Frequent questions regarding pet supplements.

The Canadian Food Inspection Agency’s (CFIA’s) update to import policies regarding finished, retail-ready pet supplements is scheduled for June 24, 2024. To help ease this transition, here are answers to some of the most common questions that have been received by the Animal Products and By-Products Team.

1 Vitamin and Mineral premixes

New import coding has been created for bulk vitamin and/or mineral premixes, for the end use of pet food manufacture. These premixes can have Vitamin A and/or Vitamin D, but no other animal origin ingredients, and are permitted from any country with a copy of the label or list of ingredients from the manufacturer. They can be declared under 23 09 90 6274.

2 Mixtures

There are too many mixtures available commercially to have import coding for each possibility. When there is no coding available, use the Animal Products and By-Products’ policy on mixtures (from Section 9 of the Import Policy Framework) to consider each ingredient separately. For example, a mix of chondroitin and rice flour from the United States would be approved for chondroitin of porcine origin under 30 01 90 1676 14, and approved for rice flour under 11 01 90 7176.

If a commodity contains one animal-origin ingredient mixed with one or more non-animal-origin ingredients (for example, 40% poultry meal and 60% plant-origin ingredients) the conditions that would apply to the single animal-origin ingredient on its own would apply to the commodity as a whole

3 Rendered products

According to section 166 of the Health of Animals Act, all products of a rendering plant require an import permit for entry into Canada. This also applies to mixtures containing a product of a rendering plant. They must originate from a country whose rendering facility has been evaluated and approved by the CFIA.

For non-ruminant material, the approved countries are:

Australia
France
Germany
Italy
Netherlands
New Zealand
Spain
United Kingdom
United States of America
For ruminant rendered material, the only countries approved are:

Australia
New Zealand
Currently, information about rendered products is available in Section 10.5 of the Import Policy Framework.

If your company has been mistakenly importing rendered materials without an import permit, we urge you to apply for one at MyCFIA as soon as possible to ensure compliance.
Please be aware of the following common products and their coding:

Milk replacers (containing milk ingredients as the only animal-origin ingredients):
23 09 90 1575 08
Rendered materials such as meat digest, meat and bone meal, spray dried blood:
05 11 99 1995 or 23 01 10 1995
Chondroitin sulphate:
30 01 90 1676, 2nd level OGD depends on species

NEW_ Registering for an import-export program (RM) account

Customs Notice 24-18: CARM: Changes to the Registration

Registering for an import-export program (RM) account
1. The Canada Revenue Agency (CRA) remains responsible for the issuance of the business number (BN9) and for registration to various CRA program accounts.

2. As part of the implementation of the CARM system, the responsibility to register new and to manage updates to import-export program (RM) accounts is being transferred to the CBSA.

3. As of May 13, 2024, the CRA will no longer register new import-export program (RM) accounts or accept maintenance requests for existing RM accounts. TCPs are required to go to the CBSA for all matters relating to their RM account.

4. The system functionality to fully automate the process of issuing and managing RM program accounts will not be in place until October 2024, when the CBSA will launch CARM externally.

Interim process for registration and maintenance of RM accounts
5. The CBSA is introducing an interim process for the registration and maintenance of program (RM) accounts for importers and exporters. The CBSA will require that the TCP submit the applicable form to register a new RM account or to seek changes to an existing RM account.

6. Information on the interim process and web links to access the new request forms can be found on the CBSA’s primary CARM web page.

Customs Notice 24-17: CARM: Launch to External Clients Rescheduled to October 2024

Ottawa, April 26, 2024

1. On April 19, 2024, the CBSA issued a news release to provide an update on its plans for the launch of the CBSA Assessment and Revenue Management (CARM) system.

2. The CBSA communicated that CARM will launch Release 2 internally at the CBSA on May 13, as planned, to advance the Agency’s compliance and enforcement efforts.

3. Responding to uncertainty in the labour environment, the CBSA also indicated that it is preserving the status quo for industry when they account for duties and taxes. It is therefore the intention of the CBSA to reschedule the launch to Trade Chain Partners (TCPs) to October 2024.

4. As a result, the CARM system will not become the official system of record that importers and other trade chain partners will use to account for imported goods and pay for duties and taxes, on May 13 2024, as previously communicated.

5. This notice is to address potential impacts of the rescheduling of the external launch of the CARM system may have on TCPs and also to provide information on what to expect during the period leading to the new October implementation date.

Release Prior to Payment (RPP) – May 13, 2024

When CARM becomes the official system of record on May 13, 2024, obtaining the release of imported goods prior to accounting and payment of duties will change for importers. They will no longer be able to use a broker’s RPP security to obtain the release of imported goods before paying duties. Importers who want to obtain the release of imported goods prior to the payment of duties will be required to post their own financial security through the CCP.

1. Regulatory changes have been made and will come into force on May 13, 2024. Regulations introduced a 180-day transition period following CARM implementation to allow time for importers to obtain financial security. This will give importers and their service providers time to adapt to the new financial security model and avoid border disruptions.

2. All commercial importers with a history of accounting for commercial goods using their importer business number within the past four years will automatically benefit from RPP for a period up to 180 days following CARM implementation on May 13, 2024.

3. After May 13, 2024, new importers who do not have a history of importing commercial goods into Canada within the past four years will also be able to benefit from the transition period. For the 180-day period to apply to new importers, they will have to enroll in RPP via the CCP and select that they wish to request a lower than recommended financial security amount. This will generate a case for CBSA to review and will apply the RPP indicator for the transition period.

4. During the 180-day transition period, importers will need to ensure they are registering in the CCP and posting applicable financial security in order to avoid disruption to the release prior to payment of duties of goods they import after the 180-day transition period ends.

Barley Products Tariff Rate Quota (TRQ)

Please be advised that the Barley Products Tariff Rate Quota (TRQ) will be filled on April 11, 2024. Consequently, April 11, 2024 (at 8:59 pm Ottawa time (EST) ) will be the cut-off date for accounting for imports of all barley products classified under a “within access commitment” tariff item number. All imports of barley products accounted for after the cut-off date and time will be classified at the “over access commitment” tariff item number, even if they were imported, (or imported and released), before the quota has been filled.

Please note that after the TRQ level is reached, certain barley products, such as those that qualify under the U.S., Mexican, Chilean, Peruvian, Costa Rican, European or United Kingdom’s tariffs, will continue to be assessed at the “within access” lower rate of duty.

You can refer to this notice at the following site:

Message to industry: Barley Products Tariff Rate Quota (TRQ) – Quota will be filled on April 11, 2024 (international.gc.ca)

Customs Notice 24-14: Preparing for CARM Release 2 Implementation, Cutover Period.

1. Effective May 13, 2024, the CBSA Assessment and Revenue Management (CARM) system will become the official system of record for importers and other trade chain partners (TCPs) to account for their goods and pay for their duties and taxes owed to the Canada Border Services Agency.

2. This notice is to provide TCPs with important information regarding the cutover period, which is required for the CBSA to migrate existing systems and functionality to CARM systems and functionality for the CARM R2 May 13, 2024 implementation. The CARM R2 cutover period will extend from April 26 (4:00 pm EDT) to May 13 (3:00 am EDT).

3. At the beginning of the cutover period, some CBSA legacy systems, such as the Customs Commercial System (CCS) and the Customs Automated Data Exchange (CADEX), will be retired.

CARM Registration and Program Enrollment
4. The CARM Client Portal (CCP) will not be available during the cutover period. TCPs will not be able to register on CARM.

5. Trusted Trader Enrolment: Customs Self-Assessment (CSA) enrolment activities will be paused during cutover, resuming May 13, 2024. Starting on May 13, all CSA applications must be submitted via the CCP. Partners in Protection (PIP) enrolment remains available in the Trusted Trader Management System (TTMS).

CARM Simulation Lab Availability
6. The CARM Simulation lab will not be available during the cutover period. TCPs will be able to access the lab the week of May 20.

New Business Number (BN)
7. New commercial importers requiring a BN and importer program account (RM) in order to obtain release for their importation of commercial goods can continue to work with the Canada Revenue Agency (CRA) to obtain a BN/RM account for their importing of goods activities. The CRA’s service will be offered until 7:00 pm EDT, Friday May 10, 2024.

8. For new commercial importers that cannot obtain a BN/RM, the use of Broker BN to obtain release of goods for existing “First time” and “One time” importer policy is maintained. CBSA will also facilitate the use of CBSA administrative BN on paper C-Type B3 entry for importers that are not using a customs broker.

9. The CRA will continue to issue new exporter program account during the cutover period, but exporters will not be able to use their new BN/RM to enroll in either the Canadian Export Reporting System (CERS) or G7 Electronic Data Interchange Export Reporting system. This includes associations of a new BN/RM to a customs services provider.

10. Exporters who obtain their new export BN/RM during the cutover period may use one of the following two options to report their goods.

Option 1: One-time submission

Use the services of a customs service provider to report on your behalf
The customs service provider will use the “one time submission” reporting option in CERS on behalf of the exporter
Once the cutover period is complete, the exporter completes the CERS or G7-EDI registration process for future exports
Note: New exporters using this option will not be required to re-submit their declaration when their registration is complete.

Option 2: BSF844 Exporter contingency form

Obtain a BN/RM from the CRA
Complete the paper BSF844 Exporter contingency form, entering the newly issued BN/RM on the form
Submit two copies of the form to the CBSA export reporting office where the goods are exported, or by email to offices providing the eLongroom service, for review and stamping by a CBSA officer
Once the cutover period is complete, complete the CERS or G7-EDI registration application, and re-submit the export declaration electronically using either the CERS or G7-EDI electronic reporting method
Note: Exporters who submit a paper contingency form and do not complete their registration and submit an electronic declaration may be subject to penalties.

11. New exporters may continue to submit CERS and G7-EDI registration forms during the cutover period, however these will not be processed until the cutover is complete. New exporters must use one of the two options listed above to submit their declarations. Applications will be processed after the cutover and exporters will receive notification when their registration is complete.

Information on HFC imports

Did you know that you MUST have an authorization issued by Environment and Climate Change Canada (ECCC) to import bulk hydrofluorocarbons (HFCs), including HFC refrigerant blends?
If you intend on importing HFCs into Canada, you must ensure you have the necessary authorizations from ECCC. HFCs are potent greenhouse gases commonly used as refrigerant in refrigeration and air-conditioning equipment, as a foaming agent in foams and as a propellant in aerosol products.

Since 2019, a gradual phase-down of HFC consumption has been in place to implement Canada’s international obligations under the Montreal Protocol on Substances that Deplete the Ozone Layer, including the Kigali Amendment. The United Nations estimated that phasing down HFCs globally will reduce greenhouse gas emissions equivalent to 105 billion tons of CO2 by 2100.

U.K. walks away from trade talks with Canada.

British negotiators walked away from trade talks with Canada Thursday — a dramatic development that taps the brakes on a bilateral trade deal between the two Commonwealth nations that has been years in the making.

A major sticking point between the two sides remains how much tariff-free access U.K. producers should have to the Canadian cheese market.

After Brexit, an interim agreement kept tariff-free British cheese on Canadian shelves for three years. That more permissive regime expired at the end of last year.

Negotiators had been working on a longer-term bilateral trade deal to replace the liberalized trade the U.K. enjoyed under the terms of Canada’s Comprehensive Economic and Trade Agreement (CETA) with the European Union.

This was excerpted from the 25 January 2024

New from Health Canada’s Consumer Product Safety Program.

The Consumer Product Safety Program would like to inform you that the Industry Guide to the Consumer Chemicals and Containers Regulations, 2001, Third Edition, is now available.

For more information, please contact a Health Canada Consumer Product Safety Office via email ccpsa-lcspc@hc-sc.gc.ca or telephone at 1-866-662-0666 (toll-free within Canada and the United States).

Reminder: Importers of manufactured foods need a licence

Reminder: Importers of manufactured foods need a licence

Most food importers are required to hold a valid Safe Food for Canadians licence (SFC licence) issued by the Canadian Food Inspection Agency (CFIA).

On February 12, 2024, the CFIA will activate the automatic verification of SFC licences for imports of manufactured foods. Food import transactions will be automatically rejected and the shipment will be denied entry into Canada unless a valid SFC licence number is declared.

If you import manufactured foods, visit Food importers: You need a Safe Food for Canadians licence to learn how you can prepare for automatic licence verification.