New CFIA Pet Food Export Certificate to Qatar — and What It Means for Importers Who Never Touch the Stuff

CFIA rolled out HA3267 for pet food to Qatar

The Canadian Food Inspection Agency negotiated a new processed pet food export certificate for Qatar. Certificate code HA3267, effective immediately through your local CFIA office. The Guideline for preparing export certificates for the Canadian pet food industry is being updated to reflect what needs to be in the exporter’s declaration.

If you’re exporting pet treats or kibble to Qatar, congratulations. If you’re not — and most of you reading this aren’t — the real takeaway is how this kind of certificate requirement plays out on the import side when you’re sourcing from the U.S., Mexico, or Europe and trying to claim preferential tariff treatment.

Why import brokers care about export certificates they’ll never see

Every time a foreign authority adds a certificate requirement for Canadian exports, it’s a mirror of what we deal with inbound. The CFIA issues phytosanitary certificates, meat inspection certs, and food safety declarations all day long. When those same products come into Canada, CBSA expects the foreign equivalent — and if it’s missing or incomplete, your commercial release gets held until the CFIA clears it at the port or at a sufferance warehouse like FENGYE’s Montreal facility.

The problem is usually timing. CFIA holds are non-negotiable. You can’t RMD your way out of a missing phyto cert. If your U.S. supplier shipped pet food, dairy, or fresh produce without the right USDA or FDA paperwork that CFIA recognizes, you’re sitting in exam until someone produces it or the shipment gets re-exported. That’s not a same-day fix.

I’ve seen this blow up CUSMA claims more than once. Importer assumes the U.S. supplier has their ducks in a row, claims preferential under 98 tariff treatment, then CFIA flags the shipment for missing documentation. CBSA holds release. Importer scrambles. Supplier admits they never bothered with the export side certificate because “we’ve shipped to Canada before.” Yeah, and someone probably paid MFN duty or got lucky with a processing officer who didn’t escalate.

The NRI angle: your supplier’s paperwork is your problem

If you’re importing from a non-resident importer setup — where your U.S. or offshore supplier is the importer of record and you’re just the consignee taking delivery in Canada — their failure to produce CFIA-required certificates becomes your operational headache even if it’s not technically your liability on the B3.

NRI is popular for a reason. The foreign party handles CBSA registration, the bond, the GST account, and the duty payment. But they’re also responsible for presenting admissibility documentation, and if they don’t know Canadian requirements or they cheap out on compliance support, you’re the one sitting at the warehouse with a truck on detention and a customer screaming for product.

This is where the disconnect happens. The NRI thinks their job ends at “we shipped it.” CBSA and CFIA don’t care. If the goods don’t meet import requirements, they don’t release. Period. And if you’re the party paying the freight or the warehousing, you’re eating the cost while the NRI sorts it out — or doesn’t.

CUSMA origin claims and supporting documentation

Here’s the kicker: when you claim CUSMA preferential treatment, you’re certifying that the goods originate in a CUSMA territory and meet the rules of origin for their HS classification. If the goods are subject to CFIA import requirements and you can’t prove admissibility because the exporter didn’t provide the right certificate, CBSA can — and will — deny the tariff preference and assess at MFN rates.

D-Memo D11-4-16 on CUSMA certification requirements is clear: the importer is responsible for substantiation. That includes not just the origin claim itself, but also any regulatory approvals tied to admissibility. If CFIA won’t let the goods in without a cert, and you don’t have it, your origin claim collapses.

This is especially messy with pet food, animal feed, and anything that touches veterinary health or phytosanitary controls. HS chapters 2, 4, 23, and parts of 21 and 22 are all CFIA territory. If you’re bringing in processed pet food under 2309, you better have your ducks in a row on both the tariff classification and the import permit or certificate requirements. We see importers get the HS code right, claim CUSMA, and then get sideways with CFIA because they didn’t realize the product needed an import license or a foreign government cert.

The operational reality

Most of this comes down to communication. If you’re importing anything that even smells like food, feed, or animal product, you need to confirm with your supplier before the shipment moves that they have the export-side documentation CFIA expects on the import side. That means asking for copies of USDA certs, phytosanitary papers, or whatever the foreign authority issued. Don’t assume. Don’t rely on “we’ve done this before.”

If you’re working with a broker who knows the CFIA landscape — and not all of them do, despite what their marketing says — they’ll flag this at the pre-clearance stage and either get the paperwork sorted or tell you to hold the shipment until it’s ready. If you’re filing your own B3s or using a generalist broker who doesn’t ask questions, you’ll find out the hard way when CBSA refers the entry to CFIA and you’re stuck in exam for three days.

We build CFIA doc checks into our pre-clearance workflow for anything in the risk chapters. It’s not optional. If the paperwork isn’t there, we don’t file. That pisses off some clients who want us to “just clear it and we’ll deal with it later,” but there is no later. CFIA doesn’t negotiate.

Why this matters now

The Qatar cert is a footnote for most of you. But the fact that CFIA is still negotiating new certificate frameworks in 2025 is a reminder that import requirements are always shifting. If you’re assuming that the export side of your supply chain is static, you’re wrong. Every time a foreign authority adds a requirement, your Canadian imports are one regulation change away from the same problem in reverse.

If your suppliers are in the U.S. or Mexico and you’re claiming CUSMA, you need to stay on top of this. If you’re NRI and relying on a foreign party to handle Canadian compliance, you need to audit their process. If you’re doing your own brokerage and you’re not checking CFIA requirements on every food or feed entry, you’re rolling dice.

If you want someone to walk through your CFIA exposure on a specific product line or help you tighten up your NRI supplier compliance, we do that all the time. Get in touch.

Source: CSCB