Food Supply Chain & Trade

Import, export, and the regulatory relationships that move food across borders and through the supply chain.

Food businesses operate inside supply chains, not in isolation. The legal issues that arise in these relationships are partly regulatory and partly commercial, and the two interact. Regulatory requirements apply to food moving across borders or through the supply chain, and enforcement consequences follow when those requirements are not met.

Importing into Canada

Importing food into Canada generally requires an SFCR import licence and brings the importer under federal preventive-control obligations from the moment product crosses the border. CFIA and CBSA both engage at port of entry, and the response window when a shipment is held is short. Most border holds turn on documentation that should have been arranged before the shipment was scheduled, not after. See Importing Food into Canada for border holds, CFIA/CBSA roles, and response options, and SFCA Licensing for licence scope, preventive control plans, and pre-licence inspection.

Canadian Market Entry

Market entry analysis happens before the first shipment. The questions are different from those that come up once product is moving: which entity carries the SFCR licence, how the label has to change to comply with Canadian rules, whether the product or any of its ingredients triggers novel food, supplemented food, or compositional-standard requirements, and how Quebec's language rules affect the launch geography. Companies that work through this before launch avoid the label rebuilds, sticker overlays, and classification disputes that catch newcomers who treat Canada as an extension of the US market. See Canadian Food Market Entry for SFCA licensing scoping, label redesign, and cross-border compliance.

Exporting from Canada

Exporting requires CFIA export certification, and the domestic compliance record affects CFIA's willingness to certify. Export readiness rests on that record; destination-market requirements often reach back to the Canadian exporter through their own verification regimes. See Exporting Food from Canada for CFIA certification and foreign regulatory reach-back.

Co-Packing and Contract Manufacturing

Co-packing relationships involve shared regulatory obligations. Under the SFCR, both the brand owner and the co-packer may carry licensing and preventive control requirements. When something goes wrong, the regulatory exposure follows the facts, not the contract. Each party's PCP must reflect the regulatory role it actually plays; CFIA's allocation of responsibility follows the facts on the ground, not the title in the contract. See Co-packing and Contract Manufacturing for regulatory role allocation and agreement structure.

Food Fraud and Supply Chain Integrity

Food fraud is a growing enforcement priority for CFIA and an increasing source of commercial disputes. Country-of-origin misrepresentation, species substitution, and adulteration create regulatory exposure for companies throughout the supply chain, not just the party that committed the fraud. Supply chain verification, supplier audit frameworks, and response strategies become operating requirements once enforcement risk extends to companies upstream of the fraud.

How We Work

Our supply chain practice is generally hands-on regulatory work. The questions are practical: what does CFIA expect of an importer's PCP, what does co-packing liability look like during a recall, what does a food fraud investigation mean for the companies upstream. We bring enforcement experience to those questions.

Last updated: March 2026. This page is maintained by GSJ&Co. and updated when there are material changes to the relevant regulatory framework.