New Information Concerning Change in Policy for Letters of Exemption for Products Containing Insignificant Amounts of Meat

Following is a message from CFIA.

This communication supercedes previously issued information. Based on feedback received, the CFIA adapted the policy for products containing insignificant amounts of meat in a manner that strives to avoid added effort, delays or cost.

Effective May 2, 2013,  the CFIA no longer  issues letters of exemption  for products containing insignificant quantities of meat that fall under Meat Inspection Regulations 3.(1)(i) exemption. Existing CFIA letters of exemption will expire as of June 30, 2013 and will no longer be accepted after this date. The letter of exemption will be replaced by an attestation or declaration issued by the manufacturer or importer that attests the product’s composition.  The attestation will be reviewed as part of the regular import certificate processing performed by the National Import Service Centre (NISC).
The attestation must accompany each shipment.

Importers can use the Automated Import Reference System (AIRS) to check current Canadian import requirements. A manufacturer or importer wishing to continue to make use of the exemptions for foods containing insignificant quantities of meat will have to document in the attestation how the food product qualifies for one of the existing exemptions. Otherwise,  the product will be assessed as presented at the border and no future processing or dilution steps are considered. For example, a soup concentrate with 8% meat extract or animal fat content that would be further diluted to under 2% once  prepared according to directions will continue to be exempt if the importer provides proof that the dilution reduces the meat content to under 2%. Otherwise, the soup concentrate would  be considered to be a meat product.

Diluting is only acceptable for foods containing rendered fat, extract or broth. If a product contained 8% meat muscle or any other meat ingredient it would not be exempted, regardless of dilution. As an example, a “flavour” with 30% ground beef  is not exempt.

A full list of exemptions can be found in the Meat Hygiene Manual of Procedures:
http://www.inspection.gc.ca/english/fssa/meavia/man/ch1/1-2e.shtml#a1-2-2

Please disregard all references to the Label and Recipe Registration Unit in the Manual.           
The operator or importer is expected to meet all requirements under all CFIA regulations applicable to that product.

These products may also be regulated by Health Canada through product-specific regulatory programs, which are administered under the authority of the Food and Drugs Act and Food and Drugs Regulations.

It is the responsibility of the prospective importer to be in compliance with any additional import requirements or restrictions associated with the importation of a commodity for human use. Before importing the product(s) into Canada any animal health restrictions must be complied with that are in place for the product in question.