Agency Headquarters, Ottawa, ON K1A 0Y9, and to the Director, Fish, Seafood and Production Division, Canadian Food Inspection Agency Headquarters, Ottawa, ON, K1A 0Y9.

4.2 Each application will be reviewed by a designated officer of the, Meat Programs Division and the Fish, Seafood and Production Division to classify the food as either a meat product or a fish product.

4.3 A list of exempted products is provided in section 5 of this annex.

4.4 The Regional Director will identify appropriate personnel to verify that a company that processes or imports an exempted product listed in section 5 is composed of acceptable ingredients as described under items 4.5 and 4.6 below.

When a company wishes to process or import a food containing meat and fish ingredients that is not listed in section 5 of this annex, the representative of the company will be advised of the procedures identified under item 4.1 above.

4.5 A food containing meat and fish that is classified as a fish product will be inspected in accordance with the requirements identified under the Fish Inspection Regulations, and must comply with all applicable Canadian regulations, including, but not limited to the Food and Drug Regulations.

The importer of a food containing meat and fish recognized as a fish product must hold either a valid Fish Importers Licence or a valid Quality Management Program Import Licence. The importer must provide written notification of each shipment to the appropriate CFIA inspection office and each shipment will be subject to inspection in accordance with the policies and procedures described in Chapter 3 of the Fish Products Inspection Manual.

The importer must be able to demonstrate that the meat component of a food containing meat and fish that is recognized as a fish product could be legally imported into Canada. This means that the meat component must comply with the Meat Inspection Regulations, 1990 and other applicable Canadian regulations, including but not limited to, the Health of Animals Regulations and the Food and Drug Regulations. For example, the use of a meat ingredient that contains non-approved additives or that originates from a region restricted for animal health diseases will not be permitted.

In order to demonstrate that the meat ingredients comply with Canadian requirements, the importer must include the country and the establishment number where the animal was slaughtered, and the country and establishment number where the meat was processed with their written import notification form.

4.6 A food containing meat and fish that is classified as a meat product will be inspected in accordance with the requirements identified under the Meat Inspection Regulations, 1990, and must comply with all applicable Canadian regulations, including, but not limited to the Food and Drug Regulations. The food will be subject to inspection in accordance with the policies and procedures described in Chapter 4 of this same manual.

The importer of a food containing meat and fish recognized as a meat product must be able to demonstrate that fish component could be legally imported into Canada. This means that the fish component must comply with the requirements described in applicable Canadian regulations, including but not limited to the Fish Inspection Regulations and the Food and Drug Regulations. For example, the use of a fish component such as raw shellfish (e.g. mussels, clams or oysters) that contains non-approved additives or that originates from non-approved sources will not be permitted.

Imports will be subject to inspection in accordance with the policies and procedures described in Chapter 10 of the MOP.

5. Classification of Products Containing Meat and Fish

See the Table of Accepted Processes and Ingredients at the CFIA website for:

  • Foods containing meat and fish that are classified as fish products and exempt from the Meat Inspection Regulations, 1990.
  • Foods containing meat and fish that are classified as meat products.
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