Preregistration of Packaging Materials Used in Federally Registered Canadian Meat Processing Plants No Longer Required

Packaging materials, along with construction materials and non-food chemicals, used in federally registered meat processing plants in Canada no longer need to be registered with the Canadian Food Inspection Agency (CFIA) as a result of recent amendments to the Canadian Meat Inspection Regulations (1990). The regulatory changes, which were proposed in April 2012, were published in the Canada Gazette on July 2, 2014 and became effective that day.

With respect to packaging materials, Paragraph 92 was amended. Previously, it stated:

1. No material used in packaging or labelling a meat product in a registered establishment shall come into contact with the meat product if the contact might prevent the meat product from conforming to the requirements of these Regulations or the Food and Drug Regulations.
2. No material used in packaging or labelling a meat product in a registered establishment shall come into contact with the meat product unless the material:
   1. is durable and effective, having regard to the manner in which it is used; and
   2. is suitable for the purpose for which it is to be used and is registered by the Director in a register kept for that purpose.

Paragraph 92(2)(b) now reads " is suitable for the purpose for which it is to be used."

Premarket clearance is still required for packaging for infant formula, novel foods, and processing aids for meat. More specifically, CFIA still requires a Letter of No Objection (LONO) from Health Canada for processing aids intended to be used as antimicrobial agents prior to their use in federally registered meat facilities. Additionally, Canada's Food and Drug Regulations require a LONO from Health Canada for packaging materials used in infant formula or novel process (i.e., high pressure processing).

CFIA will continue to conduct inspections of federally registered meat facilities to ensure that packaging materials are suitable for their intended purpose and that they meet all Canadian regulatory requirements. A Q&A Document on repealing the requirements for premarket registration of construction materials, packaging materials, and non-food chemicals lists three options that operators of federally registered meat establishments can used to demonstrate that these materials are safe and suitable for their intended use, and that they meet all regulatory requirements. These are:

• Previously issued CFIA letters of acceptance/no objection (i.e., the material is already listed on CFIA's Reference Listing of Accepted Construction Materials, Packaged Materials, and Non-Food Chemical Products)
• Letters of guarantee from suppliers/manufacturers
• A LONO from Health Canada, or other references from Health Canada

If a Letter of Guaranty is used to demonstrate safety, inspectors will have the option to request additional supporting documentation if they have a reasonable doubt regarding the safety of the packaging material for its intended use. CFIA has indicated that an existing U.S. or European Union clearance could be used as supporting documentation to show safety.

The Reference Listing of Accepted Construction Materials, Packaged Materials, and Non-Food Chemical Products will be maintained on the CFIA website for approximately two years, however, it will no longer be updated.