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By Carl Rodgers

Disclosure: I run ClearBorder, a Canadian customs compliance tool. I have a commercial interest in this topic. Every source below is public and can be checked directly.

For independent grocers and specialty food importers across Western Canada, managing margins has never been harder. But the biggest emerging threat to operating cash flow in 2026 isn't coming from supply chain costs or inflation — it's coming from a shift in Canadian customs liability that most importers haven't fully priced in.

There is a chart on CBSA's own website that tells the story.

Verification priority                   Cases targeted Closed  In error  Error rate Assessed revenue
Frozen desserts (HS 2105.00.10) 26 18 12 67% $55,211,681
China Surtax (steel & aluminum) 143 120 73 61% $4,083,528
US Surtax 2025-1   156 105 78 74% $7,121,722

These are targeted verification results, not random-market rates. CBSA selected importers in these categories because risk-profiling flagged them. That distinction makes the numbers more meaningful, not less: when CBSA decides to look at a category, this is what they find.

The $55.2 million figure is from eighteen closed cases. That averages roughly $3 million in assessed revenue per closed case — a number large enough to be material for any independent importer it lands on.

What changed on January 1, 2026

Three things came into force on the same day.

Section 17 of the Customs Act was amended. The entity named as importer of record on the customs accounting document is now jointly and severally liable, along with the importer and owner, for duties, taxes, and post-accounting reassessments. CBSA's Memorandum D17-2-5 describes the importer of record as "the primary contact for verifications and the entity with direct liability for post-accounting obligations, including record keeping, making corrections, and payment of duties."

The CARM transition period ended. From January 1, 2026, every entry filed produces structured, queryable data CBSA can analyze at scale.

The four-year reassessment window under Customs Act sections 59–61 started running entirely against the new regime. By 2030, the rolling lookback will be populated almost entirely by CARM-era entries filed under the new Section 17 liability framework.

Why this matters for Western Canada

Western Canada is the centre of Canada's specialty food import economy. BC Asian importers, Prairie wholesale operators, Alberta specialty distributors, and Western independent grocers are disproportionately represented in the categories on CBSA's January 2026 priority list: supply-managed goods (dairy, poultry, eggs), frozen desserts containing 5% or more dairy, spent fowl, animal feed, CUSMA/CETA/CUKTCA origin verifications, China and US surtax verifications, and the 25% steel derivatives surtax in force from December 26, 2025.

If your imports touch any of those categories, you are inside the current verification perimeter.

What "your business is liable" actually means

Section 17's liability attaches to the importer of record as named on the customs accounting document. For most Western importers, that entity is the operating corporation — the BN account holder. This is not automatic personal liability for the human who owns the business. A properly incorporated business remains a legal shield. What Section 17 does is make the business the primary party CBSA pursues — not the broker who filed, not the freight forwarder, not the supplier.

For an SMB owner, that matters because reassessed amounts come out of operating cash flow. The frozen-dessert results show per-closed-case assessments averaging in seven figures. For most Western independents, that's not a line item — it's an event.

The broker-model issue

Most customs brokers are paid per entry. That model prices the work of getting an entry through CBSA today. It does not necessarily price the cost of defending that entry against a reassessment years from now. Many brokers have done good work educating clients about CARM and importer-of-record liability. But release and post-entry defence are structurally different activities. Under Section 17, the entity CBSA pursues for the reassessment is the importer of record — not the broker.

Three things to check this week

First, map CBSA's 2026 verification priority list to your imports. If you import supply-managed goods, frozen desserts, animal feed, goods claiming CUSMA/CETA/CUKTCA preference, or anything caught by the surtax orders, you are in the priority perimeter.

Second, pull a recent CAD and confirm who is named as importer of record. If your business's BN is there, your business is the entity CBSA will contact first.

Third, reconcile your filings against your broker invoices and CARM Statement of Account. This surfaces both reassessment exposure and potentially unclaimed Input Tax Credits — claimable up to four years back.

Many importers have never done that reconciliation. CBSA now has a data environment that makes it easier for the agency to spot inconsistencies. Importers should give themselves the same visibility.

 
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Cows eat grass…everyone knows that. But climate change is forcing producers and scientists to rethink some of our long-held assumptions about livestock nutrition. Crop costs are climbing. Traditional pastures are under pressure. And researchers are casting a wider net for unconventional feed sources that might help the industry adapt.

Wade Abbott, a research scientist with Agriculture and Agri-Food Canada based in Lethbridge, Alberta, was curious whether cattle can digest seaweed. And if they can, what's happening inside their guts to make it work? Abbott and his colleagues used the Canadian Light Source (CLS) at USask to answer those questions. Seaweed is fundamentally different from grass or hay at the molecular level. Breaking it down requires entirely different enzymes, ones that land-plant digesters wouldn't normally need.

The researchers looked at what happened inside the gut of cows that were fed seaweed. They observed a bloom or proliferation of bacteria they believe was involved in digestion – which suggested the cattle were successfully breaking down and digesting the marine material.

Abbott and colleagues have named this the "latent trait hypothesis": Beneficial microbe digesters persist at very low levels in the gut, essentially waiting, ready to rapidly multiply when the right dietary signal arrives. "Crystallography (at the CLS) gave us the molecular blueprint for how these enzymes work," Abbott said. "We could finally see exactly how the bacteria crack the code of seaweed digestion.” The team's findings are published in the science journal Nature Communications.

Abbott is quick to note that seaweed won't replace hay or traditional animal feeds; it's far too expensive for that. But the health benefits may be significant. "We're seeing potential for seaweed as an alternative to antimicrobials, or as an immunity booster," he said.

Looking ahead, Abbott sees this work as opening a much larger door. "We're only beginning to understand the genetic mechanisms that allow gut microbes to process these marine sugars," he said. "If we can map those pathways fully, the applications go well beyond cattle. We're talking about a new framework for sustainable agriculture, one that embraces unconventional feed sources and works with the biology that's already there, waiting to be activated."

 
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By: Ryan Coburn, Technical Sales Specialist, Hapman; and Clark Wright, Technical Development Engineer, Hapman

Moving dry bulk materials in industrial settings comes with unique challenges, especially when handling substances that are abrasive, sticky, or prone to clumping. These difficult-to-handle materials can disrupt operations, decrease efficiency, and cause excessive wear on equipment. Choosing the right feeder to address these challenges is critical for ensuring consistent performance and minimizing downtime.

Dosing feeders are designed to tackle these challenges head-on. This article explores the common issues encountered when moving difficult dry bulk materials and explains how selecting the right feeder features can mitigate these problems, improve process efficiency, and enhance operational safety.

Common Challenges When Handling Difficult Materials

Clumping and Material Bridging

Materials like flour, cocoa powder, and sugar often clump and bridge within hoppers, particularly when exposed to moisture or pressure. This behavior disrupts feeding consistency, leading to uneven distribution and process interruptions. For industries such as food production or chemical manufacturing, these inconsistencies can significantly affect product quality and throughput.

Inconsistent Material Flow

Achieving a uniform flow rate is essential for production environments. However, materials with varying densities or adhesive properties, such as powders with high fat content, can create blockages that disrupt feeding. These interruptions lead to operational inefficiencies and complications in downstream processes.

Abrasive and Corrosive Wear

Handling abrasive or corrosive materials poses a significant challenge to feeders, often leading to rapid equipment wear and contamination risks. This issue is particularly critical in industries such as pharmaceuticals or food production, where hygiene and material purity are paramount.

Maintenance and Safety Concerns

Balancing ease of maintenance with operational safety is another challenge. Traditional feeders may require frequent disassembly for cleaning or repairs, increasing the risk of accidents and downtime. Ensuring compliance with safety standards while maintaining efficiency can be a difficult equilibrium to achieve.

Key Features to Address Challenges

Selecting a dosing feeder with specific design features can help overcome these obstacles. Here are some key considerations:

An internal agitation system is essential for breaking up clumps and preventing bridging. Agitators, driven by independent motors, ensure a consistent flow of material into the screw, even for sticky or cohesive powders. Adjustable agitation speeds allow operators to adapt to varying material properties, enhancing feeder versatility.

Dosing feeders with independent motor controls for the screw and agitator provide greater flexibility and precision. By adjusting these components separately, operators can fine-tune feeding rates to match material characteristics, reducing over-agitation and optimizing performance.

Stainless steel construction, particularly grades 304 and 316, offers excellent resistance to corrosion and is easy to clean. This durability ensures that feeders can handle abrasive materials and meet strict hygiene standards required in sensitive industries like food processing.

Volumetric and gravimetric feeding systems provide tailored solutions for maintaining consistent feed rates. Gravimetric feeders use weight-based measurements for high precision control, making them ideal for applications where ingredient consistency is critical, such as pharmaceuticals or specialty chemicals.

Modern dosing feeders incorporate enhanced bolt-on safety features, such as nozzles and bar grates, that reduce maintenance complexity while protecting operators. These features prevent accidental exposure to moving parts and ensure compliance with safety standards without compromising operational efficiency.

Customizable components, such as different screw types or extension hoppers, allow dosing feeders to handle a wide range of material properties. Whether it’s a progressive pitch screw for low-density powders or an extension hopper for increased storage, customization ensures optimal performance.

Best Practices for Feeder Operation

Beyond selecting the right feeder, following best practices is crucial to ensure long-term reliability and efficiency:

  • Avoid Material Buildup: Regularly clearing hoppers of residual materials prevents clogging and contamination.
  • Conduct Material Testing: Testing materials for bulk density, moisture content, and flow characteristics helps optimize feeder configurations.
  • Schedule Routine Maintenance: Periodic inspections and cleaning ensure components remain in peak condition, minimizing downtime.

The Hapman PosiPro®: A Comprehensive Solution

Hapman’s PosiPro® dosing feeder is engineered to address the challenges of handling difficult dry bulk materials. Its advanced design features, including independent motor controls and robust agitation systems, ensure consistent material flow and adaptability for a wide range of applications. Constructed with durable stainless steel, the PosiPro® offers resistance to corrosion and ease of cleaning, making it ideal for industries requiring strict hygiene standards. For additional material storage Hapman offers a conical extension hopper with the PosiPro Feeder. The conical shape of the hopper allows for unrestricted flow of material into the feeder and eliminates harborage areas for material to gather.

By incorporating bolt-on safety features and offering customizable components, the PosiPro® minimizes maintenance requirements while enhancing operational safety. Additionally, Hapman provides material testing services to help customers identify the optimal feeder configurations for their specific needs.

For industries seeking a reliable solution to the challenges of moving difficult materials, the Hapman PosiPro® dosing feeder delivers consistent performance, durability, and precision. By addressing these challenges head-on, operators can improve production efficiency, reduce downtime, and ensure long-term operational success.

 
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By Francisco Hernández Ortiz, Global Food Projects Director, HRS Heat Exchangers

 

Pasteurization is a process which reduces the microbial load in many food products, ensuring consumer safety and prolonging shelf life. There have been significant developments in non-thermal alternatives to traditional heat-based pasteurization, such as high-pressure processing (HPP) or pulsed electric field (PEF) processing.

However, before investing in any new technology, it is worth remembering that thermal pasteurization remains the standard against which these alternative methods are judged. For many ingredients and products, thermal pasteurization is still the most suitable, efficient and cost-effective solution, particularly now that it can be combined with newer heat sources such as ohmic heating and direct steam injection. Here, we take a look at the benefits and limitations of non-thermal options, before showcasing the advantages of traditional thermal pasteurization technology.

Non-thermal processing techniques

The most common alternatives to thermal pasteurization are high-pressure processing (HPP) and pulsed electric field (PEF) processing, followed by ultraviolet (UV) light, ultrasound, cold plasma, and high-pressure carbon dioxide (HPCD).

Typical industrial HPP involves underwater pressurization of the product at ambient temperature, usually to a specific pressure between 58-87 ksi, and then holding the product at this pressure for a specific time (usually one-to-five minutes). These high pressures induce changes in the functionality of the cell membranes, resulting in inactivation of vegetative cells and some enzymes.

In contrast, PEF processing uses short bursts of high voltage electric fields (up to 30,000 pulses per second) to achieve the desired microbial inactivation or modification of the food structure. This ruptures the cell membranes, causing the contents of the cells to leak out, effectively deactivating the microbes.

Some PEF processes actually use heat exchangers to pre-heat the product before the electrical fields are applied. This is usually when less heat-sensitive products are being processed, or when the product requires relatively high specific PEF energy inputs to achieve the desired level of microbial inactivation, e.g. in the case of vegetable juices, dairy products, or products where inactivation of bacterial endospores is required.

Limitations of non-thermal options

In many cases, HPP has minimal effect on taste, texture, appearance, and nutritional value. It can also be applied to ‘solid’ products, such as sliced cooked meat and ready-to-eat meals, where it reduces contamination from the manufacturing environment. However, it is not the ‘silver bullet’ that some have suggested; it requires high capital costs and is not suitable for every application. For example, any product where the air content is important (whipped creams, mousses, sauces, etc.) needs extra caution if HPP treatment is being considered, as the pressure may force the air from the product, or be compressed (and subsequently released). Both scenarios have the potential to cause catastrophic product damage.

Dry products such as powders, nuts, etc. are also unsuitable for HPP as isostatic pressure needs water to be present inside the food product in order to achieve uniform and efficient transmission (and therefore cause the necessary inactivation of any microorganisms present). Neither is HPP suitable for many whole fresh produce items where it is either ineffective (in the case of dense products such as fruits or tubers) or causes damage (e.g. leafy salads).

Finally, there is uncertainty around using HPP for raw meat products as it can induce color and texture changes. In trials, it has also been shown to cause denaturation in key proteins in certain dairy products, such as raw milk and whey.1

PEF processing has a number of roles in food processing, including dehydration; but as a pasteurization technique, it is most effective when used with liquid products (fruit juices, milk, liquid egg, etc.) and semi-solid foods (yogurts, fruit purees, salsa, sauces, etc.). However, there have been reports of a number of potential issues including corrosion and fouling of the electrodes, electrolysis of water, migration of electrode material components, and chemical changes in the food product.2

Another concern is that in many locations, food safety and public health regulations have not yet caught up with these new pasteurization techniques, meaning that further assessment may be required before they are widely accepted.

Benefits of thermal pasteurization

In most situations, there are several key advantages to traditional thermal pasteurization and sterilization techniques using corrugated tube, or scraped surface, heat exchangers:

  • They are proven and highly effective, killing 99.9% of pathogenic bacteria, yeasts and molds, and deactivating enzymes which can spoil food and beverage products. As such, thermal pasteurization is the standard against which alternative methods are judged.
  • They require lower capital costs than most non-thermal alternatives; in addition, technologies such as corrugated tube heat exchangers can offer a highly efficient process in a compact package.
  • They are scalable and versatile, making them suitable for a wide range of products. In commercial situations, one unit can be used for a range of temperature and time combinations, and to treat a wide range of products with minimal adjustment or reconfiguration.
  • They maintain nutritional value, particularly of many dairy and juice products. In particular, techniques such as HTST (high-temperature short-time) pasteurization and ohmic heating are particularly good at preserving product quality while providing effective and efficient control of harmful microorganisms.

Given the complexity and wide range of techniques available, it is important to seek expert advice, not only on thermal and non-thermal options, but also on how particular food and beverage products may react to these different processes. HRS Heat Exchangers offers a variety of thermal treatment options (including corrugated tube and scraped surface heat exchangers, ohmic heating and direct steam injection), as well as experience of numerous products and access to comprehensive laboratory testing facilities, making us perfectly placed to help food and beverage manufacturers choose the best pasteurization or sterilization options for their specific needs.

 
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By: Fabiola Negrón, Director of Food Safety at Registrar Corp

Most importers feel confident in their Foreign Supplier Verification Program until one moment: the FDA issues a Notice of Inspection. What surprises companies is not the inspection itself, but the speed, precision, and thoroughness with which investigators assess whether your FSVP is in place, implemented correctly, and accurately reflects the risks in your supply chain.

FSVP audits are among the most unforgiving reviews FDA conducts. They are designed to expose gaps quickly and to hold the U.S. importer accountable, even when the foreign supplier’s systems appear strong. This guide breaks down what really happens during an FSVP audit and why importers who think they are prepared often aren’t.

Why the FDA’s FSVP Audit Model Feels Different

Most regulatory audits allow for conversation, clarification, or corrective demonstrations. FSVP is different. Almost every conclusion the FDA reaches is based on whether your records match:

  • The hazards associated with your products
  • The controls implemented by your foreign supplier
  • The risk-based verification activities you selected

If these three elements don’t align, investigators deem the program inadequate. It’s common for importers to discover during the audit that their written procedures don’t match the actual actions of their personnel, one of the most frequent reasons for enforcement.

The Audit Trigger: How FDA Decides to Inspect You

FSVP audits may occur:

  • As routine FSMA surveillance
  • Following import entry reviews
  • After significant supplier incidents
  • In response to consumer complaints or outbreak investigations

Most companies receive no advance notice beyond Form 482, the standard notification of inspection. From that moment, the clock starts.

What Happens in the First Minutes of an FSVP Audit

Once the investigator arrives, they will immediately request:

  • Your written FSVP
  • Hazard analyses
  • Supplier evaluations and approval rationale
  • Verification activity records
  • Evidence of reanalysis

Unlike facility inspections, the FDA does not tour your operations or observe production. The audit is almost entirely a document-for-document evaluation. If your records are incomplete, inconsistent, or not readily retrievable, the investigator writes the deficiency into the file.

The Core Review: What the FDA Examines Most Closely

Investigators focus on five areas because they reveal the strength or failure of an FSVP:

  1. Hazard Analysis Quality

Is the hazard analysis product-specific, risk-based, and reviewed by a qualified individual? Does it identify who controls each hazard? If your analysis is generic or outdated, the FDA notes it immediately.

  1. Supplier Approval Decisions

Does your supplier’s performance justify approval? Many importers list a supplier as “approved” with no written rationale, no historical review, and no evaluation of corrective actions.

  1. Verification Activities

Were the activities selected appropriate for the hazards? For example, testing alone rarely satisfies verification for high-risk suppliers. The FDA expects logic, not convenience.

  1. Alignment Between Records and Reality

Do your written procedures match your actual practices? If the investigator interviews staff and hears a different process than what appears in your FSVP, this misalignment is cited.

  1. Qualified Individual Involvement

Was a properly trained individual involved in the evaluation and approval process? Lack of PCQI or FSVP training is one of the most consistent findings across Warning Letters. Importers who want clarity on common qualified-individual pitfalls often refer to audit risks PCQIs can prevent.

Where Importers Most Frequently Get Caught

Certain mistakes appear so consistently that investigators expect to find them. These include:

  • Missing or Boilerplate Hazard Analyses

Generic hazard analyses signal to FDA that the importer has not evaluated the supplier’s actual process. This often leads investigators to review multiple product lines.

  • Supplier Approval Without Documentation

“Approved” means nothing if the rationale isn’t recorded. FDA will consider the supplier effectively “not evaluated” if documents aren’t present.

  • Incomplete or Inappropriate Verification Activities

When importers choose minimal verification activities or choose them for convenience, investigators note the gap immediately.

  • Failure to Reassess Suppliers

Reassessment is required at least every three years. Many companies fail to document this step, even if their supplier has not changed.

  • Broken Internal Communication

When procurement, QA, and leadership are not aligned, the FSVP falls apart under audit pressure. FDA expects that all responsible parties can explain the program.

  • Lack of Alignment With HACCP or Preventive Controls
  • If supplier controls do not logically align with the hazards in your analysis, FDA views the entire program as structurally weak.

Why FSVP Audits Create Urgency for Training

FSVP is a regulation built on interpretation—and interpretation requires training. The most consistently cited deficiencies are tied to misunderstandings of what FDA considers a risk-based verification.

Companies with formally trained FSVP personnel are significantly more likely to:

  • Produce records that meet FDA expectations
  • Demonstrate appropriate hazard evaluations
  • Justify supplier approval decisions
  • Prepare corrective actions when needed

Your Next Step: Strengthen Your Team Before FDA Arrives

An FSVP audit goes beyond merely confirming the existence of your program; it delves into its accuracy, logic, and implementation. If your team is uncertain about evaluating hazards, justifying supplier approval, or selecting verification activities with FDA-level reasoning, formal FSVP training offers immediate alignment and clarity.

 

Fabiola Negrón is the Director of Food Safety at Registrar Corp. She oversees regulatory specialists that assist domestic and foreign food facilities and U.S. importers with U.S. FDA food safety compliance. Registrar Corp is the world’s largest FDA compliance company, helping food, beverage, cosmetics, medical devices, and drug companies meet compliance requirements.

 

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