CFIA Is Inspecting 2,400 Food Facilities by Fall 2026: Is Your Preventive Control Plan Ready?

If you hold a Safe Food for Canadians (SFC) licence and have never had a Canadian Food Inspection Agency (CFIA) inspector walk your floor, that is about to change. The CFIA is conducting risk-based inspections of more than 2,400 licensed manufactured-food establishments that have never been inspected, with the work scheduled for completion by fall 2026. Many of these licence-holders have a written Preventive Control Plan (PCP) that was built once to obtain a licence and has not been opened since. That gap is now a serious compliance risk.

This article explains what the inspection blitz is, why the CFIA launched it, how preventive control expectations have changed to include chemical hazards and food safety culture, and the practical steps food manufacturers and importers should take before an inspector arrives.

What is the CFIA doing, and why now?

In response to recommendations from its Inspector General, the CFIA published an action plan to strengthen oversight of the manufactured-food sector. The headline measure is a national inspection push: the agency will carry out risk-based inspections of over 2,400 establishments that hold an SFC licence but have not yet been inspected. The work was initiated in summer 2025 and is scheduled for completion by fall 2026.

The manufactured-food sector was only brought under the Safe Food for Canadians Regulations (SFCR) in 2022, and the CFIA's early approach focused on compliance promotion rather than enforcement. That grace period is ending. The agency has stated it is now moving toward stronger enforcement of the rules.

The six-point action plan at a glance

The outbreak that triggered the crackdown

The action plan did not appear in a vacuum. It follows a deadly listeriosis outbreak linked to plant-based beverages sold under the Silk and Great Value brands. The contamination was traced to a dedicated production line at a third-party packaging facility in Pickering, Ontario. The outbreak caused 20 confirmed illnesses, 15 hospitalizations, and three deaths, with cases reported across Ontario, Quebec, Nova Scotia and Alberta.

Reporting and the Inspector General's review highlighted a structural weakness: the facility had effectively been deprioritized in the CFIA's risk algorithm and had gone years without an on-site inspection. The episode exposed how a licensed site can slip through risk-based scheduling, and it is the direct reason the CFIA is now physically visiting establishments that the model had never flagged for inspection.

How preventive control expectations have changed

Beyond the inspection numbers, the CFIA is changing what it expects a compliant operation to look like. Three shifts stand out for food manufacturers and importers.

1. Chemical hazards now count

Historically, the CFIA's risk models leaned heavily on biological hazards such as Salmonella and E. coli. The agency is now folding chemical hazards, for example pesticides and heavy metals, into its risk calculations. For your PCP, this means your hazard analysis cannot stop at microbiological risk. Allergens, gluten and added sulphites are also chemical hazards that must be considered when you identify hazards and determine critical control points.

2. Food safety culture must be demonstrated

Food safety culture has moved from a nice-to-have to an expectation the CFIA looks for. As of October 2025, all new, amended and renewal licence applications are reviewed to confirm that information is complete, hazards have been identified, a PCP is in place where required, and a food safety culture is demonstrated by the applicant. In practice, culture is evidenced through management commitment, training records, clear accountability, and staff who understand why controls exist, not just that they exist.

3. Complaints and trend data feed the risk model

The CFIA has expanded the criteria for how it uses complaints information, including data that signals potential food safety concerns and historical or trend patterns. Internally, your own complaint logs, deviations and trend analysis are exactly the records an inspector will expect you to keep, review and act on. Treat complaint handling and trending as part of your PCP, not as an afterthought.

The table below summarizes how the inputs to the CFIA's risk picture have broadened.

Do you need a Preventive Control Plan, and what must it contain?

Under Part 4 of the SFCR, most SFC licence-holders who manufacture, process, treat, preserve, grade, package, label, store or import food must prepare, keep, maintain and implement a written PCP. A written PCP documents how hazards to your food are identified and prevented, eliminated or reduced to an acceptable level, and it also covers packaging, labelling, grading and standards of identity where they apply.

Some small businesses in certain sectors may be exempt from the written-plan requirement, but they must still meet the underlying preventive control requirements in Divisions 2 to 5 of Part 4. An exemption from writing a plan is not an exemption from controlling hazards. Importantly, the CFIA does not approve PCPs. Inspectors verify that you hold documented evidence your control measures are effective and meet the SFCR.

The core elements inspectors expect to see

• Hazard analysis: identification of biological, chemical and physical hazards relevant to your products and processes.
• Evidence a control measure is effective: scientific or technical support showing each control achieves its intended outcome.
• Critical control points and critical limits: the steps where control is essential, with measurable limits.
• Monitoring procedures: what is checked, how often, by whom, and how it is recorded.
• Corrective action procedures: what happens when a limit is exceeded or a control fails.
• Verification procedures: activities that confirm the plan is working as intended, such as record review and testing.
• Record keeping: complete, contemporaneous records that demonstrate the plan is implemented in daily operations.

Enforcement is shifting from education to action

The CFIA has been explicit that it is moving toward stronger enforcement of the SFCR. The tools it can use when it finds non-compliance include detention of product, refusal of entry for imports, licence suspension and cancellation, and Administrative Monetary Penalties (AMPs). For a licence-holder, a suspended or cancelled licence is an existential event: it can halt your ability to manufacture, sell interprovincially, import or export overnight.

The Notice to Industry on manufactured-food inspections is direct on this point. Licence-holders are responsible for implementing preventive controls, holding a written PCP where required, keeping it up to date and actively using it, and ensuring the licence reflects current business activities, commodities and establishments. Failing to meet these obligations could result in enforcement, including suspension or cancellation of the licence.

What to expect during a CFIA inspection

A CFIA inspection of a manufactured-food establishment is a structured verification of whether your preventive controls work in practice, not just on paper. Inspectors review documentation, observe operations, and look for objective evidence that your controls are implemented and effective. Knowing the rhythm of a visit helps you prepare your team and your records.

• Opening and scope: the inspector confirms the activities, commodities and establishments on your licence and explains the focus of the visit.
• Document review: your PCP, hazard analysis, monitoring records, corrective actions, verification activities and complaint logs are examined for completeness and currency.
• Facility walk-through: sanitation, pest control, equipment, employee hygiene, storage and the condition of the establishment are observed against what your records claim.
• Sampling, where applicable: product or environmental samples may be taken to confirm controls are effective, particularly for pathogens such as Listeria monocytogenes.
• Findings and follow-up: the inspector communicates any non-compliance, sets expectations for corrective action, and determines whether enforcement is warranted.

The single most common reason a first inspection goes badly is a mismatch between the written plan and the floor. If your procedures describe a control you no longer perform, or your records are completed from memory at the end of a shift rather than in real time, those gaps will be visible. Aligning documentation with daily practice is the most valuable preparation you can do.

Inspection-readiness checklist

Use this checklist to gauge whether your operation is ready for a CFIA visit. If you cannot answer yes to each item with supporting records, you have a gap to close.

• Your written PCP exists, is current, and reflects your actual products, processes and establishment.
• Your hazard analysis covers biological, chemical (including pesticides, heavy metals, allergens, sulphites) and physical hazards.
• Critical control points and critical limits are defined and scientifically supported.
• Monitoring, corrective action and verification procedures are documented and followed.
• Records are complete, contemporaneous and retrievable for the required retention period.
• Your SFC licence accurately lists your current activities, commodities and establishments.
• You have submitted complete and accurate Additional Establishment Information, now a mandatory licensing condition.
• Complaints, deviations and trends are logged, reviewed and actioned.
• Food safety culture is evidenced through management commitment, training records and clear accountability.
• Staff can explain the controls they perform and why they matter.
• You have run a mock inspection or gap assessment against the SFCR within the past 12 months.

Common mistakes the inspection blitz will expose

Across food-safety inspections, the same weaknesses appear repeatedly. These are the issues most likely to surface when an uninspected site is visited for the first time.

• The shelf PCP: a written plan created to obtain the licence that is out of date and not used in daily operations.
• Biological-only hazard analysis: no consideration of chemical hazards such as heavy metals, pesticides, allergens or sulphites.
• Records that do not match practice: procedures describe one thing while the floor does another, or monitoring records are completed after the fact.
• Outdated licence scope: new products, processes or establishments that were never added to the SFC licence.
• Weak corrective actions: deviations are recorded but root cause and effective CAPA are missing.
• No demonstrated food safety culture: training is informal, accountability is unclear, and management commitment is not evidenced.
• Ignored complaints: customer complaints are not trended or connected to the PCP.

Frequently asked questions

How many food facilities is the CFIA inspecting, and by when?

The CFIA is conducting risk-based inspections of more than 2,400 manufactured-food establishments that are licensed but have not yet been inspected. The work began in summer 2025 and is scheduled for completion by fall 2026.

Why is the CFIA doing this now?

The push follows an Inspector General review prompted by a deadly listeriosis outbreak linked to plant-based beverages. The review found that some licensed sites had been deprioritized in the CFIA's risk algorithm and never inspected, so the agency is now visiting establishments the model had not flagged.

My site has a licence but has never been inspected. Am I a target?

Quite possibly. The blitz specifically targets establishments that hold an SFC licence but have never been inspected. If that describes your site, you should assume an inspection is coming and confirm your PCP and records are current.

What new expectations apply to my Preventive Control Plan?

Your hazard analysis should now address chemical hazards such as pesticides, heavy metals, allergens and sulphites, not only biological hazards. You should also be able to demonstrate a food safety culture and show that complaints and trends feed into your controls.

What happens if I fail an inspection?

Depending on the severity, the CFIA can require corrective action, detain product, refuse entry for imports, issue Administrative Monetary Penalties, or suspend or cancel your licence. Enforcement is increasing as the agency moves beyond its earlier compliance-promotion focus.

Does the CFIA approve my PCP?

No. The CFIA does not approve PCPs. Inspectors verify that you hold documented evidence your control measures are effective and meet the requirements of the SFCR.

How MFLRC can help you get inspection-ready

MF License & Regulatory Consultants (MFLRC) helps food manufacturers and importers move from a paper PCP to a defensible, operational food safety system before the CFIA arrives. Our consultants bring more than 20 years of quality assurance and regulatory experience across food, pharmaceuticals, natural health products and cannabis, and we build practical deliverables, not generic checklists.

• PCP development and refresh: building or updating a written Preventive Control Plan that reflects your actual operation and the latest CFIA expectations, including chemical hazards.
• HACCP and hazard analysis: structured identification of biological, chemical and physical hazards, with defensible critical control points and limits.
• Mock inspections and gap assessments: simulating a CFIA inspection against the SFCR so you find and close gaps first.
• Food safety culture programs: management commitment, training, and accountability structures that stand up to scrutiny.
• SOP development and record systems: monitoring, corrective action, verification and record-keeping procedures that match practice.
• Licensing support: confirming your SFC licence scope and Additional Establishment Information are complete and accurate.

Explore our food and beverage regulatory services, audit and gap assessment services, and regulatory affairs, licensing and import/export support, or learn more about MFLRC.

Conclusion: treat your PCP as a living document

The CFIA's commitment to inspect more than 2,400 establishments by fall 2026 is a clear signal that the manufactured-food sector's compliance-promotion period is over. Licence-holders who have never been inspected, and whose PCP has sat unused since licensing, are the most exposed. The agency's expanded expectations around chemical hazards, food safety culture, and complaint and trend data raise the bar for what a compliant operation looks like.

The good news is that inspection readiness is achievable with focused effort. Refresh your PCP, broaden your hazard analysis, align your records with practice, confirm your licence scope, and build the cultural evidence inspectors now look for. A facility that does this is not just inspection-ready; it produces safer food and protects the brand it has worked to build.

Sources and references

• CFIA, Response to the Inspector General recommendations regarding manufactured foods (action plan)
• CFIA, Notice to industry: Update on CFIA inspections of manufactured foods
• CFIA, Preventive controls and preventive control plan for food businesses
• CFIA, Regulatory requirements: Preventive controls (Part 4, SFCR)
• CFIA, A guide for preparing a PCP for domestic food businesses
• Global News, Plant-based milk recall: third death as listeriosis cases rise to 20