The CanadaGAP Food Safety Manuals v8.0 2020 contain a new requirement for inclusion of Lot Code on market ready packaging materials. The glossary definition of Lot code is as follows:
Lot Code: A code that can be used to identify a lot that was manufactured, prepared, produced, stored, graded, packaged or labelled, under the same conditions. A lot code can be numeric, alphabetic or alphanumeric. Examples of lot code include, production date, best before date, establishment number, or CFIA SFCR licence number. In addition, the lot code may also be the harvest date, grower identification number, growing region or any other code that may be used for traceability purposes. Refer to CFIA’s website for more information on Lot Code https://inspection.gc.ca/food/toolkit-forfood-businesses/glossary-of-key-terms/eng/1430250286859/1430250287405#a104
The requirement for Lot code can be found in Section 17 Packaging Materials, 17.2 Use of Packaging Materials, b) Market Ready Primary Packaging Materials and is as follows:
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- Labelled with Lot Code (see glossary definition)
Note: Refer to CFIA’s website for more information on Lot Code https://inspection.gc.ca/food/toolkitfor-food-businesses/glossary-of-key-terms/eng/1430250286859/1430250287405#a104
This requirement was introduced to the CanadaGAP manuals v8.0 to ensure alignment with the Safe Food for Canadians Regulations (SFCR). To maintain Government Recognition for the CanadaGAP Program, we are required by CFIA to include this requirement for 2020, since the regulations came into full force and effect for the fresh produce industry on January 15, 2020.
However, CFIA has granted a one-year extension before they will enforce compliance with Lot code labelling for consumer prepackaged fresh fruits and vegetables. CFIA has notified the industry that it will not be inspecting to this requirement until January 15, 2021. As such, the CanadaGAP audit checklist will not be introducing this requirement as a scored item on the audit until 2021.
Further communication from CanadaGAP regarding Lot code will follow in the coming months. We anticipate that you will have questions for CanadaGAP about implementing this new requirement; we ask that you reserve your questions until you receive further communication from us.