What traceability records must a food importer keep under the SFCR?

COMPLIANCE ALERT: Traceability records must be kept for two years, must be accessible in Canada, and must be in English or French. Electronic records are acceptable but must be provided in a format readable by standard computer software. 

Under the SFCR, food importers are required to maintain traceability records for all the foods they import. The records must allow you to trace your imported food one step forward to your immediate customer and one step back to your immediate supplier. This is the one-step-forward, one-step-back standard that applies across Canadian food businesses. 

Tracing back to your immediate supplier means keeping a record of the name and address of the person or food business that sold or consigned the imported food to you and the date the food was sold or consigned. Tracing forward to your immediate customer means keeping a record of the name and address of the person to whom you transferred care, control, ownership, or responsibility of the food after it was imported. 

If you are selling your imported food directly at your own retail location, you are not required to keep records of individual end consumers. The traceability obligation extends to the next business in the supply chain, not to individual retail purchasers. 

All traceability records must be kept for a minimum of two years, must be clear and readable, must be accessible in Canada, and must be available to CFIA upon request. If you use electronic records, they must be provided in a format that can be read by standard computer software. 

INSIDER INTELLIGENCE: Traceability is one of the first things CFIA asks for during an import investigation or recall situation. Importers who cannot produce supplier and customer records quickly and accurately face significantly worse regulatory outcomes than those whose traceability records are organized and current.