CFIA Drops Import Permit for Fish Oil

The Canadian Food Inspection Agency pulled the animal health import permit requirement for fish oil last week. If you import fish oil for aquaculture feed, pet food ingredients, or nutraceutical use, that’s one fewer OGD hold in your release flow.

What Changed

CFIA updated the Automated Import Reference System to remove the animal health import permit from fish oil shipments. The old regime required a permit regardless of end use. Now you classify the shipment under one of two simplified end-use categories when filing the CAD:

Livestock feed covers fish oil used as an ingredient in livestock feed, including finfish, molluscs, and crustaceans produced for aquaculture and raised for human consumption. The Feeds Regulations, 2024 still apply here.

Other end uses covers everything else: human consumption products, cosmetics, industrial applications, nutraceuticals.

The distinction matters because the livestock feed category still triggers Feeds Regulations compliance, but the permit step is gone from both paths.

Why It Matters for Release

OGD permit requirements sit on the critical path for PARS and RMD releases. A missing or delayed CFIA permit holds the entire shipment at the border until the permit clears. Fish oil importers have been carrying that risk on every load.

Dropping the permit requirement means:

• No pre-import permit application to CFIA
• No permit number to declare on the CAD
• One fewer document for your broker to validate before filing
• Faster release for compliant shipments

For high-frequency importers bringing in fish oil weekly or monthly, the compounding time savings add up. A two-day permit delay on every second shipment becomes zero.

AIRS Update and CAD Filing

CFIA updated AIRS to reflect the new requirements. Your broker codes the end-use category on the CAD based on your commodity description and intended use. If you’re importing fish oil for aquaculture feed production, that’s the livestock feed category. If it’s going into omega-3 capsules or cosmetic formulations, that’s other end uses.

The end-use declaration on the CAD determines which regulatory requirements apply downstream. Livestock feed use still triggers Feeds Regulations 2024 compliance, including registration, labeling, and safety standards. The permit is gone, but the substantive feed safety rules aren’t.

If your supplier or importer of record has been declaring fish oil under a livestock feed end use, review your compliance posture. The permit removal doesn’t waive those requirements.

What Stays the Same

This is a documentation change, not a deregulation of fish oil as a commodity. CBSA still examines fish oil shipments on risk-select. CFIA still has authority to inspect and detain shipments that pose animal health or feed safety risks under the Feeds Regulations.

The tariff classification hasn’t changed. Fish oil typically lands under HS 1504 (fats and oils of fish or marine mammals), with the six-digit and eight-digit CCN breakdown depending on species and processing. Classification drives your duty rate and CUSMA origin eligibility if you’re claiming preference on a North American supply chain.

If you import fish oil from a non-CUSMA origin and you’ve been claiming a tariff preference under CETA or CPTPP, the permit change doesn’t affect origin verification. Your certificate of origin, supplier declaration, and origin worksheet still need to support the claim.

OGD Coordination in Practice

Fish oil sits at the intersection of CFIA (feed safety, animal health) and Health Canada (if it’s a natural health product or food ingredient for human consumption). The permit removal simplifies the CFIA side, but if your fish oil is also an NHP or a food product, Health Canada’s requirements run parallel.

A typical scenario: you import bulk fish oil for encapsulation into omega-3 supplements sold in Canada. CFIA’s permit requirement is gone (other end uses category). But if the finished product is an NHP, you still need a product license from Health Canada, and your import may trigger an NHP site license check depending on how the product enters commerce.

Your broker doesn’t apply for Health Canada licenses, but we do flag OGD holds when they appear in AIRS and coordinate release once you’ve cleared the requirements. The fish oil permit removal takes one variable out of that coordination, which is a cleaner process for everyone.

Practical Impact for Aquaculture Feed Importers

If you’re bringing in fish oil as a feed ingredient for aquaculture operations, this is a straightforward win. Aquaculture feed supply chains in Canada run tight schedules. Salmon, trout, and shellfish feeding cycles don’t wait for delayed permits.

The livestock feed category under the new AIRS structure explicitly includes finfish, molluscs, and crustaceans produced for aquaculture and raised for human consumption. That’s the majority of Canadian aquaculture. You’re still subject to Feeds Regulations 2024, which means your feed ingredient supplier needs to meet registration and safety standards, but the import permit step is out of the release flow.

For operations importing fish oil in bulk through the Port of Montreal and warehousing it at a sufferance facility before blending into feed rations, the permit removal tightens the inbound dwell time. One fewer document to hold for before CBSA releases the goods.

Next Steps

If you import fish oil regularly, notify your broker that CFIA updated AIRS and confirm which end-use category applies to your shipments. If you’ve been attaching a CFIA animal health permit to your CAD filings, that document is no longer required as of the AIRS update.

Review your commodity coding and HS classification while you’re at it. Fish oil classification can split depending on species, refining level, and whether it’s crude or processed. A misclassification on HS 1504 can trigger a duty overpayment or an incorrect origin claim, and those issues sit independent of the CFIA permit change.

The CFIA’s official guidance on AIRS updates is the authoritative source. If your shipment profile includes other animal products or feed ingredients beyond fish oil, check whether other OGD requirements shifted in the same update cycle.

Most importers won’t notice this change unless they import fish oil. If you do, it’s a cleaner release process starting now. We file CADs against the updated AIRS daily. Get in touch if you want to walk through how the end-use categories apply to your specific shipments.

Source: CSCB