Regulatory requirements: Traceability

On this page

• 1.0 Introduction

• 2.0 Application of the traceability requirements

• 3.0 Documentation requirements

• 4.0 Traceability-specific labelling requirements

• 5.0 Traceability-specific labelling requirements by food commodity

1.0 Introduction

The traceability requirements in the Safe Food for Canadians Regulations are based on the international standard established by Codex Alimentarius - tracking of food forward to the immediate customer and back to the immediate supplier. Developing an effective traceability system will allow you to:

• reduce costs associated with recalls by narrowing the scope to only food that may present a risk of injury to human health

• protect consumers against risk of injury to their health from hazards in your food

• increase consumer trust in the safety of the food you sell

The following provides an overview of the regulatory requirements on traceability, as found in Part 5 of the Safe Food for Canadians Regulations.

2.0 Application of the traceability requirements

The traceability requirements apply to a broader scope of food businesses than the licensing and preventive control plan requirements. For example, some of the traceability requirements apply to persons who sell food to consumers at retail as well as persons who send or convey food from one province or territory to another.

Although the Safe Food for Canadians Regulations came into force January 15, 2019, the traceability requirements followed a phased-in implementation approach.

Please refer to the Traceability interactive tool to help you determine if and how the traceability requirements apply to your food business.

3.0 Documentation requirements

Safe Food for Canadians Regulations: Sections 90 and 91

Rationale

Traceability documents allow you to identify from where you sourced the food and/ or food commodity (one step back), and to whom you provided the food (one step forward). Preparing, keeping, and retaining traceability documents allow you to accurately identify the scope of a recall, and thereby ensure that consumers are protected against risk of injury to their health.

What this means for your food business

To help you understand these requirements, specific criteria and examples are outlined below. The examples are not exhaustive but help illustrate the intent of the requirement and offer examples of what you can do to comply. Key terms throughout the text have been hyperlinked to the SFCR glossary.

Subsection 90(1): Documentation requirements for food businesses other than retail

• If you provide food to another person and the traceability requirements apply to you, you prepare and keep documents that:

  • identify the food by indicating the:

    • common name

    • lot code or other unique identifier; and

    • name and principal place of business of the person by whom or for whom the food was manufactured, prepared, produced, stored, packaged or labelled

  • trace the food one step back, if someone else provided you with it, by indicating the:

    • date on which it was provided to you; and

    • name and address of the person who provided it to you.

  • trace the food one step forward by indicating the:

    • date you provide it; and

    • name and address of the person to whom you provide it.

• If you incorporate any food commodity into the food or derive the food from that food commodity, you prepare and keep documents that:

  • name the food commodity

  • trace the food commodity one step back, if someone else provided you with it, by indicating the:

    • date on which it was provided to you; and

    • name and address of the person who provided it to you.

Subsection 90(2): Documentation requirements for persons who sell food to consumers at retail

• If you sell food to consumers at retail, other than at a restaurant or other similar enterprise where the food is sold as a meal or snack, have access to documents that:

  • identify the food, by indicating the:

    • common name

    • lot code or other unique identifier; and

    • name and principal place of business of the person by whom or for whom the food was manufactured, prepared, produced, stored, packaged or labelled

  • trace the food one step back, if someone else provided you with it, by indicating the:

    • date on which it was provided to you; and

    • name and address of the person who provided you with the food

• If you incorporate any food commodity into the food you sell to consumers at retail or derive the food from that food commodity, have access to documents that:

  • name the food commodity

  • trace the food commodity one step back, if someone else provided you with it, by indicating the:

    • date on which it was provided to you; and

    • name and address of the person who provided you with it

Subsection 90(3): Retention and accessibility of traceability documents

• The documents are kept for two years after the day on which

  • the food was provided to you; and

  • you provided the food to another person.

• If you sell food at retail, have access to the trace back documents for two years after the day on which you sold the food.

• You make sure that the traceability documents are accessible in Canada.

Subsection 91(1): Production of traceability documents upon request

• Upon request, you provide the traceability documents to the Canadian Food Inspection Agency (CFIA):

  • in English or French; and

  • within 24 hours of the CFIA making the request

  • within a shorter period of time if the CFIA believes there is a risk of injury to human health; and

  • within a longer period of time if the CFIA believes that the information is not necessary for a recall

• If you provide the traceability documents electronically, they:

  • are in a single file

  • are in plain text; and

  • are capable of being imported into and manipulated by standard commercial software

4.0 Traceability-specific labelling requirements

Safe Food for Canadians Regulations: Section 92

Rationale

Traceability information that is applied or attached to a food or that accompanies a food allows both you and the person to whom you provide the food to effectively identify whether a particular food is subject to a recall.

What this means for your food business

To help you understand these requirements, specific criteria and examples are outlined below. The examples are not exhaustive but help illustrate the intent of the requirement and offer examples of what you can do to comply. Key terms throughout the text have been hyperlinked to the SFCR glossary.

Other sections of the SFCR may require you to provide information on your labels in specific ways or despite exceptions noted in the traceability section. Refer to the Industry Labelling Tool for additional information on labelling requirements.

Subsections 92(1) and (2): Labelling information that must be provided with the food

• If the traceability requirements apply to you, you make sure that a label is applied, attached, or accompanies the food when you provide it to another person. The label must include the following information:

  • the common name

  • the name and principal place of business of the person by or for whom the food was manufactured, prepared, produced, stored, packaged or labelled

  • the lot code if it is a consumer prepackaged food.

    Note:

    • At retail, if you package food into consumer prepackages, the label may include either a lot code or unique identifier.

    • For food, other than consumer prepackaged food, the label may include either a lot code or unique identifier.

Paragraph 92(3)(a): Labelling exceptions for food at time of export

Foreign states may have specific labelling requirements that are different from the SFCR.

• At the time that you export the food, you are

  not required

  to make sure that a label, with the following information, is applied, attached, or accompanies the food:

  • the common name

  • the lot code or unique identifier; and

  • the name and principal place of business of the person by or for whom the food was manufactured, prepared, produced, stored, packaged or labelled

Paragraphs 92(3)(b) and (c): Labelling exceptions for lot code or unique identifier; and name and principal place of business for certain food at the time of sale to consumers at retail

• At the time of sale to consumers at retail, there are particular foods for which you are

  not required

  to have the label applied, attached or accompany the food with:

  • the lot code or unique identifier; and

  • the name and principal place of business by or for whom the food was manufactured, prepared, produced, stored, packaged or labelled

    These foods are:

  • food that are not a consumer prepackaged food, for example food that is presented in bulk display

  • prepackaged confections that are sold individually, commonly known as one-bite confections;

  • fresh fruits or vegetables packaged in a wrapper or confining band less than 13 millimeters in width; and

  • fresh fruits or vegetables packaged in a protective wrapper, or a protective bag, that is clear and transparent and on which no information is shown other than a price, bar code, number code, environmental statement or product treatment symbol.

Paragraphs 92(3)(b) to (c), and Subsection 92(4): Labelling exceptions for common name for certain food at the time of sale to consumers at retail

• At the time of sale to consumers at retail, there are particular foods for which you are not required to have the label applied, attached or accompany the food with the common name of that food.

  These food are:

  • prepackaged fresh fruits or vegetables that are visible and identifiable in their container;

  • consumer prepackaged fresh apples that are packaged such that the variety name is shown on the label (except if the label is on the bottom of the container);

  • food that are not a consumer prepackaged food, for example food that is presented in bulk display

  • prepackaged confections that are sold individually, commonly known as one-bite confections;

  • fresh fruits or vegetables packaged in a wrapper or confining band less than 13 millimeters wide; and

  • fresh fruits or vegetables packaged in a protective wrapper, or a protective bag, that is clear and transparent and that shows only the price, bar code, number code, environmental statement or product treatment symbol.

Subsection 92(5): Labelling exceptions for name and principal place of business for consumer prepackaged fresh fruits or vegetables at the time of sale to consumers at retail

• For consumer prepackaged fresh fruits or vegetables that you package at retail such that they are visible and identifiable in the container, you are not required to label them with the name and principal place of business of the person by or for whom the food was manufactured, prepared, produced, stored, packaged, or labelled.