Food > Import 

March 24, 2000

TO: IMPORTERS OF SOY SAUCES AND OYSTER SAUCES

SUBJECT: IMPORTATION OF SOY SAUCES AND OYSTER SAUCES

As a follow up to our trade letter of December, 1999 be advised that effective April 1, 2000 oriental style soy sauces and oyster flavoured sauces are expected to comply, with the 3-MCPD provisional guideline of 1.0 ppm established by Health Canada. Please keep in mind that Health Canada also indicated that the provisional guideline may be lowered in future.

Canadian Food Inspection Agency (CFIA) is offering the opportunity for compliant product to enter Canada without detention by placing Importers on an exemption list. To be placed on the list, an Importer is required to provide acceptable assurance their product complies by having upon CFIA request:

• Supplier Certificate of Analysis for each product and lot number; or
• Supplier letter of guarantee to confirm that product is in compliance with the current provisional guideline; or
• Test results by an acceptable Canadian laboratory for each product (list attached).

Note: Documentation pertaining to each product is to include manufacturer’s name, address, brand name, style or flavour, bottle size, lot number, country of origin, testing lab name and address.

Importers placed on the exemption list will be subject to random shipment audit by CFIA. Importers found with non compliant product, will be removed from the exemption list. Product previously passed and distributed may also be subject to compliance action, including product recall. If removed from the exemption list, an Importer would be required to provide satisfactory test documentation for the next four shipments.

Importers not interested in the exemption process, or testing of product at their own expense, should appreciate that shipment(s) will be detained pending testing by CFIA. Volume of testing required by CFIA is difficult to estimate so possible length of detention time is not known and is an issue to be considered when deciding whether to use Private Laboratory Services.

For your convenience, sampling instructions, names of Laboratories found acceptable to CFIA and a questionnaire in use by CFIA to develop and maintain the exemption list are attached (#’s I & III). If CFIA has not called you, consider contacting your Regional CFIA Inspection Manager at your convenience to arrange completion of the questionnaire.

Yours Truly,

Inspection Manager
Region
(Phone Number)

Canadian Food Inspection Agency
Area and Regional Offices

Attachment I

Sampling Instruction:

Each sample is to consist of a minimum of 3 bottles from each brand / flavour or style and a single code. The bottles are to be taken from different cases. Note: If all bottles are taken from the same case, the results may not compare favourably to government audit samples. The laboratory will analyse a composite sample obtained from the three bottles.

Laboratory Services Determined Acceptable to CFIA:

Attachment II

Attachment III

MCPD Importer Control Survey (March 2nd)

Questions and Answers (circle appropriate response and explain when necessary)

1. Does your firm expect to continue importation of soy, and/or oyster sauce?

   Yes / No    (if No, little need to proceed to questions below)

2. Is your firm aware of the 1.0 ppm provisional guideline for MCPD in soy and oyster sauces?

   Yes / No

3. Briefly indicate how Importer product will comply with the provisional guideline:
   1. letter of guarantee from the supplier
   2. certificates of analysis from the supplier
   3. private laboratory testing of product upon arrival to Canada
   4. all of the above
   5. none
4.  Based on the phone interview findings with the Importer, do you recommend soy and/or oyster product for this Importer be exempt from the border lookout process?

   Yes / No