Does my foreign supplier need to be verified before I can import their product into Canada?

COMPLIANCE ALERT: You are accountable for knowing that your foreign supplier’s food safety controls are in place and effective, even though you are not present at their facility. This accountability does not transfer to the supplier. 

Yes. Under section 89 of the SFCR, your Preventive Control Plan must include a description of your assurances that each of your foreign suppliers has preventive controls in place that are the same as those described in sections 47 to 81 of the SFCR, or if their controls are different, that they are equally effective at managing the food safety risks. 

As a Canadian importer, you are likely not present at the foreign facility where your food is produced. You do not have direct control over the food safety controls applied in that establishment. But you are legally accountable for knowing that those controls exist and are being implemented effectively. That accountability does not transfer to your supplier simply because the problem originated at their facility. 

Practically, foreign supplier verification means documenting how you assessed your supplier before your first shipment, what ongoing monitoring you conduct, what certificates or audit reports you collect, and what triggers a re-evaluation of a supplier’s standing. High-risk commodities may also require import controls such as product testing on arrival as part of your verification approach. 

The three types of recognition under CFIA’s Foreign Food Safety Systems Recognition Framework affect what documentation is required. Suppliers from countries with recognized food safety systems, such as the United States, operate under different documentation requirements than suppliers from countries without a recognition arrangement with Canada. Your PCP must reflect which category applies to each of your suppliers. 

INSIDER INTELLIGENCE: The foreign supplier verification requirement is the most frequently misunderstood element of an importer PCP. Many importers believe their supplier’s local certification is sufficient. It is not. Canadian accountability for what happens at a foreign facility is a distinct and separate requirement.