Q.01

Who needs a Safe Food for Canadians licence?

Under the Safe Food for Canadians Regulations (SOR/2018-108), you need a licence if you are an importer of food, or if you manufacture, process, treat, preserve, grade, package or label food that will be exported or sent to another province. Slaughtering food animals for export or interprovincial trade also needs a licence. Purely local (intraprovincial) businesses are outside these licensing triggers. Several exceptions apply.

1. Importers. Section 10(2) of the Act prohibits importing a prescribed food commodity unless a registration or licence authorises it, as the regulations provide (Justice Laws, SFCA). Section 5(2) of the Regulations makes any food a commodity that cannot be imported "unless the person is authorized to do so by a licence" [1]. Three foods are carved out:

  • food additives;
  • beverages with more than 0.5% absolute ethyl alcohol by volume;
  • unprocessed Schedule 1 foods destined to become a grain, oil, pulse, sugar or beverage, labelled "For Further Preparation Only" and not consumer prepackaged [2].

Section 27(1) also lets a licence cover storing and handling imported food in its imported condition so an inspector can examine it [3].

2. Food businesses supplying export or interprovincial markets. Section 13(2) of the Act prohibits conducting a prescribed activity without a registration or licence (Justice Laws, SFCA). Section 7(2) of the Regulations sets the activities that need a licence when the food or food animal is to be exported or sent to another province [4]:

  • Food: manufacturing, processing, treating, preserving, grading, packaging and labelling.
  • Edible meat products: all of the above, plus storing and handling in the imported condition.
  • Food animals: slaughtering.

Section 7(2) excludes:

  • growers who pack and label fresh fruits or vegetables in the field, when a licence holder will process or grade them later;
  • packaging and labelling of the Schedule 1 "For Further Preparation Only" foods described above, when they are not consumer prepackaged;
  • grading of livestock and poultry carcasses;
  • restaurants and similar businesses sending food to consumers.

Section 7(2) does not apply to food additives or to beverages over 0.5% alcohol. Storing is not on that licensable list for food that is not meat [4]. Section 27(2)-(3) lists the same activities as the ones a licence can cover [3].

3. Exporters who need an export certificate. The Minister may issue an export certificate for commercial food only if the applicant "holds a licence to export the food commodity" and meets the applicable Part 4 preventive-control requirements (s. 17(2)) [5]. Section 26(2) defines what an export licence can cover [6]:

  • any food;
  • non-food commodities from animals or plants that a foreign authority requires certificates for.

4. Importing food "for export". Non-compliant food can be imported under the "Imported for Export" label. The later processing, packaging or labelling for export "must be conducted by a licence holder" (carcass grading excepted) (s. 19(2)) [7].

Who does not need a licence

  • Carriers: someone whose "sole concern" is moving the food is outside the Act and Regulations, except ss. 122, 123 and 359(3) (s. 20) [8].
  • Personal use: Act s. 19 (Justice Laws, SFCA) covers non-commercial food that is either (a) moved by an individual, not in the course of business, within the CFIA's Maximum Quantity Limits for Personal Use Exemption, or (b) part of an immigrant's or emigrant's personal effects (Regulations s. 21) [9].
  • Other carve-outs (s. 23) [10]:
    • crew and passenger food on a conveyance;
    • samples for analysis, evaluation, research or food exhibitions in shipments of 100 kg or less (for eggs, five or fewer 30-dozen cases);
    • products labelled "Not for Use as Human Food";
    • certain Akwesasne Reserve imports and in-bond supplies to cruise or military ships;
    • transfers between federal penitentiaries.
  • In-bond transit: foreign food passing through Canada in bond is outside the Act and Regulations (s. 24) [11].
  • Returned exports: food coming back in its exported condition is exempt from the import requirements under the conditions in s. 22 [12].

Licence conditions

  • Licensed activities other than importing and exporting "must" be conducted in the establishment named in the licence (s. 31(1)) [13].
  • A licence expires two years after the issuance or renewal date shown on it (s. 33(1)) [14].
  • A licence is not transferable (Act s. 20(5)) (Justice Laws, SFCA s. 20).

Approach: I read Parts 2 and 3 of the Safe Food for Canadians Regulations (consolidation current to 2026-09-21) and sections 10, 13, 19 and 20 of the Safe Food for Canadians Act on Justice Laws. I did not review provincial licensing rules for businesses that only trade within one province.

Q.02

How do I apply and what does it cost?

You apply online through a My CFIA account, and the fee is $307.96 per licence. That covers 2 years and has applied since March 31, 2026 (it was $299.86 before). The licence fee is only the entry cost. Each licensed establishment that CFIA inspects pays a separate yearly inspection fee, and import, export-certificate and meat work-shift services are charged on top.

What the Regulations say about applying

  • Form: You apply for a new licence, a renewal or an amendment to the Minister, "in a form approved by the President" (s. 28(1)) [15].
  • Meat and slaughter: If you will slaughter food animals, or make, package, label or store meat products, the application "must include at least one proposed work shift for each establishment." A work shift is capped at 7.5 hours a day and 37.5 hours a week, excluding meals. For meat processing, the shift can instead run between 6:00 a.m. and 6:00 p.m. (s. 28(2)-(3)) [15].
  • When the Minister may issue, renew or amend a licence (s. 29(1)) [16]:
    • for a new licence, you do not owe any unpaid CFIA fee;
    • you meet the applicable Part 4 preventive-control requirements;
    • importers run the business from a fixed place in Canada, or in a foreign state with a recognised inspection or food safety system;
    • meat businesses have had their work shift approved;
    • the information is "complete, truthful and not misleading";
    • the activity does not present a risk of injury to human health.
  • Refusal (s. 30): The Minister may refuse if, in the five years before you apply, you or your directors or officers had a licence suspended or cancelled, or were convicted under the Act or the Food and Drugs Act. A renewal or amendment may also be refused if you owe licence fees [17].
  • Suspension (s. 35(b)): Not paying a licence fee is also grounds for suspending the licence [18].

How to apply in practice (CFIA guidance)

  1. Set up My CFIA. Create an account (online banking or GCKey sign-in) and a business profile. Then go to "New Service Request" and choose "Safe Food for Canadians Licence Application" (CFIA, Requesting an SFC licence).

  2. Fill in the application. You give:

    • contacts;
    • interprovincial and/or export activities, and the commodities you export;
    • the establishments to be licensed and the activities at each.

    You also declare that you have written preventive control plans for the licensable activities. Then you acknowledge the disclaimers and submit (same page).

  3. Pay. You can pay on account (if you have a CFIA accounts-receivable account), online by credit card or Interac, or by EFT, cheque or cash. CFIA emails you when the licence is issued, and you print it from the "Issued Permission" tab (same page).

  4. Complete the Food Safety Supplemental Information (FSSI) questionnaire for each establishment "before your licence can be issued, renewed or amended" (CFIA, What to consider before applying).

  5. Decide how many licences you need. CFIA notes "you may have to pay a fee for each licence you request." Each licence also needs preventive control plan coverage and may be inspected. Renewal opens in My CFIA 120 days before expiry (same page).

Costs (CFIA Fees Notice, page dated 2026-09-03)

The CFIA Fees Notice sets fees under the Canadian Food Inspection Agency Act. CFIA updates them every March 31 in line with the Consumer Price Index.

Licence fee. I confirmed the same line in each of these Parts: "issuance of a licence under section 20 of the Act or the renewal of a licence under section 22 of the Act, per licence, valid for 2 years". It is $299.86 up to March 30, 2026 and $307.96 from March 31, 2026, in:

  • Part 1 (Dairy)
  • Part 2 (Egg)
  • Part 3 (Processed Egg)
  • Part 6 (Fresh Fruit and Vegetable)
  • Part 7 (Honey)
  • Part 9 (Maple)
  • Part 10 (Meat)
  • Part 16 (Fish)
  • Part 17 (Other Food Commodity)

Part 17 covers any food not caught by Parts 1, 2, 3, 6, 7, 8, 9, 10, 13 or 16, so most general food manufacturers and importers fall under it. I did not read Parts 8 or 13.

When the licence fee is due. Dairy, egg, fruit and vegetable, honey, maple, meat, fish and other-food licence fees "shall be paid at the time the application for the licence or renewal is submitted." The exception is a CFIA charge account, which is invoiced instead (Part 17 makes no charge-account exception). Processed egg fees are paid on invoice.

Other fees (from March 31, 2026), examples:

CommodityFee
Dairy establishment inspection$1,102.46 to $3,880.20 a year, depending on milk received or product made
Honey establishment inspection$114.51 (producer-grader) to $492.73 (pasteurizing) a year
Maple establishment inspection$45.80 (sugar bush) or $258.68 (packing or shipper) a year
Meat establishment inspection (imported or stored meat products)$369.52 a year
Fish establishment inspection$1,231.81 (300 m² or less of processing area) or $1,847.72 (more than 300 m²), plus process-specific add-ons over 300 m²
Fish imports$0.00246 per kg declared
Dairy export inspection$114.51, plus $22.90 per certificate

The establishment inspection fees are charged per year, per establishment, only if the establishment is inspected that year. Part 10 also has separate slaughter inspection-station and work-shift fees, which I did not read.

Approach: I read Part 3 of the Safe Food for Canadians Regulations (SOR/2018-108, consolidation current to 2026-09-21) and, because the Regulations leave the fee amounts to the CFIA Fees Notice, I opened the Fees Notice and CFIA's My CFIA licensing guidance on inspection.canada.ca.

Q.03

Why does CFIA suspend or cancel food licences?

CFIA (acting for the Minister) can suspend a Safe Food for Canadians licence for three reasons: non-compliance, unpaid licence fees, or a risk of injury to human health. It can cancel a licence mainly when a suspension has not worked or the problem is repeated or serious. That covers suspensions not fixed within 90 days, operating while suspended, convictions, repeat non-compliance, and giving false or misleading information.

Grounds for suspension (s. 35)

The Minister "may" suspend a licence if [18]:

  • (a) Non-compliance: the holder does not comply with the Act (other than section 15), the Regulations, the Food and Drugs Act or the Food and Drug Regulations.
  • (b) Unpaid fees: the holder is in default on any licence fee set under the Canadian Food Inspection Agency Act.
  • (c) Health risk: the Minister believes a risk of injury to human health may result if the holder keeps doing an activity named in the licence.

How suspension works

  • Normal route (s. 36): The Minister "must not" suspend unless the holder first got a written report. That report sets out the grounds and a deadline for corrective action, and the holder must have missed that deadline. The Minister "must" then give written notice of the suspension and when it takes effect [19].
  • Health-risk route (s. 37): "Despite section 36," the Minister may suspend immediately once the holder has received a written report of the grounds. The holder gets written notice that the suspension takes effect immediately, with no corrective-action period first [20].
  • Lifting (s. 38): The suspension "must be lifted" once the Minister decides corrective action has been taken [21].

Grounds for cancellation (s. 39)

The Minister "may" cancel a licence if [22]:

  • (a) No fix within 90 days: the holder has not taken corrective action within 90 days of the suspension. The Minister can grant a longer period if the holder asks in writing.
  • (b) Operating while suspended: the holder keeps doing a licensed activity during the suspension.
  • (c) Conviction: the holder, or any director or officer, has been convicted of an offence under the Act or the Food and Drugs Act.
  • (d) Repeat non-compliance: the holder breaches the same laws listed in s. 35(a), and since the licence was issued or renewed it has either already been suspended for breaching that same provision, or already been suspended twice.
  • (e) False or misleading information: the holder breached section 15 of the Act in its application for a new licence, renewal or amendment, or at any time while the licence was valid.

Section 15 of the Act prohibits making a false or misleading statement, or giving false or misleading information, to anyone acting under the Act, "including in respect of an application for a licence or registration" (Justice Laws, SFCA s. 15). Section 35(a) leaves section 15 out of the suspension grounds, while s. 39(e) lists it as a ground for cancellation.

How cancellation works (s. 40)

  • The Minister "must not" cancel unless the holder was told the grounds and given an opportunity to be heard.
  • The Minister "must" then give written notice of the cancellation and the date it takes effect [23].

Related points

  • Surrender (s. 34): A licence also becomes invalid if the holder surrenders it, unless it is subject to a cancellation procedure [24].
  • Effect on future applications (s. 30): As covered earlier, a suspension or cancellation in the previous five years is grounds to refuse a new application [17].

Approach: I read sections 34 to 40 in Part 3 of the Safe Food for Canadians Regulations (SOR/2018-108, consolidation current to 2026-09-21) and section 15 of the Act on Justice Laws. I did not review CFIA's internal enforcement guidance or the separate suspension and cancellation rules for organic certification in Part 13.

Q.04