Clearit.ca's Blog on Customs Brokerage and News Updates
Last time, in our continuing series on agricultural importing, we looked at the requirements needed to bring livestock across the Canada – USA border. Today, we’re going to focus on goods that are a wee bit smaller in stature — two things, in fact, that are vital to the livelihoods of Canadian farmers and ranchers, and which carry their own set of regulations.
We’re, of course, talking about livestock feed and seeds (more specifically, the combined trio of crop, small packet, and commercial seeds).
During the 2016–17 crop year, imports of grains and oilseeds (wheat, barley, oats, etc.) in Canada totalled 1,619 kilotonnes, but that number skyrocketed to 2,428 kt in just the span of a year (as of September 17, 2018), and is projected to remain in the same ballpark going into 2018–19.
While both seeds and livestock feed have their own particularities in terms of importation guidelines, each set of rules is administered and regulated largely by the Canadian Food Inspection Agency (CFIA). Here’s what you need to know:
Regulations on Crop, Small Packet, and Commercial Seeds
There are many types of legislation that apply to the importation of seeds into Canada related to pesticide usage, plant protection and more — to ensure the basics are covered, however, overall compliance with the Seeds Act and Seed Regulations is what you should be aiming for.
First things first, your seed order will require three things:
- A signed Import Declaration Form (CFIA/ACIA 4560) that indicates the following information: seed species name; total seed weight; the seed’s lot designation; the exporter’s name and address, as well as your own name, address and telephone number; the seed’s country of origin; and the seed’s intended purpose.
- A Request for Documentation Review (CFIA/ACIA 5272), mandated by Import Service Centres and Canada Border Service Agencies.
- An acceptable seed analysis certificate, which provides information on purity and germination to show that your seed meets the minimum standards to cross into Canada.
While the Government of Canada goes out of its way to mention that the Seeds Act and Seed Regulations must be adhered to at all times, there are grounds for exemption from submitting all or some these documents, however:
- If your order contains less than a certain amount of seed (5 kg or less for large-seeded crops like wheat and corn, 500g for small-seeded crops like tomatoes or canola);
- If your seed is being imported for conditioning (cleaning, packaging, etc.);
- If your seed is being imported for research purposes;
- Herb, flower, tree, shrub and aquatic plants don’t require import declaration or seed analysis, only a documentation review.
In regards to fees, large- and small-seeded crops, outlined in the above bullet point, are considered “small shipments” and, therefore, require no extra payment. Also, if you pay yearly to be an Authorized Importer, fees don’t apply to you either. The only people required to pay are non-Authorized Importers, to the tune of $15 CDN on orders of 1,500 kg or less, and $0.01 per kg on shipments of more than 1,500 kg.
Regulations on Livestock Feed
According to the CFIA, under the Feeds Act and Feed Regulations, livestock feed imported into Canada must meet two important criteria:
- The first is, understandably, safety. All imported feeds need to be suitable not just for livestock consumption, but also without risk for inadvertent exposure to humans (e.g. residue in farmed foods like meat, milk and eggs, or through potential exposure to farm workers) or the environment.
- Secondly, imported livestock feed must serve one or more of the purposes outlined in the CFIA’s Feed Regulations (Schedules IV and V). The extensive list details 32 total categories divided into four parts (more on that in a moment) made up of dozens of different grains, proteins, minerals and more. Each entry explicitly defines eligible ingredients and, in most cases, what their intended purpose should be.
Those are the big ones. However, in special circumstances, approval from other CFIA branches or governmental agencies might be required, or your imports might be subject to other acts.
Example 1: If your farm uses organic feed, imports will be subject to additional requirements outlined by the Canada Organic Regime.
Example 2: If your feed contains medicinal ingredients to treat your livestock, it must be registered directly with the CFIA’s Animal Feed Division and will likely need to meet the necessary requirements laid out in the Food and Drugs Act.
Once you’ve determined if your imported feed meets the criteria, the other key step is registering it — or, just as important, knowing if it’s exempt from registration.
Going back to our Feed Regulations list for a moment, as promised, there is a reason why Schedules IV and V are each divided into two parts.
Since Schedule V covers flavouring ingredients rather than feed, let’s focus on Schedule IV. Everything contained in Part I are products already approved for importation and use in Canada, meaning they’re exempt from the registration process. Part II, however, contains all ingredients recognized by the CFIA that must be backed by info or data to ensure safety and efficacy.
Finally, you’ll need to consider which category your livestock feed fits into, in order to know if product registration is necessary. Single Ingredient Feeds (SIF) are straightforward, as they simply need to be placed in either Part I or II of Schedule IV to know whether or not to register. Similarly, new ingredients not previously listed in Schedule IV or V will be subject to scrutiny.
Where you have to work a little harder is with mixed feed and specialty feed. Mixed, as you might imagine, requires each separate ingredient in the mix to be registered or exempted individually. Same goes for speciality feeds, considered “anything acting as an additive or providing a specific function” (e.g. antioxidants, buffer feeds, pellet binders, etc.)
Things to Consider
- Do you have all of your required documentation in order?
- How much seed are you important and are you prepared for fees?
- Which categories do your livestock feed import fall into, and have you met the correct regulations?
- Have you ensured the reliability of your seed and feed sources?
It’s a lot to remember, and we’re here to help. Contact a customs broker today and we’ll help you get the seed and livestock feed you need into Canada!