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Many food importers will be required to obtain import licenses if new regulations proposed by the Canadian Food Inspection Agency come into effect.

The mandatory import license will cost about $250 and be valid for a 2-year period.

Each importer will be required to have one license, regardless of the number of products imported. Products covered by the proposed regulations are those in the Non-Federally Registered Sector; these include:

It appears that obtaining a license will require:

1. Paying a licensing fee;
2. Having a residence in Canada – (Foreign importers would need to establish and maintain a Canadian residence);
3. Developing and maintaining a Preventive Food Safety Control Plan that covers all imported products;
4. Having a written recall plan;
5. Maintaining written records at a Canadian address for 3 years; and
6. Notifying the Canadian Food Inspection Agency within 24 hours of becoming aware of a food safety concern.

All importers will be required to have an import license even if they hold other licenses or permits. Heavily regulated products already include dairy products, eggs, egg products, fish, seafood, fresh fruit, fresh vegetables, honey, meat and poultry.

Seth B. Abbey, a corporate lawyer at Spiegel Sohmer, is available to answer your questions about this and other topics.