What happens during a CFIA food recall and what is the importer’s responsibility?
COMPLIANCE ALERT: If the food presents a risk to human health, you are required to notify the CFIA immediately. This notification obligation falls on the importer regardless of where in the supply chain the problem originated.
When a food recall is initiated, your responsibility as an importer is to execute your documented recall procedure without delay. This means taking concrete actions to remove the affected food from the marketplace, not just notifying your customers that a recall may occur.
Your recall procedure must describe how you will identify all affected product, how you will contact customers who received the product, how you will retrieve or direct the disposal of recalled product, and how you will document every step of the process. If the food presents a risk to human health, you must notify the CFIA immediately, before the recall is fully executed, not after.
You are required to document all details of the recall in writing and retain those records for two years from the day the recall was started. The documentation requirement includes the trigger for the recall, the scope of affected product, all customer notifications, all retrieval actions taken, and the final disposition of the recalled food.
The importer’s recall responsibility does not diminish because the problem originated at a foreign supplier’s facility. You are accountable for the food you brought into Canada. The foreign supplier’s liability in their home jurisdiction is a separate matter. Your obligation to Canadian consumers and to CFIA is determined by your role as the Canadian importer of record.
INSIDER INTELLIGENCE: Importers often assume that a recall triggered by a supplier problem is primarily the supplier’s responsibility. Under Canadian food law, the importer of record is accountable for the food once it enters Canada. Having a tested, documented recall procedure is the difference between a managed compliance event and an enforcement action.