D-15-04: Audit-based Compliance Program for the Export of Canadian Wild Rice to China

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Effective date: 16/09/22

Subject:

Canadian wild rice (Zizania palustris L. and Z. aquatica L.) intended for export to China must be processed, stored and exported by Canadian companies that are approved under this audit-based compliance program administered by the Canadian Food Inspection Agency. This directive describes: 1) the process for Canadian companies to apply for approval under this program, and 2) the specific requirements that must be met for the processing, storage and exportation of Canadian wild rice in order to meet the requirements of China.

Review

This directive will be updated as required. For further information or clarification, please contact the Canadian Food Inspection Agency (CFIA).

Introduction

In September 2015, the Canadian Food Inspection Agency (CFIA) and the General Administration of Quality Supervision, Inspection and Quarantine (AQSIQ) of the People's Republic of China signed the Protocol on the Inspection and Quarantine Requirements for Exporting Wild Rice from Canada to China (referred to as the Protocol hereinafter). The signing of the Protocol provides new market access for Canadian wild rice (Zizania palustris L. and Z. aquatica L.) to China.

In order to facilitate exports and comply with the requirements listed in the Protocol, the CFIA has developed an audit-based compliance program. Any company that is processing, storing or exporting Canadian Wild rice to China must have a compliance agreement with the CFIA. The audit-based compliance program will verify that:

  • the origin of the wild rice exported to China is Canadian;
  • companies processing, storing and exporting wild rice comply with the requirements of Section 2.3 of this directive; and
  • each wild rice shipment to China is accompanied by an Export Certificate issued by the exporter, which attests to the origin (processing and storage facility) of the wild rice and the processing conditions (temperature and moisture content).

Scope

The information in this directive is intended for use by CFIA staff appointed as inspectors under the Plant Protection Act, and companies intending to process, store, and export Canadian wild rice to China.

Definitions, Abbreviations and Acronyms

Definitions for terms used in the present document can be found in the Plant Health Glossary of Terms.

1. General Requirements

1.1 Legislative Authority

Canadian Food Inspection Agency Act
Plant Protection Act
Plant Protection Regulations
Canadian Food Inspection Agency Fees Notice

1.2 Fees

The CFIA is charging fees in accordance with the Canadian Food Inspection Agency Fees Notice. Anyone requiring other information regarding fees may contact any local CFIA office or visit the CFIA Fees Notice web page.

1.3 Regulated Commodities

Wild rice grain (Zizania palustris L. and Z. aquatica L.) produced in Canada and intended for export to China.

1.4 Regulated Areas

All areas of Canada.

2. CFIA Wild Rice Program Requirements

2.1 Application requirements

Canadian companies intending to process, store or export Canadian wild rice to China must apply to participate in this compliance program by completing the application (Appendix 1) along with supporting documentation and submitting it to their local CFIA office.

2.2 CFIA Inspection Requirements

The CFIA will conduct:

  • initial reviews of the application and supporting documentation, and evaluation audits of each company prior to their approval in order to evaluate the systems used in the processing, storage, and exporting of Canadian wild rice to China.
  • annual audits of approved companies to verify compliance with the program.

The CFIA retains the option to visit the company at any time to sample wild rice for visual inspection, to review records and to verify compliance.

2.3 Program Requirements

The program requirements outlined in Appendix 2 provide the list of relevant requirements that companies intending to process, store and export wild rice to China must meet in order to be approved under the program. The requirements in Appendix 2 can be used as an outline by companies to develop their Standard Operating Procedures (SOP) document, which must be submitted along with their application as supporting documentation for approval under this program. All companies must cooperate with the CFIA during inspections and allow CFIA access to records so that program compliance can be verified.

2.3.1 Company requirements:

  • All companies approved to process and store wild rice in Canada under D-15-04 must be able to demonstrate to the satisfaction of an Inspector that:
    • Pest monitoring traps for insect pests have been installed and are being maintained regularly. These traps must be monitored, with data collected and compiled for auditing/reporting purposes by the CFIA.
    • Measures have been implemented to prevent wild rice from mildewing or being mixed with soil particles, plant residues, or weed seeds, or being comingled or contaminated with other grains or impurities.
  • All companies processing wild rice in Canada under D-15-04 must be able to demonstrate to the satisfaction of an Inspector that:
    • The wild rice has undergone heat treatment at a temperature between 150-350°C (302-662°F) for approximately 2 hours and that a moisture content of 5% to 8% has been achieved.
    • Lot Treatment Certificates(Appendix 3) will be issued, which attests that a specific lot of wild rice has been processed to meet the temperature, moisture and viability requirements stated in the Protocol.
    • Records of all Lot Treatment Certificates issued will be retained for a minimum of two years and made available to the CFIA during the annual verification audit or when requested.
    • The processed wild rice is being stored under hygienic conditions and in new, spill-proof packaging; and
    • Twice per year at approximately six month intervals, sampling of wild rice is initiated, and subsequent testing is completed at a CFIA-accredited lab to verify non-viability using established standard methods (e.g., germination or tetrazolium test)
    • Their use of an internal tracking system(s) allows the origin of all wild rice in storage that is intended for export to China, to be traced back to the grower / supplier confirming that it was produced in Canada.
  • Companies storing wild rice in Canada under D-15-04 must be able to demonstrate to the satisfaction of an Inspector that:
    • Their use of an internal tracking system(s) allows the origin of all wild rice in storage that is intended for export to China to be traced back to an approved wild rice processing facility; and
    • The processed wild rice is stored under hygienic conditions and in new, spill-proof packaging.
  • Companies exporting wild rice under D-15-04 must be able to demonstrate to the satisfaction of an Inspector that:
    • The wild rice that is to be exported to China is procured only from companies approved under this directive;
    • The internal tracking system(s) allows for an exported shipment to be traced back to the approved wild rice processing where it was processed and the storage facility where it was stored if applicable;
    • Export Certificates (Appendix 4) are being properly completed for each lot of wild rice exported to China and are based on corresponding Lot Treatment Certificates that have been obtained from approved processors;
    • Copies of all Export Certificates issued will be retained for a minimum of two years and made available to the CFIA during the annual verification audit or when requested;
    • The wild rice packages are labelled as per the program requirements (Appendix 2).

2.4 CFIA approval of facilities under Directive D-15-04

Once a company intending to process, store or export wild rice to China has been audited by the CFIA, and has been assessed as meeting the requirements of Sections 2.3, an approval letter will be issued to them by the CFIA (Appendix 5). Within this letter, a unique identification number will be assigned to the company (CFIA-WRC-XX). The approved company (processor, storage warehouse, or exporter) name and address and the CFIA- issued unique identification number will be shared with AQSIQ. Approved companies will be identified as "approved for export" and listed on AQSIQ's website.

3. Responsibilities

3.1 CFIA responsibilities

The Inspector is responsible for:

  • Evaluating and approving the application package submitted by the company including the application for approval, written standard operating procedures, applicable templates of forms, records, etc.;
  • Completing the initial on-site evaluation audit of a company to verify that the standard operating procedures are being implemented and that there is overall compliance with the requirements of the program;
  • Completing annual audits of each approved company to confirm they are continuing to comply with the requirements of the export program. The CFIA will request and review written records maintained by companies during annual verification audits or when required;
  • Obtaining a unique identification number from the CFIA-Grains and Oilseed Section in Ottawa and assigning it to the company;
  • Issuing the approval letter to the company (Appendix 5) or a letter advising the company that their evaluation audit has been unsuccessful (Appendix 6);
  • Sharing pest trap monitoring data with the CFIA-Grains and Oilseed Section in Ottawa when requested, to be further shared with AQSIQ; and
  • Sending a signed copy of the compliance agreement and the approval letter to the National Manager, Grains and Oilseeds Section in Ottawa. The CFIA-Grains and Oilseed Section will inform AQSIQ as wild rice processing and storage companies, and exporters are approved or removed from this compliance program so that AQSIQ's list is up to date.

3.2 Company's responsibilities

The company is responsible for:

  • Completing and submitting the initial application for approval as well as supporting documentation;
  • Providing full co-operation to CFIA inspection staff during evaluation audits and annual audits, including providing access to all requested records;
  • Following the company requirements as outlined in Section 2.3, as well as adhering to their written standard operating procedures in the areas of heat treatment, pest management and product purity / integrity;
  • Issuing the required documentation (example: Lot Treatment Certificates and Export Certificates) as per established requirements;
  • Ensuring export package labelling requirements are met;
  • Retaining documents and records as per the program requirements for the established two year period.

4. Non-compliance

The CFIA may suspend or revoke a company's approval status at any time upon finding a critical non-compliance with the requirements specified in this directive. A critical non-compliance is defined as any non-compliance that would compromise the integrity of this program. Companies with their status suspended or revoked may not process, store or export wild rice destined to China. The CFIA will immediately notify AQSIQ of any facilities that have had their approval revoked.

A company's approval status may be suspended or revoked when a Notice of Non-compliance (NNC) is received from China and identifies a non-compliance with a specific requirement under this directive.

The company needs to explain and demonstrate to the satisfaction of CFIA, that the corrective action(s) taken adequately address the non-compliance, prior to a suspension being lifted. If a facility's status has been revoked, they will be required to submit a new application following the completion of the corrective actions in order to initiate a new approval process for their facility.

Appendix 1: Application for Approval Under the Audit-based Compliance Program for the Export of Canadian Wild Rice to China

Company Name:space

Scope of Wild Rice Operations:
Processor
space
Independent warehouse
space
Exporter
space

Contact person name: space

Address: space

Telephone: space

Fax: space

Email: space

This agreement certifies that the Canadian wild rice will be processed, stored and exported by companies who have been approved by the Canadian Food Inspection Agency (CFIA) according to the requirements specified in D-15-04, Compliance Program for the Export of Canadian Wild Rice to China.

The above company shall:

  1. Allow the CFIA to conduct audits of the company as required to verify compliance under the audit-based program, D-15-04.
  2. Maintain records for two years, including the origin of the wild rice that is intended for export to China.
  3. Maintain a current written protocol describing the process that will be used to ensure that the wild rice is rendered non-viable. (Applicable to processors).
  4. Maintain a current written protocol describing pest management practices, and management practices that ensure the wild rice does not become contaminated with soil, weed seeds, plant material, etc. during processing and is stored as per Section 2.3 of D-15-04. (Applicable to processors and warehouses).
  5. Maintain and monitor pest traps, with data collected and compiled for auditing/reporting purposes by the CFIA.
  6. Include with all shipments of wild rice an Export Certificate containing the information summarized in Section 3.2 and Appendix 4 of Directive D-15-04. (Applicable to exporters).
  7. Agree to the CFIA sharing with AQSIQ the information regarding business name, address and approval status under the Audit-based Compliance Program for the Export of Canadian Wild Rice to China, and to the publication of the information on the AQSIQ website. (Applicable to processors, warehouses and exporters).

Further, I am and shall be responsible for and shall indemnify and save harmless Her Majesty the Queen in Right of Canada, including the Canadian Food Inspection Agency, Her officers, Employees, Successors and Assigns, from and against all manners of actions, causes of action, claims, demands, loss, costs, damages, actions or other proceedings by whomsoever made, sustained, brought or prosecuted in any manner based upon, caused by, arising out of, attributable to or with respect to any failure, inadvertent or otherwise, by act or omission, to fully comply with the said terms, conditions and requirements.

Company Contact:

Print Name: space Signature: space

Date: space

Company Recommended for Approval by: (for CFIA use)

Print CFIA Inspector's Name: space Signature: space

Date: space

Approved for Participation in the Audit-based Compliance Program for the Export of Canadian Wild Rice to China:

  1. Processor space approved
  2. Independent Warehouse space approved
  3. Exporter space approved

CFIA Regional Program Officer:

Name: space Signature: space

Date: space

CFIA Assigned Facility Approval Number CFIA-WRC-space

Appendix 2: CFIA Audit Checklist - Wild Rice for Export to China

Company Name: space

Scope of Wild Rice Operations:
Processor
space
Independent warehouse
space
Exporter
space

Contact person name: space

Section 1.0 Application for approval and supporting documentation requirements
Requirement Requirement fulfilled
**completed by company
Assessed as compliant by the CFIA CFIA Comment CAR#
i) application is complete and signed by applicant Yes No
ii) Supporting documentation is included in submission package and is completed included:
written Standard Operating Procedure on wild rice processing steps (processor) Yes No
pest management plan (processor and warehouse) Yes No
wild rice purity management plan (processor and warehouse) Yes No
examples of developed forms: Lot Treatment Certificate (Processors), Export Certificate (Exporters) Yes No
Certificate of analysis documenting non-viability of processed wild rice is supplied (Processors) Yes No
Section 2.0 Heat Processing of Wild Rice (Processors)
Requirement Requirement fulfilled
**completed by company
Assessed as compliant by the CFIA CFIA Comments CAR#
i) there is functioning instrumentation to measure temperature during the parching processing Yes No
ii) temperature readings are being recorded
(electronically or manually)
Yes No
iii) a temperature between 150-350°C (302-662°F) is being maintained for the required duration (see below) Yes No
iv) duration (approximately 2 hours) of heat treatment at 150-350°C is being achieved and recorded Yes No

v) as validation that the processing steps are effective in devitalizing the wild rice, the processor has analysis results from an accredited lab within the last 6 months showing that the seed is non-viable or has 0% germination

In subsequent years following approval, a processor must have a minimum of two analysis (once every six months) completed, which will be verified at the time of annual CFIA audits.

Yes No
Section 2.1 Monitoring and Recording of Processed Wild Rice Moisture Levels (Processors)
Requirement Requirement fulfilled
**completed by company
Assessed as compliant by the CFIA CFIA Comments CAR#
i) there is functioning equipment to measure moisture levels in processed wild rice Yes No
ii) moisture content of wild rice lots is being measured following the processing of lots Yes No
iii) moisture levels are being recorded as per the procedure outlined in the company's standard operating procedures Yes No
iv) moisture level of wild rice lots processed for export to China is documented at 5% to 8% Yes No
Section 2.2 Lot Treatment Certificates (Processors)
Requirement Requirement fulfilled
**completed by company
Assessed as compliant by the CFIA CFIA Comments CAR#
i) Lot Treatment Certificates are being prepared and issued for lots being exported to China as per operating procedures Yes No
ii) copies of Lot Treatment Certificates issued are being kept on file Yes No
iii) records are maintained that document that the wild rice is received from Canadian producers and is of Canadian origin Yes No
Section 3.0 Pest Management (Wild Rice Processors and Warehouses)
Requirement Requirement fulfilled
**completed by company
Assessed as compliant by the CFIA CFIA Comments CAR#
i) a written pest management plan is on file Yes No
ii) pest management procedures are detailed in the management plan covering stored grain insects, rodents and birds Yes No
iii) types of traps and distribution within the facility are detailed in the plan
Examples: pitfall traps for stored grain insect monitoring, rodent traps, etc.
Yes No
iv) the monitoring / reporting schedule for pest trap monitoring is included as part of the pest management plan (example: monthly) Yes No
v) a template of a pest reporting form is developed, which will be completed as per the monitoring frequency established by the company. (the template must include information on the monitoring date, trap results, pests identified, corrective action taken). The report will be maintained on file and made available to CFIA upon request Yes No
vi) a written plan on measures in place to prevent the mixing or contamination of processed wild rice with other grains, husks, stems, branches, leaves, weed seeds, and soil particles is on file Yes No
Section 4.0 Package Labelling (Wild Rice Processors and Exporters)
Requirement Requirement fulfilled
**completed by company
Assessed as compliant by the CFIA CFIA Comments CAR#
i) the company has previously provided an example of their export label (tag, label, stencil) as part of their application submission Yes No

ii) the company is labelling wild rice shipments as per their written procedures and includes the following information:

  • "To the People's Republic of China" in both Chinese and English text (Chinese text: 输往中华人民共和国)
  • wild rice variety (genus and species)
  • exporter name
  • exporter address
  • exporter's identification number assigned by CFIA
  • processing facility's identification number assigned by CFIA
Yes No
iii) records are maintained of all wild rice lots / shipments labelled to meet Chinese import requirements Yes No
iv) packaging used is new and clean and free of contamination with pests or harmful substances Yes No
Section 5.0 Export Certificates (Wild Rice Exporters)
Requirement Requirement fulfilled
**completed by company
Assessed as compliant by the CFIA CFIA Comments CAR#
i) exporter is obtaining Lot Treatment Certificates from the processor prior to issuing Export Certificate Yes No
ii) Export certificates issued correspond to Lot Treatment Certificates (shipment identification number) and are received and retained on file

iii) Exporter understands requirement to issue Export Certificate as per the copy provided with their original application submission, which include the following information:

  • exporter name
  • exporter address
  • unique identification number assigned to the exporter by the CFIA
  • processing facility's identification number
  • Shipment identification number

Treatment details:

  • Temperature
  • Duration
  • Moisture content
  • name and signature of exporter representative
  • date
iv) Export certificates being issued follow format of certificate templates submitted in application package
v) Export certificates (copies) will or are being maintained in a file that this available for review by the CFIA and are completed correctly

Inspector's Name: space

Inspector's Signature: space

Date: space

Appendix 3: Example of a Lot Treatment Certificate to be completed by Approved Wild Rice Processors

"Lot Treatment Certificate" (note: mandatory title that must be used on certificates)

The following information fields and attestation below must appear on the certificate

Processing Company Name:

Processing Company Address:

CFIA Approval Number Assigned to Processing Company: (CFIA-WRC-XX)

Shipment Identification Number [Lot Number(s)]:

This certificate attests that the wild rice in this consignment was grown in Canada and manufactured under the following treatment conditions:

Temperature:

Duration of heat treatment at the above temperature:

Moisture content of the product following heat treatment:

Name of processing company representative:

Signature:

Date:

Appendix 4: Example of Export Certificate Issued by the Approved Wild Rice Exporter

Export Certificate Under Protocol Between the Canadian Food Inspection Agency (CFIA) and the General Administration of Quality Supervision, Inspection and Quarantine (AQSIQ) of the People's Republic of China for Wild Rice Exports to China (Mandatory title that must be used on all certificates)

The following information fields and attestation below must appear on the certificate:

Exporter Name:

Shipment Identification Number:

CFIA Exporter Unique Identification Number: CFIA - WRC- XX

This certificate attests that the wild rice in this consignment was manufactured according to the following treatment details:

Processing Company's CFIA Approval Number: CFIA-WRC-XX

Temperature:

Duration:

Moisture content:

Signed by the CFIA Approved Exporter

Name:

Signature:

Date:

Appendix 5: Example of Approval Letter for Successful Evaluation Audit

[print on CFIA letterhead]

[Company name and address]

[date]

Dear [name],
An inspection of (enter facility name and location here), on (enter date), has confirmed that your company meets the requirements as outlined in D-15-04: Audit-based Compliance Program for the Export of Canadian Wild Rice to China.

By way of this letter, I am confirming that (enter company name and location here) is approved to (process/store/export) Canadian wild rice to China.

To maintain this approval, your company will be subject to an annual audit inspection by the CFIA as outlined in the directive D-15-04.

The unique CFIA identification number that has been assigned to your facility is:

CFIA - WRC -space

Further to your consent during the application process, the CFIA will share with the General Administration of Quality Supervision, Inspection and Quarantine of the People's Republic of China (AQSIQ) the information regarding your business name and address, your approval status under the program, and the unique CFIA identification number that has been assigned to your company. The information shared will be published by AQSIQ on its website.

If you have questions or concerns regarding this compliance program, please do not hesitate to contact me.

Yours truly,

Regional Program Officer, Plant Protection

CC: National Manager, Grains and Oilseeds Section, CFIA

Appendix 6: Example of a Letter for an Unsuccessful Evaluation Audit

[print on CFIA letterhead]

[Company name and address]

[date]

Dear [name],
An evaluation audit of (enter facility name and location here), on (enter date), has determined that your company at this time does not meet the requirements outlined in D-15-04: Audit-based Compliance Program for the Export of Canadian Wild Rice to China.

By way of this letter, I am confirming that (enter company name and location here) your company is not approved to (process/store/export) Canadian wild rice to China.

The following deficiencies identified during the evaluation audit that raised questions as to whether the program requirements for (processing / storing, exporting) wild rice to China could be met by your company.

When you feel that the identified deficiencies have been corrected through modifications to procedures, infrastructure, documentation, etc., please forward us written details of the changes that have been implemented. A determination will be made at that time on whether an on-site follow-up to the original evaluation audit is required at your company premises.

If you have questions or concerns regarding the results of our evaluation audit, or of the compliance program for the export of wild rice to China, please do not hesitate to contact me.

Yours truly,

Regional Program Officer, Plant Protection

CC: National Manager, Grains and Oilseeds Section, CFIA

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