CFIA Corrective Action Request: Answer It Before Your Licence Is Suspended

A Safe Food for Canadians licence can be suspended for one reason that surprises many food businesses: a missed corrective action deadline, even when no food has been recalled. In October 2026, the Canadian Food Inspection Agency (CFIA) suspended a Montreal food business for exactly that. The company did not fix the problems the CFIA had identified within the period it was given, so the licence was suspended under the Safe Food for Canadians Regulations.

This guide explains what a CFIA corrective action request really is, when the CFIA can suspend your licence, how to answer a corrective action request before the deadline, and what happens if you miss it. The rules here come from the Safe Food for Canadians Act, the Safe Food for Canadians Regulations and the CFIA operational procedure, with section references you can check yourself.

What is a CFIA corrective action request?

A CFIA corrective action request is the written report or Letter of Non-Compliance the CFIA issues when an inspection finds that your operation does not meet the Safe Food for Canadians Regulations. It sets out each non-compliance and the period within which you must take corrective action to avoid suspension of your Safe Food for Canadians licence. In the regulations this document is the written report required by section 36.

The CFIA does not always use the exact phrase corrective action request. The demand usually arrives as a standard inspection report or a Letter of Non-Compliance. Whatever it is called, the legal effect is the same. Under section 36 of the Safe Food for Canadians Regulations, the CFIA cannot suspend your licence unless two things are true: you were given a written report that set out the grounds for suspension and the period to take corrective action, and you failed to take that action within the period. The written report is your warning, and the period is your window.

This is why the corrective action request matters so much. It is not a routine letter to file. It is the step the CFIA must complete before it can suspend you, and your response to it decides whether a finding becomes a suspension. If your food business has open corrective actions, treat them with the same urgency you would give a preventive control plan rebuild.

When can the CFIA suspend your licence?

Under section 35 of the Safe Food for Canadians Regulations, the CFIA may suspend a Safe Food for Canadians licence on three grounds: non-compliance with the Act or the regulations, default on a fee, or a risk of injury to human health. A missed corrective action deadline falls under the first ground, and it does not require a recall or an outbreak.

There is one faster path. Under section 37, if the CFIA is of the opinion that a risk of injury to human health may result, it can suspend the licence immediately after giving you a written report that sets out the grounds, without first giving a corrective action period. For most non-compliances, though, section 36 applies, and you get a written report with a deadline before any suspension.

A real example: a missed deadline, no recall, a suspended licence

On 27 October 2026, the CFIA suspended the Safe Food for Canadians licence of a Montreal food business. The published notice states that the licence holder failed to take corrective actions to comply with three Safe Food for Canadians Regulations requirements within the period granted: the development and implementation of a preventive control plan, sanitation and cleaning procedures, and procedures to prevent the risk of food contamination. The non-compliances were related to Part 4 of the regulations, and the CFIA cited paragraph 35(a).

Two facts stand out. First, the notice states there were no food recalls associated with the suspension. The licence was suspended because corrective actions were not completed on time, not because contaminated food reached the market. Second, while the suspension is in effect the licence holder may not conduct any activity for which the licence was issued, which for a food business usually means operations stop.

How to answer a CFIA corrective action request before the deadline

To answer a corrective action request, read the written report closely, fix the immediate problem, find and correct the root cause, update your preventive control plan where needed, and give the CFIA objective evidence before the deadline. The goal is to close every cited non-compliance within the period you were given, and to prove it. The steps below put that into practice.

1. Read the written report in detail. List every cited non-compliance, the exact Safe Food for Canadians Regulations or Act section behind it, and the deadline. Do not rely on memory of the verbal debrief. The written report is what the CFIA will measure you against.
2. Confirm your understanding with the inspector. If a finding or a deadline is unclear, ask. A short clarifying conversation early is better than a misread requirement discovered after the deadline.
3. Correct the immediate problem first. Stop the unsafe practice, clean the area, segregate affected product and apply an interim control. This is the correction, and it buys you safety while you work on the deeper fix.
4. Do a root cause analysis for each finding. A finding of poor sanitation is a symptom. Ask why the sanitation failed: was the procedure missing, not followed, not trained, or not resourced? A strong CAPA process separates correction from true corrective action.
5. Build a corrective action plan with owners and dates. For each non-compliance, record the correction, the corrective action that fixes the root cause, the preventive action that stops recurrence, the person responsible, and the completion date. This is the document you will act from and later submit.
6. Update your preventive control plan and SOPs. Where a finding is systemic, change the written preventive control plan, the sanitation standard operating procedures and the monitoring records, not just the one occurrence. The CFIA wants to see that the system changed.
7. Collect objective evidence as you go. Keep dated records: revised SOPs, training sign-offs, cleaning logs, test results, photographs and monitoring data. Evidence is what turns a claim of corrective action into proof of it.
8. Submit your evidence before the deadline, and request an extension in writing if you genuinely need one. The regulations allow a longer period on the licence holder's written request. Ask before the deadline passes, not after, and explain why the extra time is reasonable.
9. Prepare for the verification inspection. The CFIA confirms your corrective actions through an inspection. Make your records easy to find and your staff ready to show the new controls in practice.

What happens if you miss the deadline

If you do not take corrective action within the period, the CFIA may suspend the licence. You will receive written notice of the suspension and its effective date. While the suspension is in effect you cannot carry out the licensed activities, and the suspension stays in force until the CFIA determines that corrective action has been taken. The table maps the stages and their sections.

Getting a suspension lifted is not automatic. Under section 38, the suspension must be lifted once the Minister determines that corrective action has been taken, which in practice means you notify the CFIA that the actions are complete and the CFIA inspects to verify compliance. Clean records and a genuinely fixed system are what move that decision forward.

The 90 day cliff: when a suspension becomes a cancellation

A suspension is serious, but it is still recoverable. A cancellation is far harder to come back from. Under section 39 of the Safe Food for Canadians Regulations, the CFIA may cancel a licence if the licence holder fails to take corrective action within 90 days after the day the licence was suspended, unless the Minister grants a longer period on the holder's written request.

Section 39 lists other cancellation grounds too: continuing to conduct a licensed activity while suspended, a conviction under the Act or the Food and Drugs Act, repeat non-compliance after earlier suspensions, and non-compliance with section 15 of the Act. Before cancelling, section 40 requires the CFIA to notify you of the grounds and give you an opportunity to be heard. That opportunity is a last chance, and it is far weaker than simply meeting your corrective action deadline in the first place.

Corrective action response checklist

Use this checklist the moment a written report or Letter of Non-Compliance arrives.

• Log every cited non-compliance, its Safe Food for Canadians Regulations or Act section, and its deadline
• Confirm any unclear finding or deadline with your inspector in writing
• Apply an immediate correction and interim control for each finding
• Complete a root cause analysis for every non-compliance
• Build a corrective action plan with correction, corrective action, preventive action, owner and date for each item
• Update the written preventive control plan, SOPs and monitoring records where findings are systemic
• Collect dated objective evidence: revised SOPs, training records, cleaning logs, test results and photographs
• Submit your evidence to the CFIA before the deadline
• Request a longer period in writing before the deadline if you genuinely cannot finish in time
• Prepare records and staff for the CFIA verification inspection
• If suspended, count 90 days from the suspension date and track every action against it

Common mistakes to avoid

• Treating the report as routine paperwork. The written report is the legal step before suspension. Missing its deadline is a ground for suspension on its own.
• Fixing the symptom, not the cause. Cleaning the room without fixing why it was dirty invites a repeat finding, and repeat non-compliance is a cancellation ground.
• No objective evidence. Saying corrective action was taken is not enough. The CFIA verifies by inspection, so keep dated records that prove it.
• Asking for more time too late. The regulations allow a longer period on written request, but ask before the deadline, not after it has passed.
• Operating while suspended. Conducting a licensed activity during a suspension is a separate ground for cancellation under section 39.
• Ignoring the preventive control plan. If your preventive control plan was part of the finding, update the written plan, not just the practice on the floor.

Frequently asked questions

What is a CFIA corrective action request?

It is the written report or Letter of Non-Compliance the CFIA issues when an inspection finds non-compliance with the Safe Food for Canadians Regulations. It sets out the problems and the period within which you must take corrective action to avoid suspension. In the regulations it is the written report required by section 36.

How long do I have to respond to a CFIA corrective action request?

There is no single fixed number of days in the regulations. The period is set in the written report itself, based on the nature and risk of the non-compliance. Read the report for your exact deadline, and if you need more time, request it in writing before the deadline passes.

Can the CFIA suspend my licence without a recall?

Yes. Under paragraph 35(a) of the Safe Food for Canadians Regulations, a licence can be suspended for non-compliance alone. A missed corrective action deadline is enough, and no recall or outbreak is required. The October 2026 Montreal suspension is a clear example.

What happens to my business during a suspension?

While a licence is suspended, you may not conduct any activity the licence covers, which usually means your regulated operations stop. The suspension stays in force until the CFIA determines that corrective action has been taken, confirmed by a verification inspection.

How is a CFIA licence suspension lifted?

Under section 38 of the regulations, the suspension must be lifted once the Minister determines that corrective action has been taken. In practice you notify the CFIA that the actions are complete and the CFIA inspects to verify compliance before lifting the suspension.

When can the CFIA cancel my licence?

Under section 39, the CFIA may cancel a licence if corrective action is not taken within 90 days after the suspension, unless a longer period is granted on written request, and on other grounds such as operating while suspended or repeat non-compliance. Section 40 requires notice of the grounds and an opportunity to be heard first.

How MFLRC can help

A corrective action request is a time limited test of your food safety system, and the clock is already running when it arrives. MF License and Regulatory Consultants (MFLRC) helps food businesses respond to CFIA findings before they become suspensions. Our team brings more than twenty years of quality assurance and regulatory experience across food, pharmaceuticals, natural health products and cannabis.

We can support you with a rapid review of your CFIA written report and deadlines; root cause analysis and a defensible corrective action plan; preventive control plan rebuilds and sanitation SOPs; evidence packages for the CFIA verification inspection; and, where a suspension has already happened, a reinstatement plan to lift it before the 90 day cancellation window closes. We also run mock inspections so findings are caught by us, not by the CFIA. Review your wider obligations in the Q4 2026 regulatory deadline calendar.

Conclusion

A CFIA corrective action request is the warning before a suspension, and your response to it is what decides the outcome. The Safe Food for Canadians Regulations are clear: the CFIA must give you a written report with a deadline before it suspends you under section 36, it must lift a suspension once corrective action is taken under section 38, and it may cancel a licence if corrective action is not completed within 90 days under section 39. Every one of those steps turns on whether you fixed the problem and proved it in time.

The October 2026 Montreal suspension shows that a missed deadline alone, with no recall, is enough to stop a food business. The practical answer is to treat every corrective action request as a priority, fix the root cause, keep the evidence, and meet the deadline. Do that, and a finding stays a finding instead of becoming a suspension.

Sources and references

• Safe Food for Canadians Regulations (SOR/2018-108), section 35 and following, Justice Laws Website
• Safe Food for Canadians Act (S.C. 2012, c. 24), Justice Laws Website
• CFIA, Operational procedure: suspending and lifting the suspension of a Safe Food for Canadians licence
• CFIA, Safe Food for Canadians licence suspension notice, Maison Si Bon Inc.
• CFIA, Regulatory requirements: licensing of food businesses