Importing and Exporting Pet Foods: Canada

Procedures for Export of US Pet Food Products into Canada

A review of the specific risks is required before the CFIA will issue an import permit. In some cases, the CFIA may require an inspection of the producing establishment in the foreign country to obtain more information before it makes a decision.

 Specific import requirements, based on the applicable animal health policies, can be reviewed in the Automated Import Reference System (AIRS).

- Animal Health Import Requirements for - Raw Inedible Products and Rendered products
- Annex 1 - Importation of Commercially Prepared Pet Food
Facility Questionnaire for Risk Assessment
- Highly Processed Products
- Import Policy for Pet Food and Treats Containing Animal Products and By-Products
- Application for a permit to import
- Notice to Industry: Changes to import and export certification requirements for shelf-stable thermally processed pet food, treats and chews for Canada and the United States

Additional government and industry information can be found at:

 Guide for the Labelling and Advertising of Pet Foods

Pet Food Association of Canada (PFAC)

 USDA's Role in Exporting Feed Products

USDA Web site on Importing Animal Products into Canada User fees are charged for the services APHIS provides related to the importation, entry, or exportation of animals and animal products 

USDA Export Verification Program for suppliers of meat and meat products

Food and Agricultural Import Regulations and Standards for Canada:
Export Certificate Report (GAIN)

FDA’s Role in Exporting Feed Products

FDA is often asked by foreign customers or foreign governments to supply a certification relating to products subject to the Federal Food, Drug and Cosmetic Act and other acts the Food and Drug Administration (FDA) administers. Under the FDA Export Reform and Enhancement Act of 1996 FDA is authorized to issue certificates for drugs, animal drugs, and devices within 20 days of receipt of a request for such a certificate. A fee of up to $175 may be charged for each certificate issued. In addition to issuing export certificates for approved or licensed products, the FDA will also issue export certificates for unapproved products that meet the requirements of Sections 801(e) or 802 of the Act. The Export Certificate to Foreign Governments is for the export of products legally marketed in the United States. FDA’s Web page on the Import and Export of Feed and Feed Ingredients 

The FDA will issue export permits as follows:

Guidance for Industry on FDA Export Certificates

The "Certificate of Free Sale" (Certificate of Export for Seafood) is for food, including dietary supplements, and cosmetic products that may be legally marketed in the United States. (CFSAN)

The "Health Certificates for Food/Feed" currently required primarily by the European Union (EU), are usually consignment-specific and often contain language pertaining to "compliance" of the particular product/consignment with foreign regulations. As a matter of policy, FDA does not issue export certificates that attest to compliance with another country's requirements. Rather, FDA may work with other governments to develop mutually acceptable language for the certificate, e.g., language recognizing "equivalence" rather than "compliance".

Importing Pet Food Products Into the US From Canada

Obtaining USDA Import Documentation (prior to exporting from Canada)

USDA Web site on importing Animal Products into Canada.

User fees are charged for the services APHIS provides related to the importation, entry, or exportation of animals and animal products 

USDA Export Verification Program for suppliers of meat and meat products

Food and Agricultural Import Regulations and Standards for Canada:
Export Certificate Report (GAIN)

FDA’s Role in Exporting Feed Products

FDA is often asked by foreign customers or foreign governments to supply a certification relating to products subject to the Federal Food, Drug and Cosmetic Act and other acts the Food and Drug Administration (FDA) administers. Under the FDA Export Reform and Enhancement Act of 1996 FDA is authorized to issue certificates for drugs, animal drugs, and devices within 20 days of receipt of a request for such a certificate. A fee of up to $175 may be charged for each certificate issued. In addition to issuing export certificates for approved or licensed products, the FDA will also issue export certificates for unapproved products that meet the requirements of Sections 801(e) or 802 of the Act. The Export Certificate to Foreign Governments is for the export of products legally marketed in the United States. FDA’s Web page on the Import and Export of Feed and Feed Ingredients. 

The FDA will issue export permits as follows:

• For exporting feed products not approved by the FDA, they issue FDA Form 3613 Supplementary Information Certificate to Foreign Government Requests
• For exporting FDA approved medicated feeds or food additives, they issue CERTIFICATES TO FOREIGN GOVERNMENT.

Guidance for Industry on FDA Export Certificates

The "Certificate of Free Sale" (Certificate of Export for Seafood) is for food, including dietary supplements, and cosmetic products that may be legally marketed in the United States. (CFSAN)

The "Health Certificates for Food/Feed" currently required primarily by the European Union (EU), are usually consignment-specific and often contain language pertaining to "compliance" of the particular product/consignment with foreign regulations. As a matter of policy, FDA does not issue export certificates that attest to compliance with another country's requirements. Rather, FDA may work with other governments to develop mutually acceptable language for the certificate, e.g., language recognizing "equivalence" rather than "compliance".

What constitutes a reportable food incident?

The required information must be provided in a standardized format through the electronic portal and should also be provided to the District Recall Coordinator. The following must be provided:

• The responsible party’s Bioterrorism Act registration number;
• The date the food was determined to be reportable;
• Description of the food (quantity affected, product codes, names of manufacturers and distributors, etc.); and
• Extent and nature of the adulteration.
• Responsible parties must also report the results of any investigation into the cause of the adulteration and the disposition of the adulterated item. This latter information may be unknown or incomplete at the time of the first submission but, when completed, must be included in an amended report.
• FDA may impose other requirements after evaluating the report. This could include additional information as needed for FDA to conduct its investigation and notify the immediate previous source and/or immediate subsequent recipient(s) of the adulterated item, who in turn may also have to file reports.
• There are requirements to keep records on all reports for two years.
• The report “may be accompanied by a statement, which shall be part of any report that is released for public disclosure that denies that the report or notification constitutes an admission that the product involved caused or contributed to a death, serious injury or serious illness.”

Reports submitted through the portal will be available to the public in response to a Freedom of Information Act (“FOIA”) request, but the Registry itself will not be accessible to the public. To help protect against unauthorized disclosures, confidential business information submitted to the Registry should be marked as such. Additionally, while Section 417(i) of the FDCA provides that a submission to the Registry is not an admission that the food caused or contributed to a death, serious injury, or serious illness, responsible parties making reports to the Registry also may wish to include a safety report disclaimer per Section 756 of the FDCA, stating that the report is not an admission that the food was adulterated or misbranded or posed a risk of harm.

Pet Food Regulation in Canada

Pet food sold in Canada is currently subject to the following Canadian and international regulations:

The Government of Canada’s enhanced animal health safeguards, implemented in July 2007, make it illegal for specified risk materials (SRMs) to be fed to any animal, including dogs and cats. 

The labelling and advertising of pet food is regulated by the Consumer Packaging and Labelling Act and the Competition Act, administered by Industry Canada. In addition, the Guidelines for the Advertising and Labelling of Pet Food, is a voluntary guide developed to ensure consistency and accuracy on pet food labels. The Guidelines also help to ensure that Canadian consumers clearly understand the contents of each package of pet food. They were developed by a working group including Canadian pet food manufacturers and importers, representatives from the Competition Bureau and the Government of Canada, as well as consumers. This guide does not apply to pet treats or pet food for animals other than dogs or cats. There are also voluntary quality assurance programs in place which deal with the quality, safety and nutritional value of pet food.

The Consumer Packaging and Labelling Act mandates that the following items be included on pet food labels.

• Common or generic name: e.g. “Dog Food” or “Cat Food”
• Net weight: amount of product within the package, measured in metric units
• The manufacturer’s or importer’s contact information

The Guidelines, an accepted standard in the pet food industry, recommend pet food labels should contain at least the following information in addition to the Consumer Packaging and Labelling Act items.

• List of ingredients: listed in descending order by percentage of weight
• Feeding instructions
• Guaranteed analysis: information on the minimum and maximum nutritional quantities. For example, the analysis will include the maximum or minimum percentage of protein, fat, fiber and moisture.
• Nutritional adequacy or intended life stage for which the food is suitable

Ingredients must be listed and identified by their common name. When an ingredient or combination of ingredients makes up 90% or more of the total weight of all ingredients, these ingredients may also form a part of the product name. For example, if the product contains 90% or more beef, it may be called “My Brand Beef Dog Food”.

This oversees that pet food labels and advertising are truthful and verifiable. Pre-packaged pet food destined for retail consumption must be labeled with a bilingual common name, metric net quantity, and dealer name and address. Industry Canada also oversees laws prohibiting false and misleading representations and deceptive market practices.

 See, also Pet Food Association of Canada. The Pet Food Association of Canada is a trade association representing the manufacturers of pet foods sold in Canada or manufactured for export.

Bilingual Labeling Requirements

The Consumer Packaging and Labeling Act requires bilingual labeling (English and French) on most consumer products sold in Canada. The Act requires that all information shown on the label of a prepackaged product be shown in both official languages, except that the identity and principal place of business of the manufacturer may be shown in only one of the language. For additional information see the "Guide to the Consumer Packaging and Labelling Act and Regulations".

In Quebec Province, Article 51 of the Charter of French Language requires that every inscription on a product, its container or its wrapping; or, on a leaflet, brochure or card supplied with the product, including directions for use and warranty certificates, be written in French. The French inscription may be accompanied with a translation, but no inscription in another language may be given greater prominence than the French. The exceptions to this requirement include products which are from outside Quebec, is in limited use in Quebec where no equivalent substitute presented in French is available. See the Charter of the French Language, written in English.