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View Full Version : Two Industry Regulations Asking For Opposite Standards


Mauri
2nd November 2009, 08:14 AM
I have a rather interesting dilema on my hands. I just went through an inspection with CFIA (Canadian Food Inspection Agency) and was given a CAR for a claim on a label.
A month ago I went through an inspection from CFIA for EU export and that inspector requested that I have the above mentioned claim on my label.
The claim that I have on my label is that the product we are selling meets all of the requirements for feeding to livesock for meat export to the EU.
Under the Department of Justice website http://laws.justice.gc.ca/eng/SOR-83-593/page-8.html section 28 (c) states that I can't use that claim.

I have yet to hear back from the Exporting side of the agency as to the exact EU Directive that asks for the claim.
Is anyone familiar with the EU Directive that would contain this information?

I am planning on appealingthe CAR and hopefully get some resolution to the issue.

Anyone else have similar labeling issues between two different countries or agencies, and how do you work around it?

mmantunes
2nd November 2009, 08:29 AM
Iīm not of the food industry, but reading what you pointed out, it seems to me that your claim of compliance to a EU regulatory requirements (a high-level requirement) has nothing to do with the requirement of 28 (c) (which is a technical, low level requirement). Different regulatory systems usually do not have high level problems (but this might happen).

I do not understand why your compliance claim would be some kind of non-conformance (i think thatīs what a CAR is).

Mauri
2nd November 2009, 08:37 AM
You are correct, 28 (c) is a low level (Type B) violation. There is no feed or food safety at risk. All it is is a non compliance on labelling, which I am required to have on for EU export.
One side says I have to have it on, the other side says I can't. :confused: