IREP Frequently Asked Questions

A 1. IREP participants are required to submit the following reports by the deadlines established in Appendix 2 of the Letter of Authorization:

• Monthly Export Report, due at the end of the following month (Ex. a monthly export report for April would be due no later than the end of May)
• Inventory Report (Section 16), due every two months by no later than the end of the following month.

Also, an amended Export Product List (Section 13) must be re-submitted whenever you would like to produce a new finished product using IREP ingredients.

A 2. IREP At a Glance provides a detailed overview of the IREP reporting requirements.

A 1. Please refer to the Notice to Importers for the relevant sector:
Dairy - Chicken – Eggs – Turkey

A 2. Please refer to section 10.3 (1) of the Export and Import Permits Act (EIPA) for record keeping and retention requirements under the Act.

A 1. The IREP team’s calculated inventory balance is determined by extracting the import information from DFATD’s automated import permit system and then subtracting the amounts reported by the company for exports, product disposals and losses. A balance discrepancy occurs when this calculated inventory balance does not align with the figure reported in the company’s Inventory Report (Section 16).  Common errors that can cause balance discrepancies include:

• Incorrect reporting on the monthly export report including HS and finished product codes
• Incorrect reporting on the inventory report
• Over-exportation (the exported amounts in the company’s export reports are greater than the company’s balance).

A 2. IREP At a Glance provides a detailed overview of how balances are calculated.

A 1. Please refer to the instructions on how to complete an export report: 

• For Chicken, Turkey, and Egg products, all the fields contained in the template must be entered into the report
• For Dairy products, all the fields must be filled except for the CFIA certificate numbers and weights in eviscerated equivalent.

A 2.IREP At a Glance provides a detailed overview of how monthly export reports must be completed.

Some of the common errors in the monthly export report are:

• Incorrect reporting in the monthly export report
  • incorrect HS commodity code(s)
  • unauthorized finished product (not listed in section 13)
  • inaccurate export dates
  • Missing information.
  • Any modification of the Microsoft Excel report templates.

A revised export report should be provided to the IREP team, with the missing shipment highlighted in yellow. In order for the revised report to be accepted, supporting documents (such as Customs documents and Bill of Lading) may be required.

The dates in the “Shipment Date” column should be the dates that the finished products crossed the border.

No. The automated import permit system and monthly export reports are based on the calendar month, and must be filled out accordingly. Export and inventory information must be reported in the same manner in order to be processed properly.

A 1. The inventory report (section 16) should reflect the inventory of all IREP ingredients inside Canada`s borders. This includes the quantity, in kilograms (kg), of:

• imported ingredients in transit in Canada
• imported ingredients not yet used
• production in progress that contains IREP ingredients
• finished products containing IREP ingredients (including finished products stored in any warehouse in Canada, but not any that are in US warehouses unless held in bond).

A 2.  Should finished products not sold but already exported be included in the inventory report?

For the purpose of IREP, the location of the ingredient or the finished product is the key element for the inventory report. It is not related to the sale.

For example, a finished product in a US warehouse, waiting to be shipped to the final customer, should not be included in the inventory report unless it is being held in bond, as it has already been exported.

A 3. Should finished products sold, but still in Canada be included in the inventory report?

A finished product sold, but waiting in a Canadian warehouse (owned or not by the IREP participant) for the final shipment to an export country, must be included in the inventory report as the finished product containing the IREP ingredient is still in Canada.  The name and address of the warehouse should be communicated to the IREP team as part of the original application.

A 1. Check your import permits – does the amount of imports you received match the amount listed on your permits? Have you included imports that are “in transit” (imports that have entered Canada but have not yet arrived at your facility)? Make sure that you keep track of all imports received. You may request an import permit summary report from the Department to validate that all import quantities that have been requested reflect the quantities of imports received. Where necessary, you will need to seek a permit correction. When appropriate, you can discuss the procedure for making corrections to your import permits with your broker or with a member of the IREP team.

A 2. Check your export reports – has every export shipment been captured in your reports? Review the information submitted for each month. It should match your production records and your sales to your customers.

An amended Section 13 must be submitted to the IREP team along with the finished product label(s), and finished product recipe(s)/bill of material (that clearly identifies the weight (in kilograms) of all ingredients used in production and the percentage of the finished product that the IREP ingredient represents), and a signed description of the loss factor written on company letterhead.

The loss factor (to be included in the Section 13) refers to any step during the manufacturing process of the finished products where quantities of IREP ingredients are lost. For example, ingredient that stays in the bag after its contents have been opened, ingredient that sticks to the container or conveyor, over-filling should all be included in the loss factor.

At any time, the loss factor should be measurable and verifiable. An IREP verification of the manufacturing process should be able to validate the loss factor upon request.

Depending on how the recipe/bill of material is structured, the loss factor may be already included, whether partially or completely. In that situation, the loss factor reported on the Section 13 should only include what is not built into the bill of material. However, a full explanation of all causes of loss must be provided in the description of the loss factor that is required to be submitted as part of the application process.

Exceptional losses should not be included in the loss factor. Such losses could include non-routine events like spillage, damaged or spoiled raw ingredients and/or finished products, losses from power outages, manipulation or transportation accidents. These types of losses are subject to IREP disposal requests.

The loss factor reported in your IREP application (section 13) is expected to be an average based on the production data for the previous year, or if you are producing a new product, based on an expected loss factor or similar product.

If there is a significant variation, you may want to contact the IREP team to discuss the situation in order to agree on a reporting method. For example, if your company has the ability to keep track of actual usage of ingredients in the finished products, you may request to the IREP team to report in terms of actual usage.

The percentage of imported ingredient and loss declared in the Export Product List (Section 13) should be based on your recipes and an average of the loss, respectively. If at any time there is a significant change in the use of an IREP ingredient, please inform the IREP team of the situation and provide detailed explanation of the variation in the use. If you would like to change the percentages in the Section 13, supporting documentation, such as production records, may be requested.

If your company has the ability to keep track of actual usage of ingredients in the finished products, you may request to report in terms of actual usage.

Check your import permits. You may want to ask your broker, if you do not have a copy of the permits. You may request an import permit summary report from the Department to validate that all import quantities that have been requested reflect the quantities of imports received.

To reflect the actual quantity received, you will need to request a permit amendment from a Department permit officer through your broker. The broker may be requested to provide the following import documents: 

• commercial invoice from the supplier
• amended CBSA Canada Customs Coding Form (B3)
• proof of payment
• signed Bill of Lading

Once submitted, the IREP manager will review and approve the permit amendment.

Complete a new IREP application containing the new IREP ingredient’s commodity code and submit the following: a new export product list (Section 13), finished product recipe(s)/bill of material for all products that will be produced using the new IREP ingredient, finished product label(s), and a sales contract (or equivalent).

All disposals/destructions or donations must be pre-approved by the IREP team.  A written request (sent by email to irep@international.gc.ca) must be submitted to the IREP team for approval prior to the disposal/destruction or donation being actioned.  The IREP team will provide pre-approval and inform the IREP participant if a third party witness is required at the time of destruction, disposal, or donation. All documents signed by the third party must be submitted to the Department within five business days of the disposal/destruction/donation.

No. Substitution of IREP ingredient is prohibited and subject to sanctions under the IREP. Ingredients imported under the IREP must be used for export only and cannot be used for finished products sold in Canada.

Under IREP, imported ingredients must be re-exported within a specific timeframe varying between 90 days and 180 days depending on the commodity code of the imported ingredient.

Where business requirements will lead to non-compliance of this rule, the IREP participant must inform the IREP team in a timely manner, preferably at the time of application. The IREP team will consider such requests on a case by case basis.

Should your company be facing exceptional circumstances that prevent it from meeting an IREP condition, you may contact the IREP team in advance to seek consideration of a request for an exception to the IREP conditions.