CFIA SFCR – Canada Food Traceability

This topic is part of the SG Systems Global regulatory & operations glossary.

Updated October 2025 • Canadian Food Inspection Agency (CFIA), Safe Food for Canadians Regulations (SFCR), KDE/CTE Traceability • Food, Beverage, Ingredients, Imports/Exports

CFIA’s Safe Food for Canadians Regulations (SFCR) require food businesses to maintain accurate, timely, and retrievable traceability records across the supply chain. At minimum, you must know one step back (from whom you received a food) and one step forward (to whom you provided a food), while associating identities with Key Data Elements (KDEs) at Critical Tracking Events (CTEs) like receiving, transformation, and shipping. SFCR connects to preventive controls, import licensing, labeling, and recall readiness, so your master data, labeling, WMS, and execution records must work in lockstep—and be audit‑ready on demand.

“SFCR traceability isn’t a binder—it’s living data: lots, dates, and identities flowing end‑to‑end and provable in minutes, not days.”

1) Scope—Who Is In and Why It Matters

SFCR traceability applies across manufacturing/processing, importing, exporting, warehousing, distribution, co‑manufacture, and private‑label arrangements. Even where specific carve‑outs exist, customer programs and brand protection make SFCR‑level controls table stakes. If you receive, transform, or ship lots, assume obligations exist and align your labels, master data, picking, and record retention accordingly. Harmonizing with U.S. practice (FSMA 204 KDE/CTE) reduces cross‑border friction.

2) KDEs & CTEs—The Minimum Data That Rebuilds History

At minimum, capture identifiers and dates that reconstruct product movement. A practical KDE set aligned with global practice (and compatible with U.S. FSMA) includes:

• Receiving (CTE): supplier identity, purchase doc, date/time, product identity (e.g., GS1 GTIN / description), lot/batch, quantity/UOM, condition checks, storage location, country of origin.
• Transformation (CTE): work order/job release, input lots+quantities, yields & yield variances, process dates/shifts, new product identities and output lots, line clearance evidence.
• Shipping (CTE): customer identity, ship doc, ship date/time, product identities+lots, quantities, SSCC case/pallet links, carrier and BOL.

Cold chain? Tie in temperature mapping and EM; store exceptions with Deviation/CAPA dispositions.

3) Identity, Labels & Machine‑Readable Data—Don’t Lose the Thread

Traceability fails without consistent identity. Use GTIN for items, lot/batch (AI 10), date (AI 17), and quantities. Print scannable labels at receiving, WIP, and finished goods using controlled templates under Document Control. Validate barcodes with label verification. For variable weight foods, pair identity with catch‑weight and net content logic (TNE).

Measure barcode quality (print contrast, modulation, defects). Enforce scanner verification at key gates (goods receipt, line clearance, shipping). Store images or verifier summaries with the lot record when customers demand proof of label integrity.

4) Transformation & Mass Balance—Proving Genealogy

Demonstrate lot in, lot out. Link consumed input lots to produced finished lots and reconcile a mass balance with yield evidence. Capture scrap, rework (controlled reprocessing), and obsolescence so quantities add up. If you claim volume but control by weight, maintain density factors and ensure labels pull executed net (gravimetric).

5) Warehousing, FEFO & Shipping—Identity Through the Dock

Maintain FEFO/FIFO allocation, directed picking, and dynamic lot allocation. Prevent shipping from Quarantine/Hold until QA disposition. Build case/pallet hierarchies with serialization; exchange data via ASN and EPCIS.

For DSD (direct‑store delivery) and cross‑dock flows, pre‑build SSCC hierarchies and require scan confirmation at each hand‑off. Capture exceptions (short, over, damage) with reason codes tied to lots and cases.

6) Imports & Exports—License, Records & Equivalence

Importers must maintain traceability back to the foreign supplier and forward to Canadian customers. Align KDEs with invoices, customs docs, and, where used, ASN. For exports, preserve the same chain with transport docs (BOL) and country‑specific claims. Keep country of issuance and origin clear to avoid relabeling errors. When suppliers follow U.S. FSMA 204 only, map their KDEs into your SFCR set and fill gaps at receiving (internal relabeling, data enrichment).

7) Recall Readiness—Time to Isolate Affected Lots

Expect to quickly identify affected lots, isolate inventory, notify partners, and provide distribution lists. Operationalize with mock recalls, recall readiness KPIs, and RCA. If evidence lives in ad‑hoc spreadsheets, you’ll lose hours when minutes matter. Use system queries filtering by lot/date to output manifests and customer lists instantly. Tie the recall script to approval workflows and messaging templates so legal, QA, and sales communicate consistently.

8) Allergen, Hazard & Label Controls—Prevent the Expensive Recall

Traceability intersects hazard management. Segregate priority allergens, enforce line clearance, and validate label content to avoid undeclared‑allergen recalls. Link labeling control to master data and shipping docs. Keep SOPs and QMS governance visible and integrated with internal audits.

9) Data Integrity—Electronic Proof That Stands Up

Implement unique users and role‑based access, time‑stamped audit trails, and controlled master data. Tie scale readings, scanner events, and label prints to device IDs and calibration status. Avoid shadow spreadsheets; execute in validated systems and preserve the retention trail. Align with ALCOA+ (ALCOA).

10) Implementation Roadmap—From Gap to Audit‑Ready

1. Inventory Processes & Products. Map CTEs by SKU family; mark cold chain, allergens, and high‑risk partners.
2. Harmonize Master Data. Normalize names, pack sizes, GTINs, and unit conversions (UOM). Version under Document Control.
3. Label Control. Lock templates; embed GTIN/lot/date rules; add SSCC for logistics.
4. Systemize Capture. Configure directed picking, Pack & Ship, and device integrations (load cells, scanners, printers).
5. Train & Gate. Use a Training Matrix; block ship if scan/label checks fail (hard‑gating).
6. Mock Recall & KPIs. Prove time‑to‑list; publish KPIs and trend.
7. Periodic Review. Re‑assess risks, suppliers, and cold‑chain validation each season; update training and SOPs; handle MOC.

11) Examples by Segment—What “Good” Looks Like (+ Edge Cases)

Meat & Poultry: lot identity at primal; case build with SSCC; FEFO pick; temperature exceptions logged with disposition. Cross‑link to HACCP and the plant Food Safety Plan. Edge case: combo bins split across orders—use sub‑lotting to preserve genealogy.

Dairy: tank loting by intake; pasteurizer runs as transformation CTEs; mass balance across cream/skim by‑products; label date rules enforced. Edge case: rework of cream into ice cream—track as transformation with new lot and reason code.

Produce: field/packinghouse lots; cooling CTE; EPCIS events to retailers; FEFO allocation. Edge case: commingled totes—block unless upstream lots meet identical specs and record commingle rules.

Bakery: allergen segregation, baker’s % and hydration controls, line clearance, catch‑weight at slicing/pack. Edge case: topping substitutions—treat as change with label review.

Ingredients/Flavours: micro‑lot blending with micro‑dosing; potency declarations; rework tracked as transformation with reason codes; COA linked to lots.

12) How This Fits with V5 by SG Systems Global

Lot Genealogy by Design. The V5 platform captures KDEs at each CTE: goods receipt, transformation, and shipping. Input lots, work orders, and output lots form complete genealogy.

Labeling & GS1. V5 controls templates, prints GS1, validates readability; supports case/pallet serialization and data exchange via ASN/EPCIS.

Warehouse Execution. Directed put‑away and picking; Hold status interlocks; FEFO allocation by default. Pack & Ship enforces scan checks to prevent identity drift.

Recall Speed. Lot‑pivot queries output distribution lists and quantities in seconds for notices, withdrawals, or recalls. Approval workflows route communications.

13) KPIs & Governance—Proving Control

• Mock Recall Time: minutes to complete distribution list (target: single‑digit minutes).
• Scan Compliance: % ship lines with verified scans (target: >99%).
• Label Verification Pass Rate: print/data conformance.
• Mass Balance Closure: % batches reconciled including scrap/rework.
• Allergen Incident Rate: trend toward zero undeclared events.
• Audit‑Trail Review Coverage: % high‑risk objects reviewed on schedule.
• ASN/EPCIS Match Rate: % of shipments with matching partner receipts.

14) Common Pitfalls & How to Avoid Them

• Handwritten logs. Paper fails retrieval speed and integrity—systemise capture.
• Uncontrolled relabeling. Treat as a controlled process; link to source lot and reason codes.
• Partial genealogy. Capture WIP rework/by‑products or mass balance won’t close.
• Broken cold chain. Bind temperatures to lot moves; store exceptions with dispositions.
• Spreadsheet sprawl. Replace with platform workflows or validate under V&V.
• Loose supplier data. Require GTIN/lot/date from vendors; relabel at receipt when needed and map identities.
• Identity drift between systems. Use ISA‑95 patterns; enforce canonical IDs.

15) Quick‑Start Checklist

• Confirm master data for GTIN, lot, and date rules; align templates under Document Control.
• Enable lot capture at receiving; generate internal labels for items lacking GS1.
• Link work orders to consumed inputs and produced outputs; reconcile yields.
• Turn on scan verification at picking/shipping; block ship on read errors.
• Schedule a mock recall; time the run and fix bottlenecks.
• Measure KPIs weekly; publish and review.

16) Extended FAQ

Q1. Do we need serialization for every item?
Not always. SFCR emphasizes lot‑level traceability. Case/pallet serialization (SSCC) speeds distribution mapping and recalls.

Q2. How long must we keep records?
Follow product‑specific retention aligned to shelf life and risk. Conservative posture: maintain accessible electronic traceability beyond minimums; execute controlled archival with periodic integrity checks.

Q3. What if suppliers don’t send GS1 data?
Relabel at receipt with internal labels tied to the supplier’s lot; map identities so partners still receive usable KDEs.

Q4. How fast should a mock recall be?
Target minutes. If you’re in hours, eliminate manual steps, centralize data, and test routinely.

Q5. Does SFCR align with U.S. FSMA 204?
Yes on principles (KDEs/CTEs); specifics differ. Building to global best practice reduces cross‑border friction.

Q6. What about bilingual labeling (EN/FR)?
Traceability relies on identifiers (GTIN, lot, dates) that are language‑agnostic. Ensure templates support bilingual text while preserving machine‑readable data rules.

Q7. Are distributors/3PLs in scope?
Yes—if they receive/ship lots. They must preserve identity and produce distribution lists on demand. Integrate their scans via ASN or portal capture.

Q8. How do we handle rework or relabel?
Treat as transformation: reference original lots, create new output lot(s), explain reason codes, and update label templates under Change Control.

Q9. What’s the smallest viable data model?
Core entities: Item (GTIN/description), Lot (lot/date/status), Location (site/zone/bin), Event (CTE with who/when/where), Label (template/version/print), and Shipment (SSCC/consignment). Each Event ties Item+Lot+Location with timestamps and actor ID.

Q10. How do we validate scanners/scales?
Qualify devices under IQ/OQ/PQ; maintain calibration status and periodic verification SOPs. Block data on failed checks.

Related Reading
• Traceability Core: End‑to‑End Lot Genealogy | KDE & CTE | Mass Balance
• Identity & Labels: GS1 GTIN | Label Verification | SSCC
• Warehouse & Shipping: FEFO | Directed Picking | ASN | EPCIS
• Governance & Records: Document Control | Record Retention | Audit Trail | Recall Readiness