CFIA's New Animal Products Import Policy: What Changed and Why Your Broker Needs to Care About Product Codes Now

The old policy is gone, and the new one isn’t just cosmetic

CFIA pulled the old Terrestrial Animal Products and By-products Import Policy off the shelf last week and replaced it with a final version that’s now live on inspection.canada.ca. If you move meat, poultry, dairy, egg products, pet food, hides, wool, hunting trophies, rendered products, honey, or lab samples, this isn’t a tweak — it’s a rewrite with real teeth on product coding, zoosanitary certificate requirements, and case-by-case adjudication.

The timing matters. We’re eighteen months into CARM, and CBSA’s release logic already leans harder on partner government department (PGD) holds than it ever did under the old B3 world. CFIA is a PGD. When they tighten up their import policy, that tightening shows up as a release block at the border before you ever get to pay duties or file the CAD. Your broker can have a perfect HS classification and a clean RPP account, and you’re still sitting in sufferance because the zoosanitary cert is missing a product code that didn’t matter six months ago.

Product coding is no longer a suggestion

The new policy expands and formalizes the product coding framework. CFIA’s been moving toward structured product identifiers for years, but the old policy left enough wiggle room that you could often get away with a generic description on the zoosanitary certificate if the exporting country’s competent authority didn’t have a granular coding system. That’s over.

Now, the product code on the zoo cert needs to map cleanly to CFIA’s import reference database, and if it doesn’t, the shipment gets flagged for manual review. Manual review means delay. Sometimes it’s a same-day email clearance if your importer of record has a history and the product is low-risk. Sometimes it’s a multi-day back-and-forth with the Area Program Specialist, and you’re paying warehouse and drayage while it sits.

This hits hardest on pet food and chews, rendered products, and anything dual-use that straddles Chapter 2, 5, or 23. If you’re bringing in beef tallow (HS 1502) for industrial use, CFIA still wants to know species, country of origin, and processing method. If the cert says “animal fat” and stops there, expect a request for amendment or a letter of attestation from the supplier. The amendment route burns a week minimum if the exporting country’s vet authority is slow.

Zoosanitary certificate validation is stricter

The new policy clarifies that CFIA will validate zoosanitary certificates against the model certificates negotiated with each exporting country. If the cert deviates from the model — even in ways that seem minor, like an extra attestation or a missing signature block — it’s technically non-compliant.

In practice, CFIA has some tolerance for formatting differences, but they’re tightening up on substantive omissions. If the model cert requires an attestation that the product is free from African swine fever and your cert is silent on ASF, that’s a hard stop. You can’t fix it at the border. The exporter has to reissue or provide a supplementary letter, and CFIA has to accept it, which they often won’t if it’s not on official letterhead with the competent authority’s stamp.

This is where your compliance process upstream matters more than your broker’s speed at the border. If you’re onboarding a new supplier or switching origin countries under CUSMA or CPTPP, you need to validate the zoo cert template before the first shipment moves. CFIA publishes model certificates for most trading partners, but they’re not always easy to find, and some countries have multiple models depending on product category. We’ve seen more rejected certs in the last six months than in the prior two years combined, and most of them trace back to suppliers who didn’t know Canada’s model cert requirements.

Case-by-case handling is now formalized

The updated policy dedicates real ink to case-by-case assessments, which used to be an informal fallback when a product didn’t fit neatly into a standing import policy. Now it’s a documented process with criteria, timelines, and a clear escalation path.

If you’re importing something novel — say, insect-based pet food from a country that doesn’t have a bilateral arrangement with Canada, or a hunting trophy from a species not explicitly listed in the policy — you can request a case-by-case evaluation. CFIA will assess the zoosanitary risk, and if they approve, they’ll issue an import permit with conditions. The timeline is officially 60 business days, but that’s best-case. If they need more data from the exporting country’s vet authority, add another month.

The practical takeaway: if your supply chain includes anything even slightly novel, get CFIA’s sign-off before you commit to a purchase order. Don’t assume that because a product is permitted from Country A, it’s automatically permitted from Country B with the same documentation. CFIA’s risk assessments are country-specific and disease-status-dependent, and the new policy makes that explicit.

What this means for your release workflow

CFIA holds trigger a PGD block in the CBSA system, which means your shipment won’t release under PARS, RMD, or any other stream until the block is lifted. Your broker can’t override it. The cargo sits in a sufferance warehouse — ours or someone else’s — accruing storage and handling until CFIA clears it.

If you’re moving animal products regularly, build some buffer into your lead times and make sure your broker has standing instructions on how to escalate CFIA issues. Not every hold needs a phone call, but if the shipment includes perishables or you’re up against a retail window, escalation needs to happen within hours, not days.

Also worth noting: CFIA permit requirements haven’t changed under the new policy, but the validation logic has. If you’ve been reusing the same general import permit for multiple product subcategories, double-check that the permit language still covers everything. CFIA’s becoming more literal in how they interpret permit scope, and a permit that worked fine last year might not clear a similar shipment today if the product code or zoo cert has shifted.

HS classification still matters, especially at the margin

The new policy doesn’t change HS rules, but it does create more scenarios where a borderline classification decision has downstream CFIA consequences. If you’re classifying a pet chew as 2309 (prepared animal feed) vs. 0511 (animal products not elsewhere specified), the CFIA requirements diverge sharply. Same product, different paperwork, different risk profile.

If you’re unsure, get a ruling or at least run it through a structured classification review before the first import. CFIA won’t accept “close enough” if the product code doesn’t match the tariff classification, and CBSA won’t let you amend the CAD after the fact if it changes the PGD determination.

If you’re filing CADs on animal products and haven’t revisited your CFIA documentation workflow since the new policy dropped, now’s the time. The margin for error just got narrower, and the cost of getting it wrong is sitting in sufferance for a week waiting on a reissued zoo cert. Get in touch if you want us to walk your current process and flag the gaps.

Source: CSCB