Repeal of Requirements for Pre-Market Registration of Labels and Recipe for Certain Meat and Processed Products

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What changes has the CFIA made to the Meat Inspection Regulations and the Processed Products Regulations?

The CFIA has eliminated the mandatory pre-market registration of labels and recipe for meat and meat products and processed fruits and vegetables.

Sections 110 of the Meat Inspection Regulations and Section 25(1) and 44 of the Processed Products Regulations have been amended.

When did this change come into force?

These changes are effective immediately.

The changes will be published in Canada Gazette, Part II on May 8, 2013.

Why did the CFIA make these regulatory changes?

Label registration was identified as part of the Government of Canada's Red Tape Reduction initiative. As a result, these regulatory changes assist the CFIA in responding to the recommendations made as part of that initiative.

By eliminating pre-market registration activities, the CFIA can focus its efforts and activities on its primary mandate of food safety. In addition, these changes create a level playing field since pre-market registration is not required for other sectors of the food industry.

Does this change affect food safety?

No. This change does not affect food safety. Industry remains responsible for ensuring that their labels are compliant with current regulations. Canadian labelling rules and requirements related to food safety and consumer protection are not changing as a result of these amendments.

The CFIA will continue to conduct inspection activities to verify that labelling of all food commodities meet Canadian regulatory requirements. When issues of non-compliance are found, the CFIA will continue to take non-compliance and enforcement actions.

How does this affect industry?

The CFIA no longer requires industry to pre-register labels and recipes for meat and processed fruits and vegetables. By removing this step, these products will get into the marketplace faster.

Industry remains responsible for ensuring that their labels are compliant with current regulations. Canadian labelling rules and requirements related to food safety and consumer protection are not changing as a result of these amendments.

The Label and Recipe Registration Unit is currently reviewing my label submission. What happens with this submission?

The Label and Recipe Registration Unit will continue to process any submissions that were submitted to the unit prior to the repeal of the regulations. The labels will be reviewed and the submitter will not be charged by the CFIA.

New submissions received after the repeal of the regulations will be returned to the company without registration as the CFIA will not have the regulatory authority to register labels and recipes.

If the documents I am using require a label registration number, what do I do?

If the label for the product was previously registered, that number can still be entered. If there is no registration number, the appropriate field can be left blank.

Can I destroy all of my label registration files?

It is recommended that you keep and store label registration files for a period of 10 years.

Do I have to send my labels somewhere else now that the CFIA's Label and Recipe Registration Unit is closing?

No. Companies do not have to send labels to the CFIA or anywhere else for pre-market registration. However, companies are still required to comply with all federal acts and regulations regarding labelling.

If I don't have to register my labels with the CFIA, can I put anything I want on them?

No. There are no changes to labelling acts and regulations related to food safety and consumer protection. Companies are still required to comply with all federal acts and regulations regarding labelling. The CFIA will continue to enforce all labelling requirements including those related to allergens, nutrition, and compositional standards.

If I want help with my label, who can I ask?

There are many resources available to companies to accomplish this task, including the CFIA's Industry Labelling Tool, the Meat Inspection Act and Regulations, the Canadian Agricultural Products Act, the Processed Products Regulations, Consumer Packaging and Labelling Act and Regulations and guidance documents such as the Meat Manual of Procedures. In addition, several independent service providers offer labelling advice to industry.

How will the CFIA verify that labels used by the food processing establishments meet the regulatory requirements?

CFIA inspectors verify as part of routine inspection activities, that labels on domestic and imported products meet all applicable regulatory requirements. When non-compliance actions are notices as part of inspection activities, appropriate non-compliance or enforcement actions are taken.

What enforcement actions will the CFIA take when the food industry does not comply with the applicable regulatory labelling requirements?

The CFIA takes a risk-based approach to compliance management. When the CFIA identifies non-compliance with the legislation it administers and enforces, it has a number of tools it can take as per the Compliance and Enforcement Operational Policy.

These enforcement actions may include:

  • the issuance of warning letters or penalties;
  • a request for corrective actions within a specified timeframe;
  • the suspension or cancellation of licenses, registrations or permits for federally registered establishments;
  • a recommendation to the Public Prosecution Service of Canada that violators be prosecuted, depending on the severity of the violation or the escalation of enforcement actions;
  • the seizure and detention of shipments and products or if there is a need to control the movement of certain products, for reasons such as health, safety and quality;
  • the recall of products if it is determined that the products pose a risk to consumers; and/or,
  • the refusal of imported products for entry to Canada or the order to remove imported products from Canada.
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