CFIA Just Added Organic Registration Gates to Six Dried Legume Codes

What Changed

CFIA published Chapter 07 updates to AIRS on July 8, adding mandatory registration requirements to six HS codes—all organic dried legumes destined for human consumption. If you’ve been importing organic peas, chickpeas, black gram, or mung beans and clearing them as bulk or retail-packaged grain, you now need an AIRS registration number on file before CBSA will release the shipment.

The affected codes:

• 07.13.10.1100 and 07.13.10.7200 (organic peas, bulk and packaged)
• 07.13.20.1100 and 07.13.20.7200 (organic chickpeas, bulk and packaged)
• 07.13.31.1100 and 07.13.31.1101 (organic black gram and mung beans, bulk)

These were commodity grain codes before. They’re OGD-gated codes now. The registration requirement only applies when end use is declared as human consumption—feed-grade organic legumes under the same HS aren’t caught yet, though I’d expect CFIA to circle back.

Why This Matters at Release

When your customs broker files the CAD, the CARM system pushes the HS code, AIRS registration number, and end-use declaration to CFIA’s back-end validation. If the code is on the AIRS Chapter 07 registration list and you don’t have a valid registration linked, the shipment goes to OGD hold. CBSA won’t issue RMD or release prior to payment until CFIA clears it through AIRS.

This isn’t a sampling hold or a random inspection. It’s a hard gate. No registration number = no release, regardless of how clean your compliance history is or whether the container physically looks fine sitting on the terminal.

The validation happens at filing, not at the port. So if you’re used to same-day release on organic bulk grains because “it’s just dried peas,” that stops now. Budget two to three working days if you’re caught without registration when the container shows up. Longer if CFIA’s AIRS processing queue is backed up, which it routinely is in Q3 and Q4 when harvest volume moves.

What You Need to Do Before the Next Shipment

1. Check your import history. Pull your last six months of CADs and filter for any of the six codes above. If you’re bringing in organic dried legumes—bulk totes for repackaging, retail bags for distribution, or ingredient-grade for food manufacturing—you’re in scope.

2. Register the product with CFIA. This is done through the AIRS portal. You’ll need the product description, HS classification, intended use, and your Safe Food for Canadians license number if you’re repackaging or further processing in Canada. CFIA’s current processing time for new AIRS registrations is running eight to twelve business days, so don’t wait until the container’s in transit.

3. Give your broker the registration number. Once CFIA issues the AIRS registration, send it to whoever files your CADs. It goes in the CFIA product registration field on the CAD—your broker can’t guess it, and “pending” doesn’t clear the hold.

4. Update your commercial invoices and packing lists. If you’re importing multiple SKUs under the same HS code—say, bulk organic chickpeas and retail-packaged organic chickpeas on one container—each line needs its own AIRS registration. The more granular your documentation, the less likely you are to get caught in a CFIA data-mismatch hold later.

The Broader AIRS Pattern

This update follows CFIA’s slow march toward full product-level registration for anything entering the food supply. Fresh produce, meat, dairy, and seafood have been AIRS-gated for years. Dried legumes were a gap—treated as low-risk commodity bulk—and CFIA just closed it for the organic subset.

The registration requirement is narrow right now (organic only, human consumption only), but expect it to expand. CFIA has been clear in D-memo updates and importer bulletins that their long-term plan is registration at the tariff line level for all food imports. Conventional dried peas and chickpeas will probably be next, followed by other Chapter 07 and Chapter 08 codes that currently clear without AIRS checks.

If you’re an NRI (non-resident importer) bringing organic legumes into Canada for a Canadian buyer, make sure the registration is in the Canadian party’s name. CFIA won’t issue AIRS registrations to foreign entities, and the OGD hold logic checks for a valid Canadian business number linked to the registration. This catches a lot of cross-border e-commerce and Amazon FBA shipments—the US seller files as importer of record, CBSA sees the HS code, CFIA sees no valid registration, and the container sits until someone with a Canadian BN steps in.

Cost and Timing

AIRS registration itself is free. The cost is in the delay if you don’t have it when the shipment arrives. Two to three days of container dwell at the port, plus any demurrage or per-diem charges your freight contract passes through, plus the downstream schedule slip if you’re feeding a production line or retail replenishment cycle.

For organic bulk imports moving through Montreal, where most of Canada’s pulses and legumes clear, typical dwell cost is in the CAD 150–250 per day range depending on whether you’re at Contrecoeur or the Racine Terminal and whether the container needs reefer power. Add another day if the hold triggers on a Friday afternoon and CFIA doesn’t staff AIRS reviews on weekends. If your shipment is temperature-sensitive or you’re running JIT replenishment into a warehouse cross-dock window, three days of unplanned dwell is enough to break the entire inbound plan.

The smarter move: register once, use it for every shipment under that HS code going forward, and avoid the hold entirely.

If your shipment’s already in transit and you just found out about this, call your broker now. CFIA can expedite AIRS registration in some cases if you escalate through the Safe Food for Canadians helpdesk, but “the container arrives tomorrow” is not a compelling reason for expedite treatment. Get ahead of it.

We handle CFIA compliance and OGD coordination as part of standard clearance. If you’re not sure whether your organic legume SKUs need registration or you want someone to walk through the AIRS filing, come talk to us.

Source: CSCB