Category Archives: News

The US Food and Drug Administration (FDA) announced a proposed rule to establish additional traceability recordkeeping requirements for certain foods. The FDA also published a draft “Food Traceability List,” which describes the foods that would be subject to the proposed requirements. The list includes leafy greens, fresh cut fruits and vegetables, some types of fish, shell eggs, nut butters, and more.

The proposed rule, “Requirements for Additional Traceability Records for Certain Foods” (Food Traceability Proposed Rule) is a key component of the FDA’s New Era of Smarter Food Safety Blueprint and would implement Section 204(d) of the FDA Food Safety Modernization Act (FSMA). If finalized, the proposal would standardize the data elements and information firms must establish and maintain, and the information they would need to send to the next entity in the supply chain to facilitate rapid and accurate traceability. While limited to only certain foods, this proposal lays the foundation for a standardized approach to traceability recordkeeping, paving the way for industry to adopt, harmonize, and leverage more digital traceability systems in the future. Where possible, FDA has drawn on existing consensus standards that industry members may already be using.

Existing FDA regulations require much of the food industry to establish and maintain records to identify the immediate previous sources and the immediate subsequent recipients of foods (commonly referred to as “one-up, one-back” recordkeeping). These requirements form a baseline for traceability recordkeeping, but they provide limited information to effectively and rapidly link shipments of food through each point in the supply chain. This — and the fact that recordkeeping systems can be largely paper-based and lack a universal lexicon throughout industry– can make it difficult to trace a product to its original source when necessary.

As a result, many foodborne illness outbreak investigations have been slowed, resulting in more illnesses and economic loss. Improved traceability, as envisioned by the proposed rule, would allow the FDA to more quickly identify the source of a contaminated product, reduce the scope of product recalls, and conduct more timely root-cause investigations to learn more about how contamination occurred in order to prevent future outbreaks.

At the heart of the proposal is a requirement for those who manufacture, process, pack, or hold a food on the Food Traceability List (FTL) to establish and maintain records associated with specific Critical Tracking Events (CTEs): growing, receiving, transforming, creating, and shipping. For each CTE, entities would be required to establish and maintain records containing Key Data Elements (KDEs). Examples of KDEs include the traceability lot code, the date the product was received, the date the product was shipped, and a product description. The traceability lot code is an important KDE throughout the supply chain intended to establish critical linkages that will help to facilitate rapid traceback and traceforward investigations during foodborne illness outbreaks and recall events. In addition, those subject to the rule would also be required to create and maintain records related to their internal traceability program, which would help regulators better understand a firm’s recordkeeping practices and traceability operations.

The proposed rule would require records to be maintained as either electronic, original paper records, or true copies. In addition, the proposal states that in the event of a foodborne illness outbreak, a product recall, or other threat to public health, the FDA could require that firms submit, within 24 hours, an electronic sortable spreadsheet containing relevant traceability information for specific foods and date ranges. More generally, the FDA encourages all food businesses to maintain their traceability records electronically whenever possible, to expedite the identification of traceability information when needed to address threats to public health.

The requirements of the proposed rule would only apply to foods that are on the FTL, which includes foods that have listed foods as ingredients. The proposed rule includes several exemptions, including that the additional traceability records would not be required after a kill-step (a process that significantly minimizes pathogens in a food) is applied to a food, but documentation of the kill-step application would have to be established and maintained.

The proposed rule and draft Food Traceability List are available for public comment for a 120 days from the date of publication. The FDA will also be holding three public meetings during the public comment period. Information about the public meetings will be provided in a forthcoming announcement.

For More Information

The US Food and Drug Administration is announcing additional flexibility for manufacturers who need to comply with updated Nutrition and Supplement Facts label requirements by January 1, 2021. This upcoming compliance date applies to manufacturers with less than $10 million in annual food sales. Although the compliance date will remain in place, the FDA will not focus on enforcement actions during 2021 for these smaller food manufacturers. This additional flexibility includes manufacturers of packages and containers of single-ingredient sugars, regardless of the size of the manufacturer.

The FDA has heard from some manufacturers that more time may be needed to meet all of the requirements, especially during the COVID-19 pandemic.

The FDA provided the same flexibility for manufacturers with $10 million or more in annual sales, who were required to comply with the Nutrition and Supplement Facts label requirements by January 1, 2020, by indicating it would not focus on enforcement actions during 2020.

For more information:

Changes to the Nutrition Facts Label
Food Labeling Final Rule: Revision of the Nutrition and Supplement Facts Labels

The European Union (EU) has officially notified trading partners under the World Trade Organization (WTO) notification G/TBT/N/EU/732 of the Draft Commission Delegated Regulation amending Annex III to Regulation (EU) 2018/848 of the European Parliament and of the Council as regards certain information to be provided on the labelling of organic product.

The draft proposal amends certain provisions laid down under Annex III to Regulation (EU) No 2018/848 regarding collection, packaging, transport and storage of products with regard to information to be provided on compound feed and mixtures of fodder plant seeds, in order to allow the organic operators to get complete information on the composition and presence of organic, in-conversion and authorized non-organic components in the products concerned.

The proposal aims to introduce more transparency with respect to the detailed information to be transmitted among organic operators with respect to the exact qualitative and quantitative composition of compound feed and mixtures of fodder plant seeds in terms of organic, in-conversion and allowed non-organic components to be provided on the label or on documentation accompanying the concerned products.

Below is EU’s WTO notification with the proposed amendments.

Please note that in light of the COVID 19 pandemic, our understanding is that the date of entry into force could potentially be delayed until January 1st, 2022 as opposed to January 2021. We will be sure to communicate any further information pertaining to implementation timelines once they become available.

Please submit any comments or questions related to this notification no later than September 28, 2020 to the Market Access Secretariat at


On September 8th, the Ministry of Agriculture, Forestry and Fisheries of Japan (MAFF) notified the World Trade Organization (WTO) of their Draft revision of Japanese agricultural standards for organic livestock (Notification No. 1608 of 2005). The purpose of this proposal is to introduce new standards for organic turkey and revise the Japanese Agriculture Standards for Organic Livestock. Below is a copy of the notification for review.

Please submit any comments or questions related to this notification no later than Friday, September 25, 2020 to the Market Access Secretariat at


Three MERCOSUR members, Argentina, Paraguay and Uruguay, notified the World Trade Organization (WTO) of the following draft resolutions:

  • Draft Common Market Group (GMC) Resolution No.03/20 “MERCOSUR Technical Regulation on the positive list of monomers, other starting substances and polymers authorized for the manufacture of plastic packaging and equipment that comes into contact with food; and,
  • Draft Common Market Group (GMC) Resolution No. 02/20 “MERCOSUR Technical Regulation establishing general provisions for plastic packaging and equipment that comes​ into contact with food.

Below are copies of the notifications (in Spanish only) for review and comment.  Comments should be submitted no later than September 21, 2020.

To submit your comments and for any additional questions, please contact the Market Access Secretariat at:


Brazil notified the World Trade Organization (WTO) of the following draft resolution:

Draft Resolution number 897 proposes the revision of the Resolution RDC number 105, 19 May 1999, which establishes technical requirements for packages and plastic containers in contact with food; the Resolution RDC number 56, 16 November 2012, which establishes the positive list of monomers, starting substances, and polymers authorized in the manufacturing of packages and plastic containers in contact with food; and the Resolution RDC number 88, 29 June 2016, which establishes the materials, packages, and cellulosic materials designated to enter in contact with food; in order to update the health requirements of material in contact with food.

Below is a copy of the notification (in Portuguese only) for review and comment. Comments should be submitted no later than October 20, 2020.

To submit your comments and for any additional questions, please contact the Market Access Secretariat at:


As you know, the United Kingdom (UK) left the European Union (EU) on January 31st, 2020. The ratified Withdrawal Agreement provides for a transition period lasting until December 31, 2020, to permit the UK and the EU to negotiate their future relationship.

Canada has agreed that the Canada-EU Comprehensive Economic and Trade Agreement (CETA) can continue to apply to the UK until the end of this transition period. Following a call on August 6, 2020 between the Minister of Small Business, Export Promotion and International Trade, Mary Ng and her United Kingdom counterpart, Secretary of State for International Trade Liz Truss, Canada and the UK have agreed to re-engage in discussions on a Transitional Trade Agreement with the UK. These discussions are expected to take place over the fall with a view to finalizing a Transitional agreement before the end of this year.

Agriculture and Agri-Food Canada will continue to update stakeholders via the TAND-DACN (ATNCG) account to provide information as it becomes available.

This message is to provide an update of Japan’s proposal to amend the Ordinance for Enforcement of the Plant Protection Act (G/SPS/N/JPN/684).

On August 5, 2020, Japan published a revision to the October 2019 notification that listed Canadian plant products requiring a phytosanitary certificate accompanying imports into Japan. In this regard, we can report that a three year transition period for the implementation of this requirement has been introduced as of August 5, 2020. This provides the Canadian Food Inspection Agency (CFIA) with an opportunity to continue discussions with Japan’s Ministry of Agriculture, Forestry and Fisheries (MAFF) regarding potential alternatives to this new requirement. During this transition period, a phytosanitary certificate will not be required (unless an agreement between the CFIA and MAFF is reached prior to 2023). Below is a copy of the recent notification.

For questions and comments related to this notification please contact the Market Access Secretariat at


Effective March 1, 2021, Saudi Arabia will require that foreign halal certification bodies are approved and accredited to certify halal meat, poultry and their products by Saudi’s new “Halal Centre”, which is affiliated with the Saudi Food and Drug Authority (SFDA). Previously recognized certification bodies need to become accredited under the new system by March 1, 2021, in order to continue certifying halal exports destined for Saudi Arabia. At present, there is no organization based in Canada and the United States that is accredited under the new regime.

For a list of approved bodies, please refer to the following link: (in English). Canadian industry interested in becoming recognized under this new regime can contact the SFDA Halal Centre by writing, and expressing their interest in becoming accredited. The Halal Center will guide you through the necessary steps.

excerpts from the Toronto Star article by Jerry Dias (full article is available at this link):

“Blanket travel restrictions no longer make sense as parts of the world open up. Other countries are ready to accept Canadian travellers. If they can show that they have controlled the virus, travel should be allowed.”

“This is not to say that we should throw open the borders, of course. Travel restrictions to the U.S. continue to make sense. For other countries, there are several options worth exploring, including a negative COVID test before leaving and/or on return, and safe travel corridors directly to other countries that have the virus under control.”

“Other countries are beginning to implement such measures, and Canada should follow suit. Automatic 14-day quarantines make no sense when we have science-based alternatives.”

We agree with the above and hope the Canadian government can look at implementing measures that are science-based and not a one size fits all scenario.

Visit the Canadian Travel & Tourism Roundtable website for more information on travelling The Canadian Travel & Tourism Roundtable is comprised of leaders across the travel and tourism industry – with representatives from airlines, airports, hotels, and chambers of commerce across Canada. Their mission is to promote a responsible reboot of the travel and tourism industries by prioritizing safety and adherence to new regulations.