When exporting pickles to Canada, the exporter must consider three main categories of requirements: food requirements, importer requirements, and procedure requirements.

First, the food must meet the general food safety requirements like having been manufactured, prepared, stored, packaged, and labelled under sanitary conditions, as per the Safe Food for Canadians Regulations. In addition to the SFCR, the food and drug regulations, section B.11.051 [S], specifies that pickles and relishes shall be the product prepared from vegetables or fruits with salt and vinegar, and may contain spices, seasonings, sugar, food color, a class II preservative, a firming agent, polyoxyethylene (20) sorbitan monooleate in an amount not exceeding 0.05%, lactic acid, vegetable oils and in the case of relish or mustard pickles a thickening agent.

Standards of identity and grades for processed fruit or vegetable products can be found under:

• Canadian Standards of Identity Volume 4, Processed Fruit or Vegetable Products
• Canadian Grade Compendium Volume 3, Processed Fruit or Vegetable Products

When finding an importer, the latter must have a Safe Food for Canadians License to be able to import your products. In order to know if and when the company needs a license, exporters are advised to use the licensing interactive tool. To apply for a license, the importer must sign up with My CFIA and create an account and a business profile. My CFIA will coordinate and process the administrative services that are required for imported foods under the SFCR licensing. Also, the importers must know if their suppliers meet the same level of safety standards as domestic suppliers in preparing, storing, and transporting their food products.

While the SFCR does not specify how the importer can confirm the implementation of preventative controls, some appropriate actions could include an on-site visit to the supplier. The importer must obtain written documentation from the supplier to prove that all control measures are well implemented, including the name, address, contact information of the process authority that developed the process, and a product description with technical information showing that the processing of the product was adequate with the standards set and the preventive controls were in place. Also, the importer should have a written statement, signed by the process authority, attesting that the process produces a product that meets Canadian requirements.

In addition, importers need to write a preventive control plan (PCP), in which they specify how they monitor and verify that the import process is going well, how the food meets requirements for safety, grading, standards, labelling, and net quantity, and how the procedures they have to handle complaints and recalls. To find out when an importer needs to write a PCP, check the preventive control plan interactive tool.

Any food that is imported into Canada must not be contaminated, must be edible, must not consist in whole or in part of any filthy, putrid, disgusting, rotten, decomposed, or diseased animal or vegetable substance, and must have been manufactured, prepared, stored, packaged and labelled under sanitary conditions.

Under food safety standards and guidelines, you can find the requirements set by Health Canada for but not limited to:

• Lists of permitted food additives
• Maximum levels for chemical contaminants in foods
• Maximum residue limits for pesticides

As per the FAO, in terms of contaminants, the products shall comply with the maximum levels of the General Standard for Contaminants and Toxins in Food and Feed (CXS 193-1995). Also, pickles shall comply with the maximum residue limits for pesticides established by the Codex Alimentarius Commission.

To collect specific import conditions and requirements, check the Automated Import Reference System (AIRS). For pickles, specifically cucumbers (HS 200110), the AIRS indicates that importers are responsible for ensuring that the food they import for sale into Canada complies with the requirements of all applicable Canadian legislation including the Safe Food for Canadians Act and Regulations, and the Food and Drugs Act and Regulations. Similarly, it states that the labeling must be in French and English for prepackaged products sold at retail and that the United States “Nutrition Facts information is not permitted and that label claims must comply with the regulations”. In addition, it notes that the food must not contain undeclared food allergen and should be free from contamination of glass particles.

For more information on pesticides, you can check pesticide limits for each commodity used in the process through the query of Health Canada.

The importer or the broker must ensure that the packaging material, being used to ship the product, is properly labelled. In other words, the wood packaging contained should abide by one of the following: it should either “display the ISPM No. 15 compliant stamp”, “[be] accompanied by a Phytosanitary Certificate: approved treatment per ISPM no. 15. " (Please note that phytosanitary certificates are not accepted for wood packaging materials originating from China), “[be] made out of manufactured wood which is exempted from ISPM No. 15.”, or when it applies “[the] wood packaging [should not be] contained with shipment”.

Furthermore, the most common package for pickles in the retail segment is the glass jar with a metal closure, since it preserves the original shape of the product.

According to the Food and Agriculture Organization of the United Nations, the product should fill no less than 90% of the water capacity of the container. A container that fails to meet the minimum fill requirement should be considered “defective”. Moreover, in terms of weight, the drained weight of the product should not be less than 40% of the net weight for Whole and Halves Style. Pieces Style and Other Styles should not be less than 50% of the net weight (except for pickled red cabbage, which should not be less than 45% of the net weight). These percentages are calculated on the basis of the weight of distilled water at 20°C which the sealed container will hold when completely filled. For non-metallic rigid containers such as glass jars, the basis for the determination should be calculated on the weight of distilled water at 20°C which the sealed container will hold when completely filled with less than 20 ml. For more information on the matter, you can check the Standard container sizes –processed fruit or vegetable products of the CFIA.

The Canadian packaging and labeling regulations require that all mandatory information must be shown in English and French.

Labeling requirements:

• Common Name
• Ingredients and Allergens
• Nutrition Facts
• Country of Origin (if required)
• Durable Life Date (if required)
• Food Additives, Fortifications, and Grades (if required)

The Mandatory requirements include:

• Nutrition Facts Table
• List of Ingredients and Common Name
• Net Quantity
• Food Allergens
• Health and Nutrient Content Claims
• Other Claims and Statements
• Bilingual Requirements
• Country of Origin
• Food Additives
• Fortification
• Grades
• Food Specific Labelling Requirements
• Label Information Legibility & Location

The changes applied to the nutrition facts table according to the new law:

The Canadian nutrition facts table has been modified in appearance and content:

• Serving Size
• Percentage daily value calculations
• Percentage daily value for sugar added
• Potassium added
• Vitamins A & C removed
• Amount in mg for potassium, calcium, and iron
• Added footnote about percentage daily values

The changes to the list of ingredients:

• Grouping all sugar ingredients in brackets after the name "Sugar"
• Listing all food coloring by their individual common names
• The text must be black on a white or neutral background
• Updated minimum type height requirements
• Use of bullets or commas to separate ingredients
• Use of both upper- and lower-case letters for the list of ingredients

Sugar in the Nutrition Facts Table

• To add the percentage of the daily value for total sugar

Sugar in the list of ingredients

• To group sugar-based ingredients in descending order by weight

Most pre-packed fresh fruit or vegetables are required to include a lot code or a unique identifier (lot code if it is a consumer pre-packaged food, not packaged at retail), the common name of the food, and the name and principal place of business of the company by or for whom the food was manufactured on the label, which must be applied, attached, or accompanying the food when it is provided to another person. Moreover, general guidance on importing fresh fruits and vegetables is publicly available on the Canadian Food Inspection Agency (CFIA) website.
The term "lot code" is not specifically defined in the SFCR nor in the Safe Food for Canadians Act (SFCA), but it is included in the SFCR: it is a glossary of key terms and would typically be a numeric, alphabetic, or alphanumeric code to identify a lot of products. For the fresh fruit and vegetable industry, the CFIA provides that the following are also permitted to be used as a lot code:

• Harvest date
• Grower identification number
• GPS coordinates
• Growing region*

*when using a growing region as a lot code, it must be sub-national (i.e. country of origin is not acceptable). State/province is acceptable as a growing region.

According to FAO, the producer shall monitor the color, flavor, odor, and texture characteristics of pickled products.

For pickled fruits or vegetables in edible oil, the percentage of oil should not be less than 10% by weight. As for pickled fruits and vegetables in brine or an acidic medium, the percentage of salt in the liquid or the acidity should be sufficient to keep the quality and proper preservation of the product.

The FAO defines the defects in terms of:

• Blemishes: these include, but are not limited to, bruises, scabs, and dark discoloration, which adversely affect the overall appearance of the product.
• Harmless extraneous material: any vegetable part that does not pose any hazard to human health, but affects the overall appearance of the final product.

As such, a container that fails to meet one of the aforementioned requirements is considered defective.

In terms of hygiene, the FAO recommends that the product must be prepared and handled as per the General Principles of Food Hygiene (CXC 1-1969), Code of Hygienic Practice for Low and Acidified Low-Acid Canned Foods (CXC 23-1979), and other relevant Codex texts such as the codes of hygienic practice and codes of practice. In addition, the pickled products must comply with any microbiological criteria established in accordance with the Principles and Guidelines for the Establishment and Application of Microbiological Criteria related to Foods (CXG 21- 1997).

For more information on the specific qualifications for the Canadian market, you can check the Canadian Grade Compendium: Volume 3 –Processed Fruit or Vegetable Products, as well as Chapter 5 – Process Products of the Processed Products Establishment Inspection Manual.

As mentioned earlier under the mandatory requirements, the Safe Food for Canadians Regulations requires the importer to put in place a Preventive Control Plan (PCP), as well as ensure the traceability of the food in the supply chain. One example of the PCP is the Food Safety Enhancement Program that is based on the Hazard Analysis and Critical Control Point (HACCP) principles, which is implemented by meat, dairy, processed fruits and vegetables, shell eggs, processed eggs, honey, and maple food operators as well as hatcheries. The HACCP is an internationally recognized method to identify and manage risks related to food safety. There are several international institutions providing such certificates that ensure food safety across the supply chain.

Compliance with such additional standards will make it easier for pickled products to enter the Canadian market, and help them gain competitive advantages relative to their competitors. Moreover, certifications concerning general quality and food safety management systems from recognized and trustworthy sources demonstrate the supplier’s commitment to high and consistent quality and safety.

Similarly, buyers may ask for a Global Food Safety Initiative (GFSI) recognized certification. As per the government of Alberta, the most adopted certification programs recognized by GFSI in the province are:

• Safe Quality Food
• British Retail Consortium Global Standards
• Food Safety System Certification 22000

You can also check the complete list of GFSI recognized certification programs, for additional information.

Although the various food safety certification systems are based on similar principles, some buyers prefer one specific standard over the other.

To market pickled products as organic in Canada, the product must comply with Part 13 Organic Products of the Safe Food for Canadians Regulations (SFCR). According to the SFCR, any food that is labeled organic is regulated by the Canadian Food Inspection Agency (CFIA). In this context, products that are sold in the country and that either have an organic claim on the label or display the Canada Organic Logo need to comply with Part 13 organic products of the SFCR. The foods should be certified as organic as per the Canadian Organic Standards. The SFCR touches on the Canada Organic Regime, which regulates all bodies and parties that are involved in the certification of organic products. Once certified as per the requirements of the Canada Organic Regime, and having an organic content that is greater or equal to 95%, the Canada Organic Logo can be used. Also, imported products that bear the logo should add the statement “product of” before the name of the country of origin or the statement “imported” close to the logo, in both English and French, with the exception of products that have a bilingual labeling exemption. The CFIA provides a list of certification bodies that are accredited by the latter or recognized under an organic equivalence arrangement with a foreign competent authority under the regulations.

In order to import organic products into Canada, the importer must be able to present a valid certificate when requested, including when importing the products. The certificate should be issued by the certification body, include the name of the product, and accompany each shipment of the product. In addition, importers of organic commodities, for which the import requirements can be found on the Automated Import Reference System (AIRS), have to provide a digital copy of the certificate when stating that they are importing organic products online on the Integrated Import Declaration system.

In addition, the SFCR stipulates that businesses must have their Safe Food for Canadians license before presenting the shipments at the border. In turn, the importer must create a My CFIA account in order to access information about the license or apply for the license. The SFC license number should be submitted along with all other information about the shipment when submitting import information.

PwC’s Consumer insights survey for 2019 indicated that, when it comes to food and non-food purchases, a large portion of Canadian consumers tend to pay a premium to buy products that are organic and ethically or sustainably produced. In addition, they are concerned with excessive packaging and many consumers avoid the usage of plastic when possible. In fact, sustainability has become a new way to conduct business rather than an attractive feature to add. This is pushing producers to conduct a comprehensive life-cycle review of their product. Furthermore, transparency has become critical to proving the sustainable choices the company is taking.

The definition of sustainability varies across a product’s supply chain. Some producers increasingly focus on reducing CO2 emissions, whereas others focus on waste reduction, in the processing of foods as well as in the packaging. Currently, the most famous certification schemes focus on environmental impacts and ethical aspects.

Several sustainability private certifications, standards, audits, and initiatives are already well known. Some focus on social and ethical impacts, such as FairTrade, SMETA, Ethical Trading Initiative, amfori BSCI, BCorp, or Fair for Life. Others focus on a wider range of environmental issues such as Rainforest Allianceor ISO 14000 , while some only deal with CO2 emissions such as Carbon Footprint Certification.

Other entities provide certification schemes that cover a wide range of features, such as the FSCC 22000 Scheme, requiring the ISO 22000, sector-specific pre-requisite programs (ISO/TS standards and BSI PAS), and specific requirements to ensure consistency, integrity, and governance management of the scheme. Also, the IFS International Featured Standardsfocus on food safety and quality management systems, and governance and commitment, among other aspects of transparency and control for hazards. The ISO 26000 Social Responsibility provides guidance for companies committed to social responsibility and sustainability. In addition, SGS supports companies in having processes and systems that comply with quality, health, and safety requirements as well as environmental and social responsibility. You can check a list of ecolabels in Canada on the Ecolabel Index.

According to a survey conducted by Accenture Strategy, 66% of surveyed Canadian consumers are attracted to organizations that treat employees well. As such, purchasers might anticipate suppliers to comply with the codes of conduct regarding social responsibility, which are often based on the ILO labor standards. Some companies require adherence to their code of conduct or one or more of the common standards, such as the Supplier Ethical Data Exchange (SEDEX), Ethical Trading Initiative (ETI), and/or Business Social Compliance Initiative’s (BSCI) code of conduct.

Corporate responsibility initiatives also affect you as a supplier. Common requirements include signing a code of conduct for suppliers, in which you declare that you conduct your business in a responsible manner. More specifically, you declare that you (and your suppliers) observe such measures as respecting local environmental and labor laws and avoiding corruption. These aspects are also investigated further in company audits performed by potential buyers.

Islamic dietary laws (Halal) propose specific restrictions on diets. If you want to focus on the Islamic ethnic niche markets, consider implementing Halal certification schemes.

While cucumbers and vegetables do not contain gluten, malt vinegar adds gluten to the jar. Some consumers prefer to make sure that the product is gluten-free. Thus, you can avoid such products if you’re targeting this specific segment, and you can aim for a gluten-free certification, which is provided by institutions like SGS and SAI Global.