Please note that this is not a change in policy, but clarification of an existing policy. For more details, the Terrestrial Animal Products and By-products Import Policy Framework discusses trans-shipments in Section 8 (General Import Requirements).
CFIA Clarification
Trans-shipment means a movement of commodities from the country of origin to a country of destination, where the container enclosing the goods passes through an intermediate country. The shipment is customs cleared in the intermediate country, the container is opened, the original seal is broken, the contents are removed and a portion (or potentially all) of the original cargo is then shipped from the intermediate country to the country of destination.
For situations where a shipment travels from the country of origin directly to Canada, the requirements for importing animal products and by-products to Canada are outlined in the Automated Import Reference System (AIRS).
For trans-shipment of the following low-risk commodities through the US only, an import permit is not required. Instead, 2 zoosanitary certificates (one from the country of origin and one from the US) are required.
- Milk and milk products
- Eggs and egg products
- Highly processed products from non-bovine species (gelatin, collagen, vitamins of animal origin, hormones, peptones)
- Highly processed products originating from bovine bones or hides and skins where the country of origin poses a negligible risk of BSE
- Integumentary tissues (hides and skins, feathers, hooves, horns, antlers)
- Fertilizers containing processed manure but no rendered materials
For trans-shipment of commodities not listed above through the US, and for trans-shipments through all other countries, an import permit is required.
Example Scenario 1: Trans-shipment with Canada as the final destination
The product is made in one country (for example, Mexico), shipped to an intermediate country (for example, the United States), where the shipment leaves official government control and clears customs, then part or all of the shipment is sent to Canada without further treatment in the United States. Certification will be required from the country of origin (Mexico) attesting that the product meets Canadian requirements, as well as from the intermediate country (US) attesting that the product has not been altered or cross-contaminated during the trans-shipment. The import permit will give the required wording for the zoosanitary certificates from each country.
Example Scenario 2: Treatment or processing occurs in an intermediate country
The product is made in one country (for example, India) but undergoes treatment or processing in another country (for example, Germany) that changes the animal health status of the product (such as heat treatment, irradiation or chemical disinfection). The product is then considered a product of Germany, and the requirements in AIRS for Germany would apply as though the product was shipped directly to Canada from Germany.
Cutting, packaging or repackaging are not considered treatment or processing for the purpose of trans-shipment.
We hope that this helps to clarify the import requirements for animal products and by-products. If you have any questions, your local CFIA office should always be your first point of contact.
New from the CFIA – Automatic Licence Verification for Manufactured Food Imports
The Canadian Food Inspection Agency (CFIA) has issued a Food Import notice to inform importers that on February 12, 2024, the CFIA will activate the automatic verification of Safe Food for Canadians (SFC) licences for imports of manufactured foods. Food import transactions will be automatically rejected unless a valid SFC licence is declared.
The CFIA has also updated its guidance on Importing food with a valid Safe Food for Canadians licence. If you import food into Canada, refer to this guidance for more information on automatic licence verification and the steps you can take to make sure your SFC licence is valid. Holding a valid SFC licence before you submit your import declaration will help to prevent your food shipment from being delayed at the border.
If you have questions about applying for or amending an SFC licence, visit the CFIA’s Food Licences page. Refer to Food imports for more information on food import requirements.
Questions? Please reach out to our team if you need any clarification!