CFIA Closes Entry for Chinese Fish Pet Treats Under Chapter 23

What Changed

CFIA published Chapter 23 updates on August 4, 2026, moving two HS codes from “Refer to CFIA-NISC” to “Refuse entry” for goods originating from China. The affected codes are 23.09.10.1575.17 and 23.09.90.1574.17, both covering piscine, crustacean, or mollusc treats made of rendered ingredients like fish meal, fish oil, or fish hydrolysate.

The change applies to three end-use categories: “Other end uses,” “Samples for testing,” and “Show or Exhibition.” Most commercial importers fall under “Other end uses.” If you’re bringing in fish-based dog or cat treats from China under Chapter 23, your next shipment will be refused at the border, not held for inspection.

Refused Entry vs Referral to NISC

The difference matters. Under the old “Refer to CFIA-NISC” instruction, CBSA would release the shipment to a licensed sufferance warehouse pending CFIA inspection and clearance. You paid storage, but you had a path to release if the goods passed inspection or if CFIA granted a waiver.

Under “Refuse entry,” CBSA will not release the goods. The shipment sits in a sufferance facility under CBSA control. Your options are re-export to origin, voluntary destruction, or — if you can make a case that the classification or origin declaration was wrong — re-file the CAD under a different code or country. Most importers choose re-export. Destruction fees and drayage to a CFIA-approved disposal site run higher than the cost of sending the container back.

Refused entry also triggers an F-code (refusal flag) in CARM that follows the importer’s BN15 and the supplier’s foreign vendor record. Repeat refusals under the same HS code pattern can elevate your risk score and pull more of your shipments into exam queues going forward.

Check Your HS Classification Now

If you’re importing pet treats from any origin, verify your current HS classification. The two codes above are narrow: they cover rendered fish ingredients (meal, oil, hydrolysate). If your treats are whole fish jerky or freeze-dried fish fillets, you’re likely under a different code in 23.09 or even Chapter 16 (prepared fish). If your treats are poultry- or beef-based, you’re not in scope.

But if your supplier’s commercial invoice lists “fish meal” or “fish protein” as a primary ingredient and your goods originate from China, your broker should have filed under one of these two codes. Pull your last three CADs and check the HS code field. If you see 23.09.10.1575.17 or 23.09.90.1574.17, and the country of origin is CN, your next shipment will be refused.

CFIA’s Automated Import Reference System (AIRS) drives the release logic at the border. When your CAD hits CBSA’s customs clearance system, the HS code, origin, and end-use combination automatically routes to AIRS for a release recommendation. CBSA officers follow that recommendation. There is no discretion at the booth. If AIRS says refuse, CBSA refuses.

What to Do Before Your Next Shipment

If you have goods in transit, contact your customs broker before the container arrives. You have three options:

1. Verify country of origin. If the finished treats were manufactured in Vietnam, Thailand, or another country using Chinese fish meal as an input, the country of origin for customs purposes is the country of last substantial transformation. If your supplier can document that the treats were cooked, formed, and packaged outside China, the origin is not CN, and the refusal instruction does not apply. Your broker will need a manufacturer’s declaration, production records, and possibly a certificate of origin. Get those documents before the shipment lands.

2. Re-classify if the code is wrong. If your treats do not contain rendered fish ingredients, the HS code is wrong. File a corrected CAD under the right code before CBSA processes the release. This requires a detailed ingredient breakdown and possibly a CFIA opinion on product composition. Do not guess. A wrong code that gets flagged in a post-release audit costs more than the delay to get it right the first time.

3. Stop the shipment or re-route. If the code and origin are correct, and you cannot re-classify, do not let the container enter Canada. Arrange re-export from the foreign port or divert to a U.S. consignee if you have a related entity that can receive and re-sell the goods there. Refused entry in Canada means you pay drayage to the sufferance warehouse, sufferance storage until CBSA authorizes re-export, and outbound drayage back to the port. That is three moves and two storage legs. Re-routing before entry is cheaper.

Why CFIA Tightened This Now

CFIA has been tightening controls on pet food imports from China for the past two years, mostly in response to contamination incidents and labeling fraud in the feed ingredient supply chain. Rendered fish ingredients have been a recurring issue. Fish meal imported for aquaculture feed and pet food has tested positive for prohibited antibiotics, undeclared additives, and species substitution.

The shift from referral to refusal means CFIA no longer wants these goods entering the Canadian control zone at all. The risk threshold has moved. CFIA is treating these two codes as presumptively non-compliant when the origin is China, regardless of the importer’s history or the specific supplier.

If you import pet treats from China under other HS codes in Chapter 23, expect similar tightening over the next twelve months. CFIA updates AIRS on a rolling basis. The August 4 update is Chapter 23 only, but the pattern is clear.

Filing and Compliance Workflow

Your broker should be checking AIRS release recommendations as part of the pre-clearance review. If you use a freight forwarder that also handles customs, make sure they are running the HS-origin-end-use combination through AIRS before filing the CAD. A refused-entry notice after the fact is a planning failure, not a regulatory surprise.

If you are filing your own CADs as a registered importer, you have access to AIRS through the CFIA import portal. Run the query before you hit submit. The system will return the release recommendation. If it says refuse, stop and fix the issue before CBSA sees the declaration.

Storage and Re-Export Costs

A 40-foot container of refused pet treats will sit in sufferance storage at the port-adjacent warehouse. Montreal sufferance rates run around CAD 18 to CAD 25 per day for a 40-foot unit, depending on the facility and the season. CBSA’s refusal authorization process takes five to ten business days if there are no documentation issues. You are looking at CAD 200 to CAD 300 in storage before you can move the container back to the port for re-export.

Drayage from sufferance to the container terminal is another CAD 400 to CAD 600 in the Montreal market. Add the ocean carrier’s re-export documentation fee and the cost of repositioning the container back to China. Total landed cost of refusal is CAD 2,500 to CAD 4,000 per container, assuming no demurrage at the terminal and no penalty from your customer for late or non-delivery.

If you are bringing in pet treats on a regular cadence, one refused container wipes out the margin on the next three. Get the classification and origin documentation right before the goods ship.

We file CADs against CFIA-controlled codes daily. If your current HS classification is anywhere in Chapter 23 and your origin is China, run the AIRS check now. Get in touch.

Source: CSCB