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New And Temporary Import Requirements On Romaine Lettuce

By Pacific Customs Brokers, CFIA Oct 02, 2020

Please see the CFIA News Release: New import requirement: romaine from parts of California must be tested for E. coli. and Import Requirements page: Import requirements for romaine lettuce from the United States for complete details. Following is a recap of the new requirements.

Affected Commodities: Shipments of fresh romaine lettuce and salad mixes containing romaine, sold in bags, bulk or combined with other foods, which originated from the U.S.

New Import Requirements: 

1. Romaine lettuce and products containing romaine from California Salinas Valley Counties of Santa Cruz, Santa Clara, San Benito and Monterey will require:

  • A certificate of analysis (COA) for each lot of product demonstrating that sampling was conducted according to the sampling and testing requirements and the product does not contain detectable levels of E. coli O157:H7.  
    • A separate and unique COA is required for each individual product in a lot.
    • A lot cannot be more than one truckload of product or 20400kg (45000 pounds)
    • Example: A truckload contains 500 cartons of romaine hearts and 50 cartons of bagged salad containing romaine. This would be 2 lots and 2 COAs are required.
  • Product must be held pending approval of the COA from CFIA for sale or distribution.
    • It is possible to let the product transit to Canada while the analysis is performed

Sampling and testing can be conducted either in the USA or in Canada.

2. Romaine and products containing romaine from all other areas of the US will need:

  • A Declaration of Origin on the exporter's official company letterhead which includes:
    • The signature of the exporter
    • The date the letter was signed by the exporter
    • The state and county where the romaine lettuce was harvested

Note: If the Declaration of Origin is not available as COA will be required

Existing Import Requirements for all Leafy Greens:

  • The Importer must have a valid Safe Foods for Canadians Licence for importing produce.
  • Romaine (and other leafy greens) from California must be handled by a member of the California Leafy Green Marketing Agreement (LGMA) 
  • Romaine from Arizona must be handled by a member of the Arizona Leafy Green Marking Agreement (LGMA) 

The details of the new import requirements can be found on CFIA's website: Import requirements for romaine lettuce from the United States

As a valued client of PCB, you receive the benefit of our proactive release process which will ensure your imports are declared with the additional requirements listed above:

  • Upon receipt, our release team ensures all necessary documents that are required for import, are included.
  • If they are missing we will reach out to you, your carrier or your vendor to obtain this paperwork (depending on service package, additional fee may apply)

Please reach out to your account manager with any questions you have about these new requirements at any time by emailing compliance@pcb.ca or calling 604-538-1566. We are here for you always

 

Recent Updates:

 

For Shipments from the Salinas Valley Counties of Santa Cruz, Santa Clara, San Benito and Monterey
 
1) For Shipments where the Certificate Of Analysis (COA) is submitted as part of the customs entry: Once the shipment is released through CFIA and Customs, the importer can sell and distribute the product immediately. They do not need to wait for CFIAs approval, the release at the border is the approval.
 
2) For shipment to be tested in Canada: A form 5078 Conditional Release for Inland Inspection by CFIA will need to be submitted as part of the customs entry. When the product is received by the importer, they will need to hold the product and arrange for testing.  The test results will need to be sent to their local CFIA Area Office for review and approval. Once approval is received they will be able to sell the product.
 
3) If there is no COA available and the conditional release is not submitted, the shipment will be refused entry into Canada by CFIA.
 
For Shipments from Outside the Salinas Valley
 
1) Declaration of Origin clarification: These are shipment specific and the dating on the declaration should be on or near the date of direct shipment to Canada.
 
CFIA has verbally advised that the requirements will be applicable to all shipments crossing the border after the requirements are published in AIRS - even if the shipment is in transit already.