Summary: If your business manufactures, processes, packages, labels, imports, or distributes food in Canada, a compliance review should be your immediate business priority. The Canadian Food Inspection Agency (CFIA) is in the middle of an enforcement push that puts every licensed food facility on the inspection list. Penalties such as licence suspension, product seizure, recalls, and administrative monetary penalties can result from a serious gap.
This article walks you through what the Safe Food for Canadians Regulations (SFCR) require, where compliance gaps most often appear, and what your business can do now to be inspection-ready.
Why Food Safety Compliance is Urgent Right Now
The CFIA’s licence verification campaign —sometimes referred to as the “CFIA licence blitz 2026” — launched in October 2025 and aims to complete risk-based inspections of over 2,400 licensed manufactured food establishments by the fall of 2026. The catalyst was the 2024 Listeria outbreak linked to refrigerated plant-based beverages, which caused 20 confirmed illnesses and three deaths and exposed gaps in CFIA’s earlier risk-based inspection model.
Recent CFIA enforcement actions show how a compliance gap can become a critical issue for your business:
- Deficiencies in Hazard Analysis, Sanitation, and Chemical Risk Management Lead to Licence Cancellation: In April 2026, the CFIA cancelled the licence of a Calgary-based breast milk freeze-drying business after the licence holder failed to correct non-compliances following a March 2025 suspension. The violations involved deficiencies in hazard analysis, sanitation, chemical risk management, equipment maintenance, and validation of storage and transportation practices. No recall was associated with the cancellation, but the CFIA disposed of the seized product.
- Ineffective Preventive Control Plan Triggers Suspension and Recalls: In Ontario, the CFIA suspended a food company’s licence in July 2025 after the licence holder failed to comply with SFCR requirements to implement and maintain an effective preventive control plan (PCP) for hazards. Food recalls were associated with products manufactured by the licence holder. After corrective measures were taken, the licence was reinstated effective November 17, 2025.
These outcomes show why the CFIA has moved away from self-verification for lower-risk establishments. The agency now reviews all new, amended, and renewal applications directly, and inspections can be announced or unannounced. If your facility holds an SFCR licence, it could be inspected at any time as part of this broader compliance effort.
Understanding the SFCR: What It Requires
The SFCR came into force on January 15, 2019, consolidating 14 sets of regulations from four older acts into a single modern framework under the Safe Food for Canadians Act (SFCA). The SFCR apply to many businesses that import, export, or trade food across provincial or territorial borders for commercial purposes. The regulations consolidated federal food safety requirements into a framework focused on licensing, preventive controls, and traceability.
For most food and beverage manufacturers, the SFCR are built around three core pillars:
- Licensing: Your business must hold the correct licence for the activities, commodities, and establishments covered by the regulations.
- Preventive Controls: You must identify food safety hazards and implement controls to prevent, eliminate, or reduce them. Most manufactured-food businesses need a written PCP.
- Traceability: Your business must be able to trace food one step back to the supplier and one step forward to the purchaser.
A PCP is a working document that ties hazard analysis, critical control points, monitoring procedures, corrective actions, and record-keeping together. It builds on the international Hazard Analysis and Critical Control Points (HACCP framework, which underpins most modern food safety systems worldwide. The CFIA has also added chemical hazards, such as pesticides and heavy metals, to its risk calculation, widening the scope of what a PCP needs to address.
What your PCP should cover
At a minimum, your PCP should cover:
- Hazard Identification: Your plan should identify biological, chemical, and physical hazards that may affect your products, ingredients, suppliers, processes, packaging, facility, or distribution model.
- Risk Controls: Explain how your business prevents, eliminates, or reduces those hazards to an acceptable level.
- Monitoring Procedures: Your team should know how controls are monitored, who is responsible for monitoring, how often checks are performed, and what records must be kept.
- Corrective Actions: Your plan should explain what happens when something goes wrong, including who responds, how the issue is documented, how affected products are handled, and how the problem is addressed.
- Record-Keeping: Your records should show that the plan is not only written, but actively followed. If an inspector asks how a control works, your team should be able to support the answer with current, accurate records.
Are You Properly Licensed?
A valid SFCR licence is essential, but it only protects your business if it accurately reflects what your business actually does.
Activities that require a licence include manufacturing, processing, treating, preserving, grading, packaging, and labelling food for export or interprovincial trade. Importing food into Canada and slaughtering food animals are also licensable activities. If your activities, commodities, or establishment details have changed since you were last licensed, you may need to amend your licence information through My CFIA.
Non-compliance can carry serious regulatory and business consequences. The CFIA may issue Administrative Monetary Penalties (AMPs), suspend or cancel your licence, seize product, or trigger a recall.
A licence suspension halts the activities covered by that licence, which can stop production overnight. If the underlying issue is not resolved within 90 days, the CFIA may cancel the licence after notifying the licence holder and providing an opportunity to be heard.
According to the CFIA website, SFCR licences can be suspended for these violations:
- Failure to comply with the SFCA, the Food and Drugs Act (F&DA), and related regulations
- Default of payment of any fee related to the licence
- Risk of injury to the public if the licensed activity continues
Labelling, Allergens, and Traceability
Labelling, allergen control, and traceability are three of the most common areas where compliance gaps surface during CFIA inspections.
- Labelling: Food labelling requirements under the SFCR cover the common name, ingredients list, net quantity, manufacturer or distributor name and address, and country of origin. Labels must match the product’s actual contents, and changes to formulations or suppliers should trigger a label review.
- Allergens: Canadian allergen labelling rules require clear disclosure of priority allergens: peanuts, tree nuts, sesame, milk, eggs, fish, shellfish, soy, wheat, and sulphites. Cross-contact controls in production and packaging should be documented in your PCP and demonstrable in practice.
- Traceability: Your business must be able to trace every product one step back to the supplier and one step forward to the purchaser, with sufficient detail to support a rapid recall if needed. Many food manufacturing operations rely on traceability software or batch-tracking systems to maintain complete, accessible, and easy-to-retrieve records during inspections.
How to Prepare: A Compliance Readiness Checklist
A pre-inspection gap assessment is the most practical way to identify and correct issues before they create regulatory, operational, or financial risk.
- Review Your SFCR Licence Details: Confirm that your licence is active, current, and aligned with your activities, commodities, and establishments. If your operations, product categories, sites, or distribution model have changed, amend your licence information through My CFIA.
- Update Your PCP: Make sure your PCP reflects how your business operates today, including current hazard analysis, monitoring procedures, corrective actions, record-keeping practices, and recall processes. Address biological, chemical, and physical hazards. If you have HACCP certification in Canada, your PCP should integrate cleanly with those systems.
- Test Your Traceability Records: Run a mock trace exercise to confirm you can move every product one step back and one step forward quickly and accurately. Lot codes, supplier records, purchaser records, and inventory data should all be complete, accessible, and retrievable.
- Strengthen Allergen and Labelling Controls: Confirm labels match formulations, priority allergens are properly declared, and cross-contact controls are documented and followed. Have a process for reviewing labels when ingredients, suppliers, or formulations change.
- Train Your Team Before an Inspection: Employees should know their roles, where records are stored, and how to clearly explain food safety procedures. CFIA inspectors look for a working food safety culture, not just paperwork.
- Engage a Qualified Advisor: A pre-inspection gap assessment by an independent advisor often surfaces issues that internal teams have stopped noticing, and fixing them before the CFIA arrives is far less costly than enforcement action afterward.
Final Thoughts: Food Safety Readiness is Also Business Risk Management
Food safety isn’t just about ticking boxes for regulators. It’s about safeguarding your customers, maintaining your licence, nurturing your supply chain relationships, and protecting the business you’ve put so much effort into building.
With increasing CFIA oversight of licensed food manufacturing facilities, your business should treat compliance reviews as an immediate priority, not a last-minute inspection exercise.
Reviewing your licence, updating your PCP, testing traceability, strengthening allergen and labelling controls, and training your team ahead of an inspection will help you respond with confidence.
At Aprio, we work with Canadian food and beverage manufacturers to connect compliance readiness with stronger operations, risk management, systems, and financial planning.
Drawing on decades of advisory experience across our Manufacturing and Distribution and Consumer Products solutions, we help your business assess operational gaps, strengthen internal controls, prepare for inspection readiness, and align food safety obligations with broader business priorities such as ESG reporting and supply chain risk.