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Most founders assume that once they hire a licensed co-packer, federal licensing is handled. Often it is. But the Safe Food for Canadians Regulations (SFCR) license activities, not companies, so the answer depends on who does what to the food before it crosses a provincial border. This article walks through common set-ups so you can see where your business fits before your first interprovincial shipment.
The rule in one paragraph
The Canadian Food Inspection Agency (CFIA) requires a licence to manufacture, process, treat, preserve, grade, package or label food that is exported or sent across provincial or territorial borders, and to import food. Each business needs a licence covering the activities it carries out itself. Food made, packaged and sold entirely within one province doesn’t need a federal licence, although some provinces have their own requirements for certain foods.
Five common set-ups
1. The co-packer does everything, and you only sell
The co-packer manufactures, packages and labels the finished product, and you market and sell it to retailers in other provinces. The co-packer needs a licence for those activities. You don’t perform a licensable activity on the food, but keep reading on traceability below.
2. The co-packer makes and packs, and you apply the labels
This is the scenario that catches brands. The CFIA’s shared-facility example is clear: if facility staff process and package the food but the brand does the labelling, the facility needs a licence to process and package, and the brand needs one to label. Applying over-stickers or retail labels yourself before shipping out of province counts.
3. One business makes it and another packs it
The CFIA also says that when one business manufactures a food and another later packages or labels it for interprovincial trade, both need a licence for their own activities. If your bulk product moves from a kitchen to a separate packing facility, check both.
4. Everything stays in one province
If your product is made, packed and sold inside a single province, a federal SFC licence isn’t required, but provincial rules may apply. Plan ahead: a single listing with a national retailer or an online order shipped to another province changes the picture.
5. You import ingredients or finished goods
Importing food is itself a licensable activity under the SFCR. If you bring in ingredients for the co-packer to use, confirm who is acting as the importer.
When in doubt, the CFIA’s licensing interactive tool will walk you through your specific situation.
Preventive control plans: who writes one?
Most licence holders must prepare, keep and implement a written preventive control plan (PCP) showing how hazards are identified and controlled. There’s an exception for some businesses with gross annual food sales of $100,000 or less, but it doesn’t apply to processed fruit or vegetable products, dairy, eggs, fish or meat, or to businesses requesting export certificates, and exempt businesses must still meet preventive control requirements such as sanitation and pest control. If set-up 2 or 3 applies to you, that obligation may land on your desk as well as your co-packer’s.
Traceability and lot codes
Where SFCR traceability rules apply, consumer prepackaged food must carry a lot code, and records must let you trace food one step forward and one step back. Agree with your co-packer how a lot is defined (for example by production day, shift and line) and where the code is printed, because a narrower lot can limit the scope of a recall. Brand owners shipping across borders can have traceability record-keeping duties even without a licence of their own.
Five questions to ask your co-packer this week
- What is your SFC licence number, and which activities and food categories does it cover?
- Will you apply the final retail label, or will we?
- How does your PCP cover a product like ours?
- How do you define a lot, and where does the code go on our package?
- What records will we receive with each production run?
For the full selection process, including facility visits, sample runs and contract terms, read our guide on how to choose a co-packer in Canada. Comparing pricing at the same time? See co-packing costs and MOQs.
Where COPACK Canada fits
COPACK Canada co-packs food, sauces, condiments, snacks and beverages from Toronto and Vancouver, and offers labeling and label compliance support as part of its service. Bring these questions to your first conversation. When you request a quote, the form lets you list the certificates your buyers require.
FAQ
Do I need an SFC licence if my co-packer is licensed?
Not if the co-packer performs every licensable activity and you only market and sell. If you label, package or import the food yourself for interprovincial trade or export, you may need your own licence.
How long is an SFC licence valid?
The CFIA states that a licence is valid for two years.
Does selling online to other provinces count?
Shipping food across provincial or territorial borders is interprovincial trade, which brings SFCR licensing into play for the businesses performing licensable activities.
Sources
- CFIA, Food business activities that require a licence under the SFCR (inspection.canada.ca)
- CFIA, Licensing under the Safe Food for Canadians Regulations (inspection.canada.ca)
- CFIA, Preventive control plan exception for small food businesses (inspection.canada.ca)
- CFIA, Selecting a lot code to meet traceability requirements (inspection.canada.ca)
- Western Economic Diversification Canada, Resource Guide for Co-packing (2020), hosted by Manitoba Agriculture
This article is general information, not legal, regulatory or food safety advice. Confirm requirements with the CFIA and a qualified advisor.