PFAC RegReport FallVol11No2 2019

Fall, 2019, Vol 11, Issue 2 Regulatory Report A PUBLICATION FOR MEMBERS OF THE PET FOOD ASSOCIATION OF CANADA C A F P This memorandum provides information about regulatory initiatives affecting the import and export of pet food and is based upon the most current information available at the time of publication. All rights reserved. Copyright 2019. Pet Food Association of Canada PO Box 35570, 2528 Bayview Avenue, Toronto, ON M2L 2Y4 Tel: 416-447-9970 • Email: petfood@pfac.com • www.pfac.com MESSAGE FROM THE CHAIR Welcome to the Fall 2019 issue of the PFAC Regulatory Report, which includes a summary of the current regulatory issues being monitored within the Regulatory Affairs Advisory Group (RAAWG). I certainly hope everyone had a great time at the 2019 PFAC Annual Conference in Montreal. It was our best attended conference ever and was great to see so many involved and engaged. The last RAAWG face to face meeting was May 13, 2019 however the group has been very active with many ad hoc meetings and discussions on various topics. This report will go into more detail on each one of the issues discussed and provide a current status of the challenges facing the industry. PFAC will be undertaking a full review of the RAAWG with regards to its structure, member selection criteria and group size, and other aspects. It is felt that while this group has been effective, there is room for improving efficiency and focus. More regular communications to the broader membership on regulatory and trade issues is also being explored. Any changes will be communicated to the membership well in advance of being implemented. This report will continue to be published and sent to members biannually in 2020. Thank you for your ongoing engagement and support of PFAC and the industry. Melanie Sippel, Trouw Nutrition Canada Chair, Regulatory Affairs Advisory Working Group Page 2 Regulatory Report A PUBLICATION FOR MEMBERS OF THE PET FOOD ASSOCIATION OF CANADA Fall, 2019, Vol 11, Issue 2 This memorandum provides information about regulatory initiatives affecting the import and export of pet food and is based upon the most current information available at the time of publication. All rights reserved. Copyright 2019. Pet Food Association of Canada PO Box 35570, 2528 Bayview Avenue, Toronto, ON M2L 2Y4 Tel: 416-447-9970 • Email: petfood@pfac.com • www.pfac.com MESSAGE FROM THE DIRECTOR, REGULATORY AFFAIRS AND GOVERNMENT RELATIONS I would like to thank everyone for your support in my transition to this role and industry. There have been many important regulatory challenges for the industry so far in 2019, and with your feedback and ongoing support, I feel that they have been successfully managed. The work is certainly not done, and I have big plans for 2020. As Melanie mentioned, I will be reviewing the RAAWG structure and function and proposing recommendations for improvement. I will be looking at using our Membership management software to create an online discussion forum for regulatory discussion, and a place for better communication and sharing of information. Now that the election is over and we know the results, I will be launching a government relations strategy early in 2020 to meet with some key officials in the Ministry of Agriculture and AgriFood, as well as Trade to raise the profile of the pet food industry in Canada. With so much on our plate, I truly appreciate the great members we have to work together to continue to grow the industry and manage regulatory challenges as they come. Thank you! Chris Nash Director, Regulatory Affairs and Government Relations cnash@pfac.com Page 3 Regulatory Report A PUBLICATION FOR MEMBERS OF THE PET FOOD ASSOCIATION OF CANADA Fall, 2019, Vol 11, Issue 2 This memorandum provides information about regulatory initiatives affecting the import and export of pet food and is based upon the most current information available at the time of publication. All rights reserved. Copyright 2019. Pet Food Association of Canada PO Box 35570, 2528 Bayview Avenue, Toronto, ON M2L 2Y4 Tel: 416-447-9970 • Email: petfood@pfac.com • www.pfac.com REGULATORY AFFAIRS ADVISORY WORKING GROUP (RAAWG) The RAAWG is a group of volunteers who are appointed for a one-year term to help provide detailed analysis of the regulatory issues we work on. The group is active and there is an expectation that a volunteer will have the time to commit to review and comment as requested. The RAAWG for 2019 is made up of the following people: Melanie Sippel, Trouw Nutrition Canada (Chair) Laurie Ross, Mars Canada Janice Baker, Nestle Purina Petcare Chinedu Ogbonna, Champion Pet Foods Jeffrey Park, ADM Mary Ann Zamora Grepe, Elmira Pet Food Michael Faurot, Hills Pet Nutrition Robert Nixon, Royal Canin Page 4 Regulatory Report A PUBLICATION FOR MEMBERS OF THE PET FOOD ASSOCIATION OF CANADA Fall, 2019, Vol 11, Issue 2 This memorandum provides information about regulatory initiatives affecting the import and export of pet food and is based upon the most current information available at the time of publication. All rights reserved. Copyright 2019. Pet Food Association of Canada PO Box 35570, 2528 Bayview Avenue, Toronto, ON M2L 2Y4 Tel: 416-447-9970 • Email: petfood@pfac.com • www.pfac.com The Pet Food Safety Advisory Working Group assists the Board on matters pertaining to the safe production of pet food. PFSAWG has been instrumental in reviewing GMPs that will be included in the new Manufacturing Guidance document that PFAC will release this spring. The PFSAWG convenes on an as-needed basis when the Board requires its advice. As is the case with other working groups, members are appointed on a 1-year basis. 2019 PFSAWG: Gayan Hettiarachchi, Champion Petfoods Anna Doupe Trouw Nutrition Charles Shagass, Elmira Pet Products Elmer Eng, Nestle Purina Petcare Shannon Harrison; Simmons Pet Foods Natasha Bangel; Hills Pet Nutrition Dana Delacey-Wilson, Mars Canada The RAAWG maintains a spreadsheet of regulatory issues that we are working on. This spreadsheet forms the basis of those issues that we are providing comment on, are monitoring, have completed, or are in progress. You can assist in making this tracker as complete as possible by providing information on regulatory issues that you are facing, or that you are aware of provincially, nationally, or globally. PET FOOD SAFETY ADVISORY WORKING GROUP (PFSAWG) REGULATORY TRACKER Page 5 Regulatory Report A PUBLICATION FOR MEMBERS OF THE PET FOOD ASSOCIATION OF CANADA Fall, 2019, Vol 11, Issue 2 This memorandum provides information about regulatory initiatives affecting the import and export of pet food and is based upon the most current information available at the time of publication. All rights reserved. Copyright 2019. Pet Food Association of Canada PO Box 35570, 2528 Bayview Avenue, Toronto, ON M2L 2Y4 Tel: 416-447-9970 • Email: petfood@pfac.com • www.pfac.com CFIA NEWS CFIA leadership and Directorate personnel have not changed since we met at Dialogue in May 2019. The recognition of PFAC as the lead industry association for pet food within the Agency continues to be strong. Now, more than ever, it is important for pet food manufacturers and suppliers to our industry to support our activities and our role as the national voice for the pet food industry in Canada. We are pleased to report that PFAC was invited to present on pet food nutrition during the joint CFIA CVMA Animal Health Week. This was hosted by the Chief Veterinary Officer (CVO) and attended by senior staff in the Feed division, animal health and import/export group, among others. During this meeting, PFAC was invited to participate in a Chief Veterinary Officer (CVO) office working group to advise on the submission to the OIE for review of Canada’s BSE status. This is a high profile activity because Canada’s BSE status can be changed as early as 2020 and our invitation shows a recognition of the importance of the pet food industry perspective industry on this working group. There is more on the BSE submission below in the OIE section. Page 6 Regulatory Report A PUBLICATION FOR MEMBERS OF THE PET FOOD ASSOCIATION OF CANADA Fall, 2019, Vol 11, Issue 2 This memorandum provides information about regulatory initiatives affecting the import and export of pet food and is based upon the most current information available at the time of publication. All rights reserved. Copyright 2019. Pet Food Association of Canada PO Box 35570, 2528 Bayview Avenue, Toronto, ON M2L 2Y4 Tel: 416-447-9970 • Email: petfood@pfac.com • www.pfac.com GOVERNMENT AND STAKEHOLDER RELATIONS PFAC has continued to meet with key government staff in both CFIA, AAFC, and their joint international branch office. This has proved important in getting a different perspective on some issues that the CFIA animal by-products group were not equipped to manage. The Canadian federal election happened October 21, 2019, with a Liberal minority win. At this point it is too early to say for certain, but likely that the Liberals will form a government with the NDP holding the balance of power. Regardless of leading party, PFAC has a government relations strategy for 2020. It is best to wait until the new government has settled in, Ministers chosen, and mandate letters sent before making appointments to meet. Starting early in 2020, PFAC will take a top down approach for raising the profile of both PFAC and the pet food industry with government. This will start with meeting the Minister of Agriculture, and ideally the Minister of Trade. The next step will be to meet the senior bureaucratic staff, and down the chain of command to the technical people we work with most, so the message is heard from the top down. The other meetings to consider will be those with the opposition’s shadow cabinet, seeking opportunities to present before a House of Commons or Senate committee on a study that is relevant to the pet food industry. The objective of these meetings is to highlight the pet food industry and its contributions to the Canadian economy, its importance to the general public, and its export growth potential. We expect this will lead to pet food being a higher priority, but also to government officials calling us to meet instead of always meeting with them only when we have an issue. To this end, we will be looking for feedback from members throughout 2020 to inform these meetings and may ask some members to attend some key meetings, because it is always best when a Minister hears from industry stakeholders instead of just an association. Page 7 Regulatory Report A PUBLICATION FOR MEMBERS OF THE PET FOOD ASSOCIATION OF CANADA Fall, 2019, Vol 11, Issue 2 This memorandum provides information about regulatory initiatives affecting the import and export of pet food and is based upon the most current information available at the time of publication. All rights reserved. Copyright 2019. Pet Food Association of Canada PO Box 35570, 2528 Bayview Avenue, Toronto, ON M2L 2Y4 Tel: 416-447-9970 • Email: petfood@pfac.com • www.pfac.com DISCUSSION BY MARKET - CANADA/USA DOMESTIC SUBSTANCE LIST Many of you will be aware that PFAC has been working towards finding an elegant solution to a very large gap in the reporting and registering of pet food ingredients on the Domestic Substance List (DSL). We are happy to report that there has been great progress made over the summer and early fall on the DSL project. PFAC staff, led by Chris Nash, received several ingredient inventories from PFAC members, and these were reviewed in great detail and compared against the DSL, Schedule IV and V in the Feed Regulations, and re-categorized into exempt with justification, and needs more information. The goal of the review was to refine the potential list of ingredients that would require notification to the DSL. At time of writing this report, over 1200 ingredients were reviewed, and of these less than 10% have not yet been added to the exempt list. Those that remain needed more information and have been followed up on, but not yet reviewed fully. It is expected that only about 2% of ingredients will be difficult to exempt under the current regulations. Having said this, PFAC met with Environment and Climate Change Canada (ECCC) in September and discussed some of the more challenging ingredients. These included those that were natural, but more highly processed than what the regulatory definition allowed for, so ECCC has agreed to have a discussion on making a policy decision on where to draw the line on ‘occurring in nature’. It is likely that there will be some ingredients that are not possible to exempt from the notification process, but until these have been identified completely, and all avenues have been exhausted, we will not know what those are. The industry will have to have a discussion on how best to complete (and pay for) the notification process, especially if it ends up being ingredients used by many companies. At this point, we have shown progress, and feel that ECCC is satisfied so far with what has been done. Once down to the final list of ingredients that need to be possibly notified, PFAC will send out a list of ingredients to all members to identify if anything has been missed, looking for only those that are not yet captured. Thanks to the support and follow up from those members who have shared information so far. Page 8 Regulatory Report A PUBLICATION FOR MEMBERS OF THE PET FOOD ASSOCIATION OF CANADA Fall, 2019, Vol 11, Issue 2 This memorandum provides information about regulatory initiatives affecting the import and export of pet food and is based upon the most current information available at the time of publication. All rights reserved. Copyright 2019. Pet Food Association of Canada PO Box 35570, 2528 Bayview Avenue, Toronto, ON M2L 2Y4 Tel: 416-447-9970 • Email: petfood@pfac.com • www.pfac.com DISCUSSION BY MARKET - CANADA/USA (continued) IMPORT CHANGES AIRs Changes and CFIA Policy Change on Importing Products that Contain a Mixture of Ingredients Starting on November 1, 2019 guidelines for importing products of animal origin containing multiple ingredients came into effect. These changes affect pet food because they include commodities containing products of a rendering plant or other animal-origin ingredients. CFIA has said that these changes will not affect finished pet food, because those have clearly defined HS codes and OGD extensions, and the import conditions are clearly listed in AIRS. Single ingredient commodities will also not be affected. Where this policy gets tricky is in mixed ingredients used in pet food, like seasonings, flavours, different blends etc. Some members have reported that it is somewhat difficult to identify the correct OGD extension for the product being imported, because in some cases the tariff/customs HS codes don’t link up correctly with the OGD extensions in AIRS. This is an issue where it may not be visible right away, because if things are still crossing the border without incident, then it may not be noticeable until something gets stopped. PFAC will attempt to gain clarification on this and further guidance from CFIA on how best to identify the correct codes for imported mixed substances. Non-Ruminant Rendered Materials Certificates This new certificate was developed by USDA and CFIA and was finalized at some point in the summer. CFIA will still require import permits that include the same sanitary statements that have been negotiated and in the certificates. The updated USDA document is published here: https://www.aphis.usda.gov/aphis/ ourfocus/animalhealth/export/iregs-for-animal-product-exports/sa_international_ regulations/sa_products_canada/ct_product_canada_rendered Page 9 Regulatory Report A PUBLICATION FOR MEMBERS OF THE PET FOOD ASSOCIATION OF CANADA Fall, 2019, Vol 11, Issue 2 This memorandum provides information about regulatory initiatives affecting the import and export of pet food and is based upon the most current information available at the time of publication. All rights reserved. Copyright 2019. Pet Food Association of Canada PO Box 35570, 2528 Bayview Avenue, Toronto, ON M2L 2Y4 Tel: 416-447-9970 • Email: petfood@pfac.com • www.pfac.com DISCUSSION BY MARKET - CANADA/USA (continued) Freeze Dried and Raw Certificate for Import from the US The CFIA has been working on development of a harmonized certificate with the US for import of freeze dried and raw materials and pet foods, without the need for an import permit in Canada. The last update received was that this was still under development, and unknown when it would be implemented. There may have been an update at the conference on this. EXPORT UPDATES Export of Raw Pet Food and Treats to US The USDA and the CFIA have agreed on the export certification of raw pet food/ treats to the USA. This certificate also applies to raw pet food legally imported from the USA for further re-export to that country. No USDA permit is required but the facility must be approved for export of Animal by-products to the USA (BSE questionnaire for non-thermally processed ABP). Original certification is required for every shipment. The implementation date for the use of the new certificate (HA3025) was October 1st, 2019. There will be a transitional period of one year during which, the CFIA will issue either an in-house certificate for facility already having an import permit or the HA3025, for facility that have been inspected and approved by the CFIA. As of October 1st, 2020, no in-house certificate will be issued. US – Japan FTA Agreement As we all know, Canada enjoyed an advantage over the US through the implementation of the CPTPP free trade agreement (FTA) before December 31, 2018, which allowed for a tariff reduction for 2018 and another one early in 2019. With the new US-Japan FTA coming into force on January 1, 2020, this advantage is gone at least with Japan, as the US agreement brings them to the same tariff levels as Canada immediately. Page 10 Regulatory Report A PUBLICATION FOR MEMBERS OF THE PET FOOD ASSOCIATION OF CANADA Fall, 2019, Vol 11, Issue 2 This memorandum provides information about regulatory initiatives affecting the import and export of pet food and is based upon the most current information available at the time of publication. All rights reserved. Copyright 2019. Pet Food Association of Canada PO Box 35570, 2528 Bayview Avenue, Toronto, ON M2L 2Y4 Tel: 416-447-9970 • Email: petfood@pfac.com • www.pfac.com DISCUSSION BY MARKET - CANADA/USA (continued) Grain Free Diets There is not much new to report on this, other than the FDA, PFI, and the US and Canadian pet food industry is working on better understanding the cause of dilated cardiomyopathy (DCM) in certain cases in the US that the FDA has linked to grain free diets. There is some anecdotal research to show that dogs with no genetic predisposition who ate grain free diets and were diagnosed with DCM, and then switched to a different diet, had their symptoms ease. This was reported by the FDA at a conference, and was anecdotal at best. At this point, there still isn’t a strong amount of research or information that undeniably links DCM to any one type of diet, and the FDA still has not issued any advisory to change diet. We will continue to monitor and work with PFI to support as required. Page 11 Regulatory Report A PUBLICATION FOR MEMBERS OF THE PET FOOD ASSOCIATION OF CANADA Fall, 2019, Vol 11, Issue 2 This memorandum provides information about regulatory initiatives affecting the import and export of pet food and is based upon the most current information available at the time of publication. All rights reserved. Copyright 2019. Pet Food Association of Canada PO Box 35570, 2528 Bayview Avenue, Toronto, ON M2L 2Y4 Tel: 416-447-9970 • Email: petfood@pfac.com • www.pfac.com WORLD MARKETS RUSSIA To provide a quick background on this issue: In late 2018, a Canadian company was temporarily suspended by Russia for allegedly not meeting the Russian GMO regulatory requirements. Since this time, the CFIA has received communication from Russian authorities asking questions and for a response to understand how compliance to these regulations will be met for all Canadian pet food exporters. The RAAWG had several conversations and PFAC had several discussions with CFIA on this topic to help support a response to Russia. In the end, PFAC reached out to the Market Access Secretariat and those responsible for this region of the world. A practical approach was developed to respond only with what was being asked, and not open up the conversation at this time to anything to do testing or any additional requirements for companies to meet. At the time of writing this report, we are still waiting for a response from Russia. PFAC has held the CFIA and MAS to task to do what they can and represent the industry’s interests for this important market. Around the same time, there were other companies temporarily suspended in Europe, so PFAC will discuss this further with FEDIAF and try to better understand from a Russian perspective by speaking with the Russian Pet food association. We will continue to monitor and act on members’ behalf and in your best interests to implore CFIA to take a slow and calculated approach to make sure any changes are practical and on our terms. EU In the early summer, PFAC received notice from CFIA that new certificates would be ready for use near the end of July and go into force as of August 1, 2019. Not only were the certificates delayed for use in some regions of Canada, some District offices of CFIA were also backlogged in signing the ‘old’ certificates, which needed to be completed by July 31. This was a problem, because the new certificates weren’t ready either. Since then, we have heard from a few members that the cross-outs on the EU certificates are not clear and may not be correct. CFIA District veterinarians were unsure of how these were to be done, while at the same time there were issues with veterinarians in the EU as to how they should be done. At Page 12 Regulatory Report A PUBLICATION FOR MEMBERS OF THE PET FOOD ASSOCIATION OF CANADA Fall, 2019, Vol 11, Issue 2 This memorandum provides information about regulatory initiatives affecting the import and export of pet food and is based upon the most current information available at the time of publication. All rights reserved. Copyright 2019. Pet Food Association of Canada PO Box 35570, 2528 Bayview Avenue, Toronto, ON M2L 2Y4 Tel: 416-447-9970 • Email: petfood@pfac.com • www.pfac.com WORLD MARKETS (continued) the same time, the naming conventions were changed without notice on the new certificates. This caused additional problems for some. This all to say that PFAC will use this as a prime example of the disorganization of CFIA on rolling out changes, and the significant logistical and financial impacts these types of issues can have on companies. INDIA There still has not been any formal publication of the certificate in the Indian gazette process. Earlier this year, PFAC and the Trade Commission held a webinar on India, and the India International Pet Trade Fair was held in August. There seems to be significant potential in this market, but until the certificate is formally published, it is up to individual companies if they want to accept the level of commercial risk in exporting to India. We will continue to follow up, but it appears that there isn’t much to do but wait for the certificate to be published. CHILE There have been two recent updates on Chile. The first, is an updated list of third country establishments producing ruminant meat and bone meal that are approved for export to Chile, found here: http://www.sag.gob.cl/ambitos-de-accion/lista-de- alimentos-importados-para-animales-autorizados-por-monografia-de-proceso-o- por-habilitacion-directa/1735/registros At the moment, there are no establishments in Australia or New Zealand producing ruminant meat and bone meal, approved for export to Chile. This information has been confirmed by the Chilean authorities. Therefore, the industry is asked to continue ensuring that pet food intended for export to Chile does not contain any ruminant meat and bone meal from these two countries. The second update is regarding the Chilean resolution No:7885/2017 establishing maximum limits for chemical contaminants in products intended for animal feed, indicates that, in terms of mycotoxins, aflatoxin B1 is the only concern and that the maximum limit of aflatoxin B1 allowed in pet food is 10ppb. Page 13 Regulatory Report A PUBLICATION FOR MEMBERS OF THE PET FOOD ASSOCIATION OF CANADA Fall, 2019, Vol 11, Issue 2 This memorandum provides information about regulatory initiatives affecting the import and export of pet food and is based upon the most current information available at the time of publication. All rights reserved. Copyright 2019. Pet Food Association of Canada PO Box 35570, 2528 Bayview Avenue, Toronto, ON M2L 2Y4 Tel: 416-447-9970 • Email: petfood@pfac.com • www.pfac.com This has been a regulation since 2017, but only until recently has the CFIA been enforcing it, and doing so consistently across the country. THAILAND The CFIA received confirmation from the Thai authorities that companies manufacturing pet food must register their products before they can export them. The registration of these products requires among others to provide a certificate of free sale mentioning the name of the products to be registered. To obtain this certificate of free sale, Companies will have to provide a declaration mentioning the list of products to be registered. MEXICO SENASICA will enforce the implementation of the sanitary requirement under Chapter III, Article 15, paragraph IV of the Decision announcing the general criteria applied by Mexico in establishing and amending safety requirements for the importation of animal, plant, aquatic and fisheries goods regulated by SADER through SENASICA. This amendment is incorporated into the relevant animal health requirement sheets (HRZs). For the mitigation of risks to the safety of goods of animal, plant, aquaculture or fishing origin, in order to achieve the appropriate level of protection for the country, the Secretariat decided to apply the following measure: Article 15. IV. The imported products must be presented in new boxes, bags or packaging, must come free of ectoparasites and without signs of disease; if they come in small sacks, combos, boxes and containers these must come in pallets; the labels must match the documentary information; the containers must come free of organic residues, both in their inside and outside and with chilling equipment and anti-spilling system, when required. WORLD MARKETS (continued) Page 14 Regulatory Report A PUBLICATION FOR MEMBERS OF THE PET FOOD ASSOCIATION OF CANADA Fall, 2019, Vol 11, Issue 2 This memorandum provides information about regulatory initiatives affecting the import and export of pet food and is based upon the most current information available at the time of publication. All rights reserved. Copyright 2019. Pet Food Association of Canada PO Box 35570, 2528 Bayview Avenue, Toronto, ON M2L 2Y4 Tel: 416-447-9970 • Email: petfood@pfac.com • www.pfac.com WORLD MARKETS (continued) KOREA There is no further update on the internal discussion by Korea on what they consider to be a ‘raw material’. We will continue to follow up with CFIA and monitor this for developments. A webinar was held to provide economic, cultural and practical considerations in doing business in S. Korea and Taiwan. The Trade Comissioner provided information about an opportunity for attending the Korean K-Pet trade mission in November 2019. Regarding Korea as well, we have received a clarification for use of vitamin D from ovine sources used in pet food being sent to Korea. According to the quarantine rule of Korea, ovine lanolin (Vitamin D) is not a risk factor for animal health, so no Korean import restrictions apply to this ingredient. Therefore, Korean authorities asked, when an exported product contains such ingredient to write the information on the certificate as follows: Ovine (Vitamin D-Lanolin) or ovine (Lanolin) instead of Ovine (Vitamin D). CHINA China continues to be a challenging market, and there haven’t been any updates from CFIA recently on how they plan to handle approving new companies for the Chinese market. Last discussed, China wanted a reciprocal agreement, whereby they could approve Chinese companies for export to Canada. The CFIA has indicated that it is not accepting of such a reciprocal arrangement. On top of this, the political issues have been mounting with China, as they have banned canola exports from Canada, as well as some meat products for labelling issues. With the trade ‘war’ and discussions ongoing between the US and China, it is politically volatile, and uncertain now how things will unfold. PFAC will continue to monitor and may look at holding a webinar with the Trade Commission on this market. Page 15 Regulatory Report A PUBLICATION FOR MEMBERS OF THE PET FOOD ASSOCIATION OF CANADA Fall, 2019, Vol 11, Issue 2 This memorandum provides information about regulatory initiatives affecting the import and export of pet food and is based upon the most current information available at the time of publication. All rights reserved. Copyright 2019. Pet Food Association of Canada PO Box 35570, 2528 Bayview Avenue, Toronto, ON M2L 2Y4 Tel: 416-447-9970 • Email: petfood@pfac.com • www.pfac.com WORLD MARKETS (continued) HONG KONG Just recently, the Trade Commissioner in Hong Kong has reached out to PFAC to ask for more information to support their plan for exhibiting at a pet food show in February 2020. We will provide what we can, but also ask about holding a webinar on Hong Kong if there is interest. We will keep members posted on these opportunities. EL SALVADOR Although likely a small market, the opportunity to export to El Salvador now exists, with an approved certificate by CFIA. In order to export to this market however, pet food plants must be inspected and approved by the Salvadorian authorities and the products registered in El Salvador. CFIA is working with the Salvadorian authorities with regard to the pet food audit. As more information becomes available, PFAC will send notifications. AZERBAIJAN CFIA has informed us that Azerbaijan have opened their market to Canadian pet food. The certificates have been approved and will be validated soon, and pet food guidance has been updated with the requirements for this country. NEW ZEALAND The CFIA has now updated the pet food export guidelines regarding export of Shelf-Stable pet food containing bovine material to New Zealand. New Zealand has changed its SRM definition to align with the OIE list of SRM. The CFIA has developed an export certificate attesting to the import requirements found here: Industry must ensure that no material listed in the document found in the guidelines is used in the manufacture of pet food for New Zealand. Take note that tongues from animals of all ages can be used as raw material only if the lingual tonsils are removed. Details will be provided shortly in the guidelines. An exporter’s declaration must be included with the shipment. Page 16 Regulatory Report A PUBLICATION FOR MEMBERS OF THE PET FOOD ASSOCIATION OF CANADA Fall, 2019, Vol 11, Issue 2 This memorandum provides information about regulatory initiatives affecting the import and export of pet food and is based upon the most current information available at the time of publication. All rights reserved. Copyright 2019. Pet Food Association of Canada PO Box 35570, 2528 Bayview Avenue, Toronto, ON M2L 2Y4 Tel: 416-447-9970 • Email: petfood@pfac.com • www.pfac.com OIE The CFIA is working on developing a submission to the OIE for review of Canada’s BSE status. PFAC has been invited to be part of the working group of industry- government that is undertaking the process of informing the submission. The expected timeline for the submission, review, and hopefully adoption of a change to negligible status is as follows: July 2020 – CFIA provides submission to OIE working group Fall 2020 – OIE Working group completes initial review Winter 2021 – OIE Scientific review of submission May 2021 – Adoption by OIE of Canada’s request for change of BSE status It goes without saying that this is a critical process that will have significant positive impacts to the Canadian pet food market. PFAC will support this working group as best as we can and will be requesting feedback and information from members to do so. MERCOSUR The Canadian government has been having ongoing meetings and discussions on this trade block, and the potential for a FTA with these countries. To this end, this summer, trade negotiators asked for further information from our sector, and PFAC provided what we could. Thank you to those who provided feedback. We will continue to participate in the MERCOSUR conference call updates and to monitor this and other ongoing trade discussions. CUSMA With the political uncertainty in the US at the moment, and the new government in Canada needing to be settled in, the formal ratification and implementation of the ‘new NAFTA’ agreement is likely not going to happen in 2019. We will monitor and review as it does happen and provide further updates. FREE TRADE AGREEMENTS Page 17 Regulatory Report A PUBLICATION FOR MEMBERS OF THE PET FOOD ASSOCIATION OF CANADA Fall, 2019, Vol 11, Issue 2 This memorandum provides information about regulatory initiatives affecting the import and export of pet food and is based upon the most current information available at the time of publication. All rights reserved. Copyright 2019. Pet Food Association of Canada PO Box 35570, 2528 Bayview Avenue, Toronto, ON M2L 2Y4 Tel: 416-447-9970 • Email: petfood@pfac.com • www.pfac.com FREE TRADE AGREEMENTS (continued) BREXIT This situation has been a rollercoaster, with numerous extensions on the ‘leave’ date. The latest at the time of writing this report is that the British parliament has voted down Boris Johnsons proposed deal, and with only 9 days until the formal leaving date of October 31, they will continue to vote until a deal is reached and legislation passed. Otherwise, a no-deal Brexit could occur, given the limited timeframe left. This scenario could trigger another extension to allow for more time. In any case, MAS has provided insight into how trade will hopefully not be disrupted. Guidance documents have been created in preparation of a ‘no-deal’ exit. We still need to gain clarity on CFIAs role in inspections, and what certificates will be used and the timelines for transition to whatever the new system or new trading agreement may be with Canada. CETA The CETA agriculture committee met in September in Ottawa. The meeting focused on beef and pork tariff rate quotas, Canadian cheese, wheat exports to EU, EU vet. Medicinal regulation, and dairy. Page 18 Regulatory Report A PUBLICATION FOR MEMBERS OF THE PET FOOD ASSOCIATION OF CANADA Fall, 2019, Vol 11, Issue 2 This memorandum provides information about regulatory initiatives affecting the import and export of pet food and is based upon the most current information available at the time of publication. All rights reserved. Copyright 2019. Pet Food Association of Canada PO Box 35570, 2528 Bayview Avenue, Toronto, ON M2L 2Y4 Tel: 416-447-9970 • Email: petfood@pfac.com • www.pfac.com GAPFA PRIORITIES 2019 The GAPFA Technical Congress and other meetings was held in Mexico City at the end of October, so at the time of writing this report, any new information, updates, or 2020 priorities was not included in this report. If possible, these will be discussed during the Regulatory presentation at the PFAC conference and added to the spring 2020 regulatory report. FOOD SAFETY AND TRADE FACILITATION WORKSTREAM OBJECTIVES a. Finalize ‘safe to trade’ guidance for pet food, for the OIE chapter proposal This work is ongoing and being undertaken in several smaller projects and working groups. PFAC has had discussions at the RAAWG and Board level on the principles for sourcing of ingredients of animal origins, ensuring that the language is inclusive enough for the Canadian reality and consider novel sources of protein and how those may be handled in the future. b. Request OIE to recognize mitigation requirements for pathogens proposed by GAPFA GAPFA members have reviewed Terrestrial Code chapters to identify animal diseases of concern and provide information on how pet food processing may mitigate risk of these diseases if possible. This work was summarized and will be provided as part of the package to OIE in the ongoing discussions around a ‘Pet Food Chapter’ and/or global certificate. c. Development of global industry testing method on undesirable substances and create MRL safe harbour approach This work is ongoing, and a smaller working group of experts on testing methodology is being formed to discuss this topic. PFAC will continue to monitor and ask for feedback and support as needed. Page 19Fall, 2019, Vol 11, Issue 2 This memorandum provides information about regulatory initiatives affecting the import and export of pet food and is based upon the most current information available at the time of publication. All rights reserved. Copyright 2019. Pet Food Association of Canada PO Box 35570, 2528 Bayview Avenue, Toronto, ON M2L 2Y4 Tel: 416-447-9970 • Email: petfood@pfac.com • www.pfac.com Regulatory Report A PUBLICATION FOR MEMBERS OF THE PET FOOD ASSOCIATION OF CANADA HEADING GAPFA PRIORITIES (continued) NUTRITION WORKSTREAM a. Align on global industry maximum safety limits of Inorganic Phosphorus in cat food Research on this is ongoing, and PFAC will continue to monitor and provide updates to members. b. Develop GAPFA Guidelines on Veterinary Dietetic Products PFAC has asked for and received some feedback from members on the idea of guidelines for Vet dietetic products. For Canada, it is likely not currently necessary given the structure of this specific market. If the veterinary community shows they need this guidance, or if companies change their marketing strategy for this category, then perhaps it is worth pursing for Canada, but at the moment it is not. We will continue to monitor and offer input as required. DIALOGUE 2020 May 12, 2020 9:00 – 3:00 pm Hilton Garden Inn Ottawa Airport 2400 Alert Rd, Ottawa, ON K1V 1S1 2020 PFAC CONFERENCE 50th Anniversary November 3-4, 2020 Rimrock Resort Hotel 300 Mountain Ave, Banff, AB T1L 1J2 UPCOMING EVENTS C A F P 5 0 Y E A R S C E L E B R A T I N G