Canada Gazette, Part I, Volume 160, Number 28: Regulations Amending Certain Regulations Relating to Harmonization of the Enhanced Feed Ban

July 11, 2026

Statutory authorities
Health of Animals Act
Feeds Act
Fertilizers Act
Food and Drugs Act
Safe Food for Canadians Act

Sponsoring agency
Canadian Food Inspection Agency

REGULATORY IMPACT ANALYSIS STATEMENT

(This statement is not part of the Regulations.)

Executive summary

Issues:

Canada’s Enhanced Feed Ban (EFB) was implemented in 2007 to address bovine spongiform encephalopathy (BSE). It prohibits the use of specified risk material (SRM) in livestock feed, fertilizer, and pet food. These measures were put in place at the time to manage uncertainty and protect public and animal health. However, Canada’s EFB requirements have not been updated to reflect the current BSE risk profile or evolving international standards.

Classical BSE has declined globally to near zero, and Canada has been recognized by the World Organisation for Animal Health (WOAH) as having a negligible BSE risk status since 2021. Despite this evolution, Canada’s EFB has more restrictive requirements than the U.S., which allows certain lower-risk SRM to be used for non-ruminant feed, fertilizer, and pet food. This misalignment has been cited as creating an unnecessary regulatory burden, as it increases costs and limits value recovery, placing Canadian cattle and processing sectors at a competitive disadvantage within integrated North American markets. Regulatory amendments are required to ensure Canada’s EFB framework is proportionate and aligned with current risk and supports alignment with the U.S., while maintaining strong protections for human and animal health.

Description:

Proposed amendments to the Health of Animals Regulations, Feeds Regulations, 2024, and Fertilizers Regulations would introduce a targeted flexibility to Canada’s EFB requirements by allowing a defined subset of SRM to be handled as prohibited material and used in non-ruminant livestock feed, fertilizer, and pet food. This voluntary approach would align Canada’s EFB with the U.S. list of cattle material prohibited from animal feed (CMPAF) and with the risk-based principles set out by the WOAH. Core safeguards would remain unchanged. All SRM would continue to be prohibited in human food, and the prohibition on feeding most mammalian-derived proteins to ruminants would remain fully in place, maintaining control over the primary BSE exposure pathway. High-risk SRM (the brain and spinal cord of cattle aged 30 months or older) would remain prohibited for all uses.

Rationale:

Updated scientific assessments confirm that Canada’s negligible BSE risk status supports a more proportionate application of controls. Permitting lower-risk SRM for non-ruminant feed, fertilizer, and pet food would not increase risks to human or animal health, provided existing safeguards remain in place. Despite the reduced BSE risk, Canada’s EFB requirements impose blanket prohibitions, which create an unnecessary regulatory burden and hinders competitiveness. Stakeholders have consistently called for better regulatory alignment with the United States and a more risk-based approach. The proposed amendments would maintain core BSE protections while reducing the unnecessary burden through targeted flexibility. The proposed amendments would not impose any new burden, as adoption would be voluntary.

Issues

Canada’s Enhanced Feed Ban (EFB) prohibits certain cattle materials, known as specified risk material (SRM), to be used in livestock feed, fertilizer, and pet food. The EFB was put in place in 2007 to accelerate Canada’s progress toward the reduction of bovine spongiform encephalopathy (BSE) in the Canadian cattle herd. Canada’s first domestic case of classical BSE was in 2003, and since then SRM was formally defined and has been excluded from the human food chain. The EFB expanded the original feed ban of 1997, under which most mammalian proteins, and, by extension, SRM, were already prohibited from ruminant feed (i.e. cattle, sheep, and goats). The objective of Canada’s EFB was to strengthen controls and to regain access to global markets for Canadian cattle and beef products.

Over time, the number of BSE cases has fallen from epidemic levels in the 1990s to near zero globally. Only two confirmed classical cases worldwide have been reported since 2017, both in the United Kingdom (UK). In May 2021, Canada was officially recognized by WOAH with having a negligible BSE risk status. The risk of BSE being reintroduced into Canada’s cattle herd is extremely low.

Canada’s EFB regulatory requirements have not been updated in nearly twenty years and no longer are appropriate with the current epidemiology and BSE risk level. Multiple industry stakeholders, including the Canadian cattle industry, have stated that Canada’s EFB creates unnecessary red tape and makes it more expensive to compete in the global market, especially against their U.S. counterparts, where the rules are less strict. Stakeholders have requested that Canada update its EFB to align with U.S. requirements. They emphasize the urgency of modernizing outdated regulatory requirements to reduce economic strain and improve the competitiveness of the agricultural sector.

There is a need to update Canada’s EFB to adjust requirements proportional to the current risk profile, to align with U.S. requirements for non-ruminant livestock feed, pet food, and fertilizer, and to eliminate unnecessary red tape it creates for the Canadian cattle industry, while maintaining ongoing protections for human health and Canada’s food supply.

The following are the key issues with Canada’s EFB:

1. The EFB is not aligned with Canada’s current BSE risk profile

The implementation of effective control measures has led to a worldwide decline in classical BSE, with the current incidence considered negligible and approaching zero cases per million cattle. The last Canadian classical BSE case was reported in 2015 in cattle born in 2009. In 2021, Canada was officially recognized by WOAH with a “negligible BSE risk status,” the highest designation level under WOAH standards. Canada’s “negligible BSE risk status” was again reaffirmed under updated 2023 standards.

Canada’s EFB, namely the prohibition of all SRM tissue in secondary pathways (i.e. non-ruminant feed, fertilizer, and pet food), was developed in response to past disease outbreaks and does not reflect the latest scientific analysis. Recent scientific risk assessments have concluded that flexibility could be introduced to the EFB requirements without increasing Canada’s BSE risk and maintaining Canada’s WOAH negligible BSE risk status. These risk assessments examined lower-risk SRM and their use in non-ruminant feed, fertilizer, and pet food. All SRM will remain prohibited in human food.

In 2025, the CFIA, in collaboration with other federal organizations, assessed impacts on human and animal health related to aligning Canada’s list of materials prohibited in non-ruminant feed, fertilizer, and pet food with that of the U.S. Three assessments, building on a risk analysis by Risk Sciences International (RSI), were conducted independently by CFIA, the Public Health Agency of Canada (PHAC) and Health Canada. These assessments concluded that aligning Canada’s EFB with U.S. requirements would not increase Canada’s BSE risk, provided key safeguards remain in place. These safeguards include having effective segregation of SRM, robust traceability, and prevention of cross-contamination between ruminant and non-ruminant feed streams.

2. Canada’s and U.S.’s feed bans are not aligned, and WOAH standards have evolved

WOAH guidelines have evolved as the global prevalence of classical BSE has fallen. In 2023, WOAH updated its approach, moving away from using surveillance to verify if feed bans work, to focusing on rapid detection of new cases. WOAH does not prescribe a universal feed ban given the enormous variability of livestock industry practices around the world. Instead, WOAH requires countries to first identify all practices that could result in oral exposure of ruminants to ruminant-derived protein meal and to then demonstrate that effective mitigation measures are in place for each identified risk to prevent such exposure. It also requires countries to periodically review and adjust their measures in line with current risk conditions.

Canada and the U.S. both maintain negligible risk status based on country-specific risk profiles and corresponding mitigation measures. Despite having negligible BSE risk status since 2021, Canada’s regulatory requirements remain stricter than those in the U.S., as it prohibits all SRM in non-ruminant feed, fertilizer and pet food, regardless of tissue-specific risk profiles. These measures create unnecessary red tape on the Canadian cattle industry and hurt competitiveness.

3. Canada’s current EFB creates unnecessary red tape and reduces competitiveness

Canada’s EFB requirements create both operational costs and revenue loss for industry. Under the EFB all SRM, regardless of risk profile, is subject to strict requirements (e.g. handling, staining, transportation, tracking and disposal). In addition, all SRM is prohibited not just in human food, but is also prohibited to be used in all livestock feed, fertilizer, and pet food. This results in a compounding burden where slaughter and processing establishments lose the potential value of lower-risk SRM that could otherwise be safely repurposed in select products, and they must also incur the costs associated with meeting strict handling and disposal protocols. This undermines the competitiveness of the Canadian cattle industry, where the U.S. operates under less restrictive, risk-aligned requirements. As the cattle, feed, pet food, and fertilizer markets are tightly integrated in North America, having to adhere to stricter SRM requirements in Canada creates a competitive disadvantage.

Industry stakeholders have repeatedly raised Canada’s overly strict SRM requirements and misalignment with U.S. requirements as an issue causing red tape for the cattle industry. In response to these concerns, the House of Commons’ Standing Committee on Agriculture and Agri-Food (AGRI) recommended, in its report entitled “Unleashing the Potential of the Canadian Agriculture and Agri-Food Sector Through Regulatory Reform” that regulatory amendments be made to Canada’s EFB to harmonize SRM regulations with the U.S.

Background

BSE is a prion disease that affects the central nervous system (the brain and the spinal cord) of cattle. BSE is both an animal health and a public health concern due to its potential link to variant Creutzfeldt-Jakob Disease (vCJD) in humans, an incurable neurodegenerative disease. BSE has been a federally reportable disease under the Health of Animals Act in Canada since 1990.

Both atypical BSE (spontaneous) and classical BSE (acquired through contaminated feed) are associated with the presence of an abnormal form of a cellular protein called a prion, which accumulates and damages the central nervous system of cattle. SRM hold the highest concentration of BSE prions in infected cattle. Canada defines SRM as

While atypical BSE can occur randomly, classical BSE occurs when cattle ingest BSE prions through feed containing animal proteins from other cattle. Canada’s first domestic case of classical BSE occurred in May 2003. It was linked to imported cattle from the UK and feeding practices that allowed BSE prions from infected cattle to be present in cattle feed. This case of classical BSE closed markets and caused economic devastation for Canadian producers. To restrict feeding practices that led to the global BSE epidemic, Canada introduced an initial feed ban in 1997, prohibiting the feeding of most mammalian proteins (defined as prohibited material) to ruminants. Banning the use of prohibited material in ruminant feed was highly effective at addressing the primary exposure pathway, greatly reducing BSE in the cattle population and eventually leading to the end of the epidemic. Prohibited material is defined in the Health of Animals Regulations, Part XIV. In general, it is a broad category that includes most mammalian proteins and represents the majority of inedible material derived from slaughtered cattle. SRM are a specific subset of prohibited material that are subject to more stringent controls because they have been identified as capable of transmitting BSE.

Since 2003, SRM has been excluded from the human food chain in Canada. The EFB, introduced in 2007, responded to the need to further accelerate the reduction of BSE, as cases indicated the continued presence of BSE prions in the feed system after the initial feed ban of 1997. The EFB extended SRM removal to secondary exposure pathways (livestock feed, pet food, and fertilizer), successfully reducing cases to zero. Canada’s EFB supported the recovery of international market access and marked the final step in a series of strengthening BSE controls. In light of the scientific evolution in the understanding of BSE, the EFB is not aligned with Canada’s current BSE risk profile.

Although Canada and the U.S. have regulations to reduce the risk of BSE, Canada’s regulatory requirements are stricter. This is because Canada had to introduce the EFB following a domestic case of classical BSE, while the U.S. has not had a case of native-born classical BSE.

Recent risk analysis undertaken by the CFIA and federal organizations indicates that the risk of BSE would not increase if certain lower-risk SRM tissues were used in non-ruminant feed, fertilizer or pet food provided that Canada’s strict prohibition on feeding prohibited material to ruminants remains unchanged. SRM would still need to be prohibited in food and in ruminant feed.

Given the updated risk analysis, leveraging existing controls established under the original ruminant feed ban would represent a more appropriate and proportionate means of managing BSE risk while maintaining protections for animal and public health. Maintaining a strict prohibition on feeding prohibited material to cattle, the cornerstone of the original feed ban, remains Canada’s most important BSE control measure and keeps the risk of re-starting an epidemic effectively nonexistent.

Federal legislative and regulatory authorities 

There are five CFIA acts and associated regulations that collectively provide a comprehensive framework for controlling prohibited material and SRM across the food, livestock feed, pet food, and fertilizer supply chains.

There is no overarching Canadian legislation that regulates the manufacture of pet food for domestic sale and consumption. Requirements for pet food fall under various federal laws, each addressing different aspects of safety and consumer protection, such as the Consumer Packaging and Labelling Act, administered by the Competition Bureau.

CFIA oversight 

The CFIA exercises comprehensive oversight of SRM across the value chain, from slaughter and processing through rendering, livestock feed, pet food and fertilizer production, transportation, and final disposal. SRM is typically removed at slaughter and processing establishments where edible tissues are prepared for food. Federally licensed food establishments must integrate SRM controls into their Preventive Control Plans (PCPs), which are verified by the CFIA. Meat establishments under provincial jurisdiction are inspected by the latter for compliance with federal SRM requirements, with additional verification being conducted by CFIA. Under the Health of Animals Regulations, SRM must be removed in accordance with prescribed requirements, managed to prevent crosscontamination, and is strictly prohibited from entering the food supply. SRM may not leave slaughter or processing establishments without a CFIA permit, and disposal methods must permanently contain or destroy SRM.

Following removal, inedible tissues containing SRM are commonly transferred to permitted rendering facilities for further processing. Renderers handling SRM operate under CFIA permits and are inspected according to their risk profile, with enhanced oversight where processed material may be used as livestock feed ingredients. CFIA oversight continues downstream through verification activities at commercial feed mills, fertilizer manufacturing and distribution, and through import and export controls for pet food, to protect animal health.

Objective

Overall, the proposed regulatory amendments would

Specifically, the regulations would

Description

The proposed amendments would introduce flexibility to Canada’s EFB in a manner that supports competitiveness and remains proportionate to the current BSE risk profile. Amendments to the Health of Animals Regulations, Feeds Regulations 2024, and Fertilizer Regulations would allow lower-risk SRM to be handled as prohibited material and be used in non-ruminant feed, fertilizers, and pet food, subject to conditions. Stringent protections for human food will remain. These amendments would not impose new rules on regulated parties. Rather, establishments would have the option to take advantage of this flexibility if it makes business sense. The amendments would

  1. Reflect Canada’s current BSE risk profile: With classical BSE now at historically low levels globally, and Canada having a negligible risk status for BSE, limited use of lower-risk SRM is appropriate within a controls-based framework. The proposed changes would apply only to secondary exposure pathways (non-ruminant feed, fertilizers and pet food) while core protections would remain unchanged, including the strict prohibitions of prohibited material in ruminant feed, and of SRM in human food.
  2. Align with U.S. requirements and continue to meet WOAH standards: A risk-based approach that preserves controls on the primary BSE pathway while providing flexibility to requirements for secondary pathways would align the EFB with U.S. CMPAF classification and continue to meet WOAH standards to maintain Canada’s negligible BSE risk status.
  3. Reduce regulatory burden and support sector competitiveness: The added flexibility would reduce the administrative burden for participating regulated parties by allowing eligible, low-risk tissues to be managed as prohibited material for use in non-ruminant feed, fertilizer, and pet food. This would eliminate SRM-specific handling and disposal requirements for those tissues and improve value recovery across integrated North American supply chains, including improved access to higher-value meat and bonemeal inputs for the pet food sector.

Amendments to the SFCR and FDR would also be made to ensure regulatory coherence and clarity.

No changes have been proposed to SRM regulatory requirements for human food. All SRM would continue to be prohibited in food, and all existing food safety controls would be maintained.

Scope and proposed framework

The proposed regulatory amendments would introduce targeted flexibility to Canada’s EFB by allowing a defined subset of SRM to be repurposed and used in non-ruminant feed, fertilizer, and pet food, subject to conditions. The subset of SRM would be exempt from certain SRM-level requirements and follow established prohibited material requirements. Eligible SRM tissues would include

Tissues from cattle slaughtered for human consumption and from deadstock (cattle that died or were condemned before slaughter) would be eligible. High-risk SRM, specifically the brain and spinal cord of cattle over thirty months of age, would continue to be prohibited for all uses.

Under the current regime, a CFIA permit is required to handle SRM. Under the proposed approach, a new CFIA permit would be required to separate eligible SRM from high-risk SRM of cattle over 30 months of age to mitigate the additional risk related to those activities, such as removing the brain from the skull. To minimize the impact on regulated parties, the existing SRM permitting framework would be expanded to allow establishments to voluntarily handle eligible SRM if they meet conditions necessary to prevent cross-contamination with high-risk SRM. The combination of permits and existing controls such as the original feed ban and the national BSE surveillance program is anticipated to keep BSE risk as a negligible level.

While the new permit introduces a very small administrative cost, it would enable a significant net reduction of operational red tape since businesses that choose to adopt the changes would no longer need to handle the majority of the SRM they generate under strict SRM-level requirements. It would also allow the reproposing of eligible SRM and create a new revenue stream for those businesses.

In addition, a permit would no longer be required to handle the distal ileum of cattle under 30 months of age, and all carcasses under 30 months would be considered prohibited material in their entirety. This is because the distal ileum is the only SRM present in cattle under 30 months and there would be no need to demonstrate effective measures to prevent cross-contamination with high-risk SRM.

This approach would provide flexibility while allowing businesses to decide whether participation aligns with their operational needs. Establishments could choose to continue to handle all SRM under existing requirements.

Federally and provincially inspected slaughter and processing establishments that choose to repurpose eligible SRM from cattle over 30 months of age would

No new regulatory requirements would be imposed on downstream establishments handling cattle-derived materials. Renderers, feed mills, fertilizer manufacturers, pet food producers, transporters, and disposal facilities would continue to operate under existing SRM and prohibited material requirements, including labelling provisions designed to prevent access or exposure of ruminants. In some scenarios, the amendments could reduce the need for SRM permits. For example, additional controls would not be needed in veal slaughter establishments because there is no high-risk SRM in animals under 30 months of age.

CFIA (and provincial authorities, where applicable), would provide oversight and verify compliance with permit conditions at slaughter or initial processing.

Core safeguards would remain unchanged, including the strict prohibitions of prohibited material in ruminant feed, and of SRM in human food. Collectively, the proposed amendments would add flexibility to businesses and support competitiveness and the reduction of unnecessary regulatory burden while maintaining Canada’s negligible BSE risk status.

Details on the proposed amendments by the CFIA regulation are set out below:

Health of Animals Regulations (HAR)

Amendments to the HAR Part I.1 (Specified Risk Material) would create the framework to enable the repurposing of eligible SRM by

  1. defining “eligible specified risk material” as: the skull, eyes, trigeminal and dorsal root ganglia, tonsils, and distal ileum from cattle over 30 months of age and the distal ileum from cattle under 30 months of age;
  2. setting the condition that eligible SRM from cattle over 30 months of age must be completely separated, segregated and collected, in accordance with a permit issued by the CFIA; and
  3. exempting eligible SRM from certain existing SRM requirements, such as dyeing, segregation and record keeping requirements.

The amendments would also

It is important to note that while eligible SRM would be exempt from some SRM requirements, they would continue to be regulated under part XIV of the HAR as prohibited material.

Feeds Regulations, 2024

Feeds Regulations, 2024, 35(e)(i) would be amended to allow the inclusion of eligible SRM in non-ruminant feed according to the HAR framework.

Fertilizer Regulations

Fertilizers Regulations, 9(a)(ii) would be amended to allow the inclusion of eligible SRM in fertilizer according to the HAR framework.

Additional amendments

There would be additional amendments to ensure various regulations align with the updated permitting framework under the HAR, and to add clarity. This includes:

Safe Food for Canadian Regulations

SFCR s. 155(3), which currently requires licence holders to keep all SRM in a separate area of the inedible room, would be repealed. This would avoid overlap and potential conflict of handling requirements between the SFCR and the HAR, as the proposed framework would allow eligible SRM to be mixed with other prohibited material.

Additionally, the requirement to destroy SRM in accordance with Part I.1 of the HAR is not operationally feasible or enforceable. Approved destruction methods for SRM are strict, technically complex, and can only be carried out at specialized facilities. Because these methods cannot be performed at most slaughter or processing establishments, on-site destruction is impractical and would not reflect how SRM is safely managed in practice. Offsite disposal under existing HAR permits provides the necessary controls to ensure SRM is handled and destroyed in compliance with regulatory requirements.

All essential food safety protections would be maintained, and licence holders would still be required to move SRM into the inedible area. All SRM handling and destruction requirements would now be fully governed by the HAR.

Food and Drug Regulations

FDR B.01.047.1(3), which exempts the definition of SRM for SRM from countries designated as free from BSE, would be repealed. This would clarify the regulatory intent for a complete prohibition of SRM in food regardless of origin.

Regulatory development

Consultation

A range of stakeholders would be affected by the proposed regulatory amendments, including cattle producers and beef processors; renderers; feed, pet food and fertilizer manufacturers; provincial and territorial (PT) governments; and international trading partners. Engagement to date indicates broad support across most sectors for updating the EFB, with specific operational considerations noted by some stakeholders.

Industry engagement — CFIA-industry working group

The CFIA established the BSE Regulatory Alignment Engagement Group in 2024 to engage stakeholders on policy development. Stakeholders included major cattle and beef industry associations, processors, renderers, pet food manufacturers, feed and fertilizer associations, and PT representatives. Specific stakeholders include Canadian Cattle Association (CCA), Canadian Meat Council (including Cargill, True North Foods, Montpak), Beef Cattle Research Council, Animal Nutrition Association of Canada, Pet Food Association of Canada, Alberta Cattle Feeders’ Association, Canadian Renderers Association, Government of Alberta, Fertilizer Canada, and the Compost Council of Canada. This group has informed the CFIA’s assessment of the feasibility of aligning Canada’s EFB with U.S. requirements, its trade and economic implications, and practical implementation considerations.

Industry stakeholders, particularly beef producers, processors, and pet food manufacturers, have consistently indicated support for a feed ban alignment to reduce red tape, improve competitiveness, and recover value from lower-risk SRM. Renderers have expressed mixed views: some see economic benefit through increased volumes of prohibited material, while others have noted possible operational impacts from reduced SRM volumes.

Industry engagement — Slaughter and meat processing establishments

Slaughter and meat processors are central to SRM removal and segregation and are therefore among the most affected by the proposed changes linked to on-site separation under a permit. Large establishments under continuous inspection (such as federal licensed establishments or high-inspection provincial and territorial establishments) are expected to be early adopters given the larger volumes of material they manage and the potential to capture value from repurposing eligible SRM. By redirecting eligible SRM to non-ruminant livestock feed, pet food, or fertilizer, these establishments could convert an existing disposal cost into a potential revenue stream.

Feedback from small and medium establishments suggests that the primary benefit would be a reduction in disposal costs, in some cases with notable annual savings. They indicate a minimal impact on reduction of labour costs associated with SRM removal, staining, or segregation.

Some operators anticipate minor operational adjustments, such as limited equipment investments, but these are generally considered manageable. Overall, for small and medium establishments, the value of the proposed changes appears to be driven primarily by cost savings rather than operational efficiencies.

These measures are therefore expected to provide economic benefits across all establishment types, while adoption would depend on individual business models, local disposal infrastructure, and the ability to capture value from diverted materials.

Industry engagement — Cattle producers industry associations

There is very strong support for these amendments from the CCA, which is advocating for regulatory changes to align with U.S. requirements to reduce red tape and support economic competitiveness. While the benefits to cattle producers are indirect, a strong packing industry supports greater domestic slaughter capacity. The CCA has advocated for small abattoirs and processors to be able to benefit equally from the regulatory change.

Industry engagement — Renderers and deadstock collectors

Rendering facilities process inedible cattle by-products, including prohibited material and SRM, and are central to the prohibited material supply chain. Some may benefit from increased prohibited material volumes, as eligible SRM are reclassified. Overall feedback from the sector has been mixed: while value recovery opportunities exist, all anticipate some operational impacts from lower SRM volumes, and several expect downward pressure on Canadian meat and bone meal (MBM) prices. Renderers also emphasized the need to avoid unintended disruptions to deadstock collection from cattle and other species and small-processor systems. Deadstock refers to livestock that have died before slaughter due to illness, disease, old age, or accidents. Cattle deadstock must be disposed of in a specific way given that it contains SRM. Renderers, especially those serving smaller provincial slaughter establishments, note that reduced SRM volumes could raise disposal costs for establishments that continue to handle SRM.

Industry engagement — Commercial feed mills

Commercial and large-scale on-farm feed mills may source ingredients containing prohibited material from rendering plants for use in non-ruminant feed. They may benefit from expanded access to feed ingredients derived from previously restricted SRM.

The Animal Nutrition Association of Canada (ANAC), representing commercial feed mills, has expressed moderate support for the proposed regulatory change. ANAC indicated that the measure does not introduce new regulatory burden for their sector. In some cases, members that use prohibited material in their products may experience reduced input costs.

Industry engagement — Pet food manufacturers

Pet food manufacturers may source ingredients containing prohibited material from rendering plants for use in pet food production. They may benefit from expanded access to pet food ingredients derived from previously restricted SRM.

The Pet Food Association of Canada (PFAC) has expressed support for the proposed regulatory change, provided it does not negatively affect their existing export markets. Given the substantial pet food trade between Canada and the United States, PFAC views the change as a positive step toward simplifying the import of cattle MBM.

Industry engagement — Fertilizer manufacturers

Fertilizer manufacturers may source ingredients containing prohibited material from rendering plants for use in fertilizer and fertilizer product production. They may benefit from expanded access to ingredients derived from previously restricted SRM.

Fertilizer Canada (FC), representing Canadian manufacturers, wholesalers and distributors of fertilizer used in agriculture, have expressed moderate support for the proposed regulatory change. FC indicated that the measures do not introduce new regulatory burden for their sector. In some cases, members that use prohibited material in their products may experience reduced input costs.

FC also indicated interest in removing the existing prohibited material label precaution statements from fertilizer products, although this is outside the scope of the current amendment. These requirements, however, continue to serve as an important risk-management tool supporting the feed ban and mitigating accidental exposure risks.

Industry engagement — Livestock producers

The CFIA held an information sharing session with representation from: Animal Health Canada, Canadian Veterinary Medical Association, Canadian Pork Council, Canadian Aquaculture Industry Alliance, Turkey Farmers of Canada, Chicken Farmers of Canada, Canadian Sheep Federation, Dairy Farmers of Canada, Animal Nutrition Association of Canada, and the CCA.

Livestock groups did not have concerns regarding the proposed changes or the inclusion of these tissues in reformulated non-ruminant livestock feed. They cautioned the CFIA on its communication approach regarding consumer perception of reformulated products to include tissues that were previously considered SRM.

Federal-Provincial-Territorial engagement

Updating the EFB is a priority of Federal-Provincial-Territorial (FPT) Ministers of Agriculture. At the September 2025 FPT Ministers of Agriculture meeting, Ministers supported continued work to pursue harmonization of Canada’s BSE EFB with the U.S. to improve competitiveness for producers and processors. Ministers noted that these efforts support regulatory modernization, economic growth, and better outcomes for producers and consumers across Canada.

The CFIA has engaged the Council of Chief Veterinary Officers, comprised of the Chief Veterinary Officer (CVO) from each federal, provincial and territorial jurisdiction. Provincial authorities were also engaged in Ontario (OMAFA), Alberta (Meat and Dairy Inspection) and Quebec (MAPAQ). CVOs and provincial authorities provided broad support for this work.

International engagement — United States

The CFIA has engaged various regulatory agencies in the U.S., and the U.S. has signalled its support for this proposal.

On January 15, 2026, the CFIA met with representatives of the USDA Animal and Plant Health Inspection Service (APHIS), including the U.S. Acting Chief Veterinary Officer, to provide an overview of Canada’s proposal to align its EFB requirements with the U.S. list of CMPAF. It was noted that regulatory alignment regarding tissues permitted in non-ruminant feed and other products would allow U.S. MBM to be imported into Canada, which is currently not permitted due to Canada’s difference in SRM list from that of the U.S. The APHIS welcomed this proposed change and agreed that resolving the long-standing issue concerning the export of MBM from the U.S. would be viewed positively by both APHIS/USDA and the U.S. industry.

The CFIA held follow-up meetings with the USDA and FDA on February 19, 2026, and again with the FDA on February 26. On March 26, 2026, APHIS/USDA confirmed that APHIS/USDA, FDA, and FSIS do not have any scientific concerns with the CFIA’s proposal to align its EFB requirements with the U.S. list of CMPAF.

International engagement — Other trading partners

The CFIA sent letters informing key importing trading partners such as Mexico, Japan, Vietnam, Korea (Republic of), Taiwan, Hong Kong, the Philippines, the EU, Indonesia, and Australia, of proposed changes to the Canadian EFB through formal correspondence. At the margins of the 93rd WOAH General Session (May 18–22, 2026), the CFIA held bilateral meetings with Japan, Korea, Australia, the EU, Indonesia, and Mexico. They indicated that further scientific analysis will be required on their part before providing a response, and that additional information may be requested to support their assessment.

International engagement — WOAH

WOAH BSE risk status is maintained through an annual reconfirmation process that focuses on confirmed, implemented measures. Countries report completed changes, supported by evidence demonstrating that the WOAH risk assessment outcome remains unaffected. This approach ensures consistency and reliability in the evaluation process. WOAH reviews the submitted updates between November and March and confirms continued risk status in May.

Indigenous engagement, consultation and modern treaty obligations

The proposed amendments update existing requirements under the EFB and apply broadly across Canada. The initiative maintains an existing regulatory framework and does not introduce new barriers or differential impacts on Indigenous peoples. No direct adverse impacts on Indigenous peoples or section 35 rights have been identified.

The proposed amendments are technical and voluntary in nature and apply uniformly across a nationally established animal health and food safety regime. They do not alter decision-making authority, land use, access to natural resources, or the exercise of Indigenous rights, including rights recognized and affirmed under section 35 of the Constitution Act, 1982. The initiative does not introduce new regulatory obligations that would uniquely or disproportionately affect Indigenous peoples, communities, or businesses. While some commercial establishments subject to these requirements may operate in proximity to Indigenous communities, any interactions would remain indirect and unchanged from the current regulatory context.

Instrument choice

A range of regulatory and non-regulatory options were considered, including maintaining the status quo (no action), implementing non-regulatory measures, and pursuing targeted regulatory amendments. Non-regulatory approaches, such as guidance or voluntary industry practices, were determined to be insufficient, as they would not provide the legal authority, consistency, or enforceability required to manage SRM across the feed, fertilizer, and pet food supply chains. More expansive regulatory reforms were also examined; however, options that would fundamentally restructure existing frameworks or introduce new obligations across the supply chain were assessed as disproportionate to the current, negligible BSE risk profile and beyond what industry is currently prepared to implement.

Under the status quo, Canada’s EFB would remain misaligned to the current epidemiological situation, despite Canada’s negligible BSE risk status. Existing requirements would continue to prohibit all SRM from use in non-ruminant feed, fertilizer, and pet food, regardless of tissue-specific risk, resulting in unnecessary regulatory burden and costs for industry. Maintaining the status quo would also perpetuate a regulatory misalignment with the United States, contributing to a competitive disadvantage for Canadian producers and businesses. The Health of Animals Regulations would continue to serve as the primary regulatory framework for the removal, handling, and control of SRM to protect the food chain, and the original mammalian-to-ruminant feed ban would remain a cornerstone measure to prevent the recycling of BSE. While these controls are essential and must be maintained, opportunities to safely repurpose eligible SRM, supported by updated scientific risk assessments, would continue to be foregone.

Targeted regulatory amendments were selected as the preferred option because they best address the identified issues while preserving core safeguards. The proposed amendments would update the EFB by refining existing requirements under the Health of Animals Regulations and related regulations, aligning them with Canada’s current BSE risk profile and U.S. requirements, while maintaining compliance with WOAH guidance and the prohibition of SRM in human food and the mammalian-to-ruminant feed ban. This targeted approach enables the safe repurposing of eligible SRM under defined and controlled conditions to reduce unnecessary red tape and address competitiveness concerns, without introducing a new burden for stakeholders that choose not to participate. By leveraging existing permitting, oversight, and enforcement mechanisms, the proposed amendments support evidence-based decision making, facilitate compliance, and enhance the competitiveness of the Canadian cattle sector.

Regulatory analysis

Benefits and costs

This section assesses the incremental impacts (i.e. benefits and costs) under the baseline and regulatory scenario. The baseline scenario is the current regulatory framework with no change to the regulations. The regulatory scenario is the future regulatory framework when these regulatory amendments come into force.

Baseline scenario versus regulatory scenario

In the baseline scenario, the skull, eyes, trigeminal and dorsal root ganglia, tonsils, and distal ileum from cattle over thirty months of age (OTM) and distal ileum from UTM cattle are considered SRM. In all cases these must be handled according to strict SRM-specific regulatory requirements. They cannot be used in livestock feed, fertilizer, or pet food.

In the regulatory scenario, the proposed regulatory amendments would enable slaughter and processing establishments to handle eligible SRM (i.e. the skull, eyes, trigeminal and dorsal root ganglia, tonsils, and distal ileum from OTM cattle and distal ileum from UTM cattle) as prohibited material (PM). Slaughter and processing establishments could save costs associated with SRM-specific regulatory requirements (e.g. segregation, staining, record keeping, and disposal) and could benefit from generating revenue by repurposing the SRM as PM. A permit would be required to handle the skull, eyes, trigeminal and dorsal root ganglia, tonsils, and distal ileum from OTM cattle as PM. The distal ileum from UTM cattle and UTM deadstock could be handled as PM by all slaughter and processing establishments without a permit. Adoption of the proposed changes would be optional. Slaughter and processing establishments could choose not to adopt the changes and continue to handle eligible SRM as currently required under the Health of Animals Regulations.

Table 1: Eligible SRM requirements in the baseline versus regulatory scenario
Baseline scenario Regulatory scenario
The following tissues are considered SRM:
  • the skull, eyes, trigeminal and dorsal root ganglia, tonsils, and distal ileum from OTM cattle
  • distal ileum from UTM cattle
  • the brain and spinal cord from OTM
 The following tissues are considered eligible SRM (ESRM):
  • the skull, eyes, trigeminal and dorsal root ganglia, tonsils, and distal ileum from OTM cattle
  • distal ileum from UTM cattle
The brain and spinal cord from OTM remain SRM in all cases (i.e. are not considered eligible SRM).
Slaughter and processing establishments must follow the SRM-specific regulatory requirements (e.g. segregation, staining, record keeping, transportation and disposal) when handling the skull, eyes, trigeminal and dorsal root ganglia, tonsils, and distal ileum from OTM cattle and distal ileum from UTM cattle.

Slaughter and processing establishments may apply for a permit to handle the skull, eyes, trigeminal and dorsal root ganglia, tonsils and/or distal ileum from OTM cattle as PM and would therefore be exempt from certain SRM-specific regulatory requirements (e.g. segregation, staining, record keeping, transportation and disposal). Only the PM-specific regulatory requirements would apply.

All slaughter and processing establishments may handle the distal ileum from UTM as PM and would therefore be exempt from certain SRM-specific regulatory requirements related to this tissue. No permit would be required.

UTM deadstock are considered SRM in its entirety.

UTM deadstock can only be disposed of as PM if the SRM tissues have been harvested from the deadstock under a permit.

 UTM deadstock could be considered PM in its entirety. No permit is required to handle the deadstock as PM.
The skull, eyes, trigeminal and dorsal root ganglia, tonsils, and distal ileum from OTM cattle and distal ileum from UTM cattle cannot be used in feed, fertilizer, or pet food. The skull, eyes, trigeminal and dorsal root ganglia, tonsils, and distal ileum from OTM cattle and distal ileum from UTM cattle may be used in non-ruminant feed, fertilizer or pet food. A permit would be required.
Feed, fertilizer, and pet food that contains the skull, eyes, trigeminal and dorsal root ganglia, tonsils, and distal ileum from OTM cattle and distal ileum from UTM cattle cannot be imported into Canada. Feed, fertilizer, and pet food that contains the skull, eyes, trigeminal and dorsal root ganglia, tonsils, and distal ileum from OTM cattle and distal ileum from UTM cattle may be imported into Canada.

Description of benefits and costs

Monetized benefits for industry
Reduction in SRM disposal costs

Slaughter and processing establishments that adopt the proposed changes would benefit from a significant reduction in costs associated with SRM requirements such as staining, handling, record keeping, transportation and disposal. Slaughter and processing establishments purchase cattle from producers, slaughter and process the meat, and subsequently sell or dispose of the meat and by-products. They are responsible for the removal of SRM and PM, and bear the costs associated with SRM and PM removal and disposal. Under the proposed regulatory changes, all SRM and PM that are currently required to be removed from cattle would still be required to be removed and as such are not costs attributable to these regulations. There would be no change in the total volume of SRM and PM removed. However, slaughter and processing establishments would be able to apply for a permit to categorize ESRM as PM at the point of separation, and therefore would avoid the strict staining, handling, record keeping, transportation and disposal requirements and costs associated with SRM. Slaughter and processing establishments may still have to pay a renderer a fee to dispose of their PM, but it may be a lower fee than they would pay for SRM disposal. ESRM accounts for 99% of the total weight of SRM removed by slaughter and processing establishments in the baseline scenario.

Revenue generated from repurposing eligible SRM as PM

Slaughter and processing establishments that adopt the proposed changes may benefit from increased revenue. Tissue that they once paid a fee to dispose as SRM may be able to be sold as PM. Disposal of PM could represent a new revenue stream if a slaughter or processing establishment is able to find a customer willing to pay for the PM (e.g. renderer, feed/fertilizer/pet food manufacturer), rather than charge a fee to collect and dispose of it. For example, under the existing requirements, it currently costs one slaughter establishment $0.10 per kilogram to dispose of the vertebral column as SRM via landfill. With the proposed regulatory changes, this material could generate a potential revenue of $4 per kilogram if it is sold to pet food manufacturers as PM.

Qualitative benefits for industry
Stronger cattle market

In the regulatory scenario, cattle producers would benefit indirectly from savings further down the supply chain. Slaughter and processing establishments would directly benefit from the proposed changes, which enhances their competitiveness and capacity to operate sustainably. Slaughter and processing establishments bid on cattle and determine the cattle market and cattle price. A financially stable and competitive processing sector strengthens demand for cattle, helps stabilize market conditions, and may contribute to higher cattle prices over time. Increased participation by slaughter and processing establishments in the cattle market expands bidding competition, supporting stronger cattle prices and improved economic outcomes for producers.

Reduced UTM deadstock disposal costs

Cattle producers may also benefit from reduced UTM deadstock disposal costs, as they would be able to dispose of UTM deadstock as PM in its entirety instead of as SRM in the baseline scenario.

Expanded access to ingredients for feed, fertilizer and pet food manufacturers

Feed, fertilizer and pet food manufacturers would benefit from expanded access to feed ingredients containing ESRM from both Canadian and international markets. In the baseline scenario, feed, fertilizer and pet food manufacturers cannot use tallow and meat and bone meal (MBM) derived from cattle that include ESRM. This means that Canadian manufacturers cannot import and use U.S. cattle-derived tallow and MBM. In the regulatory scenario, feed, fertilizer and pet food manufacturers may benefit from using lower-cost tallow and MBM from the U.S. and other markets in Canadian non-ruminant feed, fertilizer and pet food.

Qualitative benefits for Canadians
Wider variety of feed, fertilizer and pet food

Consumers may benefit from a wider variety of cattle-derived feed, fertilizer and pet food on the market. For example, non-ruminant livestock producers may benefit from access to feed and feed ingredients containing ESRM (cattle-derived ingredients would still be banned from ruminant feed). In the regulatory scenario, U.S. non-ruminant feed, fertilizer and pet food containing cattle derived tallow and MBM could be imported and sold in Canada.

Strengthening Canada’s beef supply chain

This proposal would significantly reduce red tape and costs for slaughter and processing establishments that play a central role in Canada’s beef industry. Improving the profit margins and economic viability of the slaughter and processing sector helps them compete and contribute to a strong beef sector across the country. This in turn supports domestic food security and stable beef prices for Canadians.

Monetized costs for industry
Implementation costs for slaughter and processing establishments

Slaughter and processing establishments that adopt the proposed changes would incur costs associated with familiarizing themselves with the changes, applying for a permit to handle eligible OTM SRM as PM, updating operating procedures and preventative control plans, and training staff on the regulatory and operational changes. For most processors, these changes will be minor, and they are already familiar with the SRM permit system, so the time required to apply for a new permit is minimal. Some establishments that intend to remove the brain from the skull may choose to purchase equipment for removal and verification of the brain (e.g. vacuum and skull splitter or saw) and may require staff to operate the equipment.

Loss in business for SRM-only renderers

There is one renderer in Canada that only processes SRM and deadstock. This renderer would face a decrease in profit as a result of the proposed changes, as they only process SRM. As the volume of SRM sent to this renderer for disposal would significantly decrease, this is likely to result in significant revenue losses (unless they adapt their business model). All other renderers in Canada process both SRM and PM and the loss in profit from SRM disposal would largely be offset by the increase in PM disposal.

Monetized costs for CFIA
Upfront implementation costs

The CFIA would incur upfront implementation costs associated with this regulatory amendment. The upfront implementation costs will largely be incurred before final publication of the regulatory changes and would include developing guidance materials for animal health, slaughter and feed inspectors, developing and delivering training to animal health, slaughter, and feed inspectors, developing and delivering information sessions for industry, developing and implementing the new permit (policy, guidance, and form), and updating health certificates with trading partners. This upfront-work and associated costs can be done within existing resources.

Ongoing incremental costs

The CFIA may experience minor ongoing costs, which can be done within existing resources. The minor ongoing costs would be limited to ongoing maintenance of the framework for documenting and demonstrating Canada’s BSE risk status (the BSE Health Status Program) and supporting guidance materials, administering the permitting regime (including reviewing permit applications and permit-related communications), reviewing and assessing updated preventative control plans (PCPs), and responding to inquiries. The CFIA currently processes approximately 1 500 SRM permit applications and renewals per year in the baseline scenario. The number of new SRM permit applications resulting from this proposal depends on industry adoption. An estimated 92 new SRM permit applications are anticipated under the proposed changes. There will also be a decrease in SRM permit applications related to UTM cattle and deadstock. Overall, the costs to the CFIA to process the additional permit applications are expected to be minimal.

No incremental inspection, compliance, or enforcement costs are anticipated, as existing resources would continue to be used, and the CFIA would maintain a risk-based approach to compliance and enforcement.

Qualitative costs for industry
Adaptation costs for renderers

Renderers would incur short-term costs associated with adapting their operations to a lower volume of SRM and a higher volume of PM (e.g. updating operating procedures, material handling and transportation planning, decommissioning SRM equipment). Renderers would see an increase in the volume of PM they receive from slaughter and processing establishments, and a decrease in the volume of SRM. This shift in volume from SRM to PM depends to what extent the upstream slaughtering and processing establishments would send them either SRM or PM. The proposed regulatory amendments introduce no new regulatory requirements for renderers. Their only direct cost benefits are related to the change in PM and SRM volume. The reduction in SRM volume may be significant enough for some renderers that they may decide to decommission their SRM rendering lines or facilities, as they would no longer be economically viable.

Increased cost of disposal for remaining SRM and OTM deadstock

The proposed changes may result in increased disposal costs for the remaining SRM tissues and OTM deadstock. The significant reduction in SRM volume may cause renderers to decommission their SRM rendering lines. The only other disposal method for SRM and deadstock is permitted landfill sites. Landfill is significantly more expensive than rendering and may be the only disposal option for SRM and deadstock if renderers decommission their SRM rendering operations. SRM rendering services are also for deadstock from humane societies, other livestock producers, including euthanized horses, depopulation of flocks and herds due to disease outbreaks, university research programs, rollovers of livestock trucks, and other emergencies.

Displacement of domestic MBM

In the baseline scenario, the current EFB prevents Canadian import of products that contain ESRM. This means that Canadian companies and customers cannot import tallow, MBM, feed, fertilizer and pet food from the U.S. or other countries that permit the use of ESRM. Under the proposed amendments, non-ruminant feed, fertilizer and pet food would be able to contain ESRM. This means that Canadian businesses would be allowed to import tallow, MBM, non-ruminant feed, fertilizer and pet food that contain ESRM, including from the U.S. Canadian renderers would likely face new competition in the domestic market from increased imports of cattle-derived tallow and MBM from competitors, including the U.S. Renderers may need to decrease the price of cattle-derived tallow and MBM due to increased trade and competition from international markets like the U.S. U.S. MBM costs 20% to 40% less than Canadian MBM but would be costly to ship into Canada. Renderers cannot predict the potential displacement of Canadian MBM or decrease in price of Canadian MBM. A decline in tallow and MBM prices may reduce revenues for renderers and may require renderers to increase their PM and deadstock collection fees to offset the decrease in revenue from tallow and MBM.

Displacement of domestic feed, fertilizer, and pet food

Under the proposed amendments, Canadian feed, fertilizer, and pet food manufacturers may face increased competitive pressure from imported products containing cattle derived ingredients. Currently, Canada prohibits the import of feed, fertilizer, and pet food containing ESRM, which effectively restricts imports from countries such as the U.S. that permit the use of ESRM in these products. As a result, Canadian manufacturers operate in a more protected domestic market. The proposed amendments would allow feed, fertilizer, and pet food to contain ESRM, enabling products manufactured in countries that permit its use to be imported and sold in Canada. This change could lead to the displacement of some domestically manufactured products, potentially affecting market share, pricing, and profitability for Canadian producers.

Qualitative costs for Canadians
Theoretical risk from secondary exposure pathways

The proposed changes would result in, at most, a negligible increase in BSE risk. This risk is considered very low, given the sustained and substantial reduction in BSE prevalence in Canada, which has significantly diminished the likelihood of disease transmission through secondary exposure pathways. Under current conditions, the residual level of risk is disproportionately small relative to the ongoing costs of existing risk abatement measures in the baseline scenario. While the impact of BSE cannot be ignored due to its link to vCJD, the proposed changes would not increase risk, as they apply solely to secondary exposure pathways and would not affect ruminant feed prohibitions, which would remain fully in place. In contrast, maintaining the broad prohibitions under the EFB continues to impose relatively high compliance and operational costs that are no longer commensurate with the current level of risk.

Methodology

The benefits and costs for industry are dependent on the uptake of the proposed changes. Adoption of the proposed changes by slaughter and processing establishments would only occur if participating companies anticipated net benefits from the proposed changes. It would be a business-specific decision dependent on several factors (e.g. current SRM and PM disposal costs and SRM and PM disposal options in their region, and anticipated demand for SRM and PM material). To determine the anticipated benefits and costs, the CFIA surveyed federally and non-federally inspected slaughter and processing establishments, renderers, and pet food, feed and fertilizer industry associations to estimate adoption of the proposed changes and to assess the direct and indirect impacts.

Slaughter and processing establishment survey analysis

The CFIA surveyed 10 federally inspected slaughter establishments, which collectively account for approximately 80% of total cattle slaughter in Canada. Of the respondents, two establishments indicated that they would fully adopt the proposed changes, including repurposing all ESRM as PM, which would require separating the brain from the skull. Seven establishments anticipated partial adoption, limited to repurposing the dorsal root ganglia, vertebral column, and distal ilium of OTM cattle, as well as the distal ilium of UTM cattle. These respondents did not anticipate implementing any additional measures to remove and repurpose the brain, skull, eyes, tonsils, and trigeminal ganglia from OTM cattle. One establishment indicated that it did not plan to adopt any of the proposed changes. Respondents also provided facility-level estimates of anticipated costs and benefits associated with adoption.

Although the 10 surveyed federal slaughter establishments represent a significant share (80%) of national slaughter volume, there are a total of approximately 640 slaughter and processing establishments in Canada that slaughter beef. Approximately 20 are federally inspected slaughter establishments, 400 are non-federally inspected slaughter establishments, and 220 are processing establishments. The non-federal inspected slaughter establishments are smaller than the federally inspected slaughter establishments, with 98.9% being small businesses. Based on the current industry structure and existing permitting requirements, the CFIA estimates that approximately 81 of the 620 smaller slaughter and processing establishments and 11 of the federally inspected slaughter establishments would apply for a permit to repurpose some OTM SRM as PM. The remainder of slaughter and processing establishments would not adopt the proposed changes to OTM SRM, will not apply for a permit to repurpose OTM SRM as PM, and would continue to separate and dispose of OTM SRM as they did in the baseline scenario. The cost and benefit estimates provided by the 10 surveyed federal slaughter establishments were used to extrapolate the impacts for the other additional anticipated adopters.

In addition to 92 slaughter establishments expected to adopt changes related to OTM SRM, a larger number of establishments are anticipated to adopt changes related to UTM SRM, as these changes would not require a permit. These establishments would realize savings from avoided separation and disposal requirements for the UTM distal ilium. While these savings may be meaningful at the individual facility level, particularly for smaller establishments, they are expected to represent a relatively small proportion of the overall benefits of the proposal and were therefore excluded from the monetized net benefit estimate.

Downstream industry survey analysis

The CFIA also surveyed the majority of the SRM and PM renderers in Canada to estimate the impact of the proposed changes. Most renderers who process both PM and SRM anticipate some upfront, short-term costs associated with adapting their processes but stated that these costs are difficult to predict and dependent on a number of factors (e.g. adoption of proposed changes by the slaughter and processing establishments they service, availability and price of other disposal methods, market for MBM).

Impacted stakeholders

The stakeholders directly impacted by the proposed regulatory changes include federally and non-federally inspected slaughter and processing establishments, rendering establishments, and the CFIA. Information about the number of establishments within each stakeholder group was derived from internal data and survey responses. There are 2 non-businesses in the federally inspected slaughter establishment group — these are publicly funded research institutions.

Table 2: Directly impacted stakeholders by establishment type and business size.
Stakeholder group Non-business count Small business count Medium/large business count Total business count
Federally inspected slaughter establishments 2 8 12 20
Non-federally inspected slaughter establishments 0 396 4 400
Processing establishments table b2 note a table b2 note a table b2 note a 220
Rendering establishments 0 0 4 4
Canadian Food Inspection Agency 1 0 0 0
Table b2 note(s)
Table b2 note a

No business size data available for processing establishments.

Return to table b2 note a referrer
Assumptions and data sources
Monetized costs and benefits

Overall, the CFIA estimated that the net benefit of the proposed changes to industry and government would be $97.6 million total over 10 years in 2025 dollars. This equates to an annual net benefit of $13.9 million per year in 2025 dollars. The CFIA estimated that the total present value benefit of the proposed changes to industry would be approximately $102.0 million over 10 years, in 2025 dollars. The annualized benefit to businesses would be $14.5 million per year in 2025 dollars. Out of the $14.5 million per year in projected benefits to industry, approximately $6.2 million is new revenue generated from repurposing SRM and $8.3 million is compliance cost savings from avoided SRM disposal costs ($7.0 million) and avoided SRM control activities like staining tissues ($1.4 million). There is also a small administrative cost saving associated with avoided record-keeping costs. The estimated total present value cost of the proposed changes to industry would be approximately $4.3 million over 10 years, in 2025 dollars. The main costs to industry include the cost to purchase and operate new equipment to remove the brain from the skull for those who choose to do so, upfront costs to implement the changes, applying for a permit, and for renderers who only process SRM, the profit loss associated with a reduced volume of SRM. The estimated total present value cost of the proposed changes to the CFIA would be approximately $0.1 million over 10 years, in 2025 dollars. The main costs to the CFIA include animal health inspector time to attend information sessions and time to review, approve and answer questions about permits.

Cost-benefit statement
Table 3: Summary of monetized benefits and costs
  2026 2035 Total present value Annualized
Total benefits: $14,524,493.35 $14,524,493.35 $102,013,963.40 $14,524,493.35
To industry $14,524,493.35 $14,524,493.35 $102,013,963.40 $14,524,493.35
To Government $0 $0 $0 $0
Total costs: $1,049,011.75 $555,594.72 $4,396,182.41 $625,917.47
To industry $1,034,608.71 $539,982.42 $4,287,236.85 $610,406.08
To Government $14,403.04 $15,612.30 $108,945.57 $15,511.40
Net impact: $13,475,482.60 $13,968,898.63 $97,617,780.99 $13,898,575.88

Small business lens

There are a total of 644 Canadian businesses that may be directly impacted by these amendments. This includes 420 slaughter establishments, 220 processing establishments, and 4 rendering establishments.

Of the 420 slaughter establishments, 404 are considered small businesses. Over the next 10 years, the proposed amendments are expected to result in total administrative and compliance cost savings of approximately $6,660,300.56 across all businesses in present value, or $948,276.96 annualized. This translates into an average annualized net savings of $2,347.22 per small business. The savings are mainly associated with reduced disposal costs, reduced labour required to comply with SRM control requirements, and administrative savings (e.g. lower labour time for SRM record keeping). In addition, these small businesses could also receive new revenue from diverting ESRM tissues to non-ruminant feed, pet food and fertilizer industries.

Of the 220 processing establishments, it is unclear how many are small businesses; however, the impacts are expected to be minimal to them because most SRM is handled at slaughter establishments.

All of the rendering establishments are considered medium or large businesses.

Small business lens summary
Table 4: Benefits
Administrative or compliance Description of benefit Present value Annualized value
Compliance Cost savings from SRM disposal and control activities and revenue generated from diverted SRM tissues $6,749,451.76 $960,970.09
Total Total benefits $6,749,451.76 $960,970.09
Table 5: Costs
Administrative or compliance Description of cost Present value Annualized value
Administrative Permit application and familiarization with the regulations $13,370.07 $1,903.60
Compliance Upfront implementation $75,781.13 $10,775.91
Total Total costs $89,151.20 $12,693.13
Table 6: Net impacts
Amount Present value Annualized value
Net impact on all impacted small businesses [Total benefits minus total costs] $6,660,300.56 $948,276.96
Average net impact on each impacted small business [Net impact divided by number of impacted small businesses] $16,485.89 $2,347.22

One-for-one rule

The one-for-one rule helps control the administrative burden that regulations impose on business. Under the one-for-one rule, for every new regulation or regulatory amendment increases the administrative burden on businesses, it must be offset by an equal amount of administrative burden. The change in administrative burden across all businesses is monetized and reported in 2012 dollars, and the number of regulatory titles added or removed is counted. The one for one rule does not include a compliance burden, only an administrative burden on businesses. All values listed in this section are presented in 2012 dollars, discounted to 2012 at a rate of 7%.

The proposed regulatory amendments related would result in an incremental decrease in administrative burden on business. The proposal is considered a burden OUT under the rule, and no regulatory titles have been repealed or introduced. The amendments would result in an annualized administrative total cost savings of $1,175 (in 2012 dollars, discounted at 7% over 10 years) across the 640 businesses. The administrative savings stem from reduced labour hours for record keeping. The administrative costs are associated with costs to complete a permit application and familiarization with the regulatory changes. Overall, the administrative savings associated with reduced labour for record keeping are greater than the administrative costs associated with completing a permit application or familiarization with the regulatory changes, and there is an overall decrease in administrative burden stemming from the proposal.

The annualized administrative savings from reduced record keeping would be $1,818 per year, based on a savings of 189 hours and 22 minutes per year at a wage rate of $24.76 per hour.

The annualized administrative cost to the 12 federally inspected slaughter establishments and 80 non-federally inspected slaughter establishments to complete a permit application is estimated at $419 per year. This assumes it takes each business a half hour to complete the permit application at a wage rate of $39.32 per hour for federally inspected slaughter establishments and $21.10 per hour for non-federal slaughter establishments.

The annualized administrative cost for all 20 federally inspected slaughter establishments and 400 non-federally inspected slaughter establishments to familiarize themselves with the proposed changes would be $224 per year. This assumes it takes each business a half hour at a wage rate of $39.32 per hour for federally inspected establishments and $21.10 per hour for non-federal slaughter establishments.

Regulatory cooperation and alignment

The proposed regulatory amendments would support alignment with the U.S. Currently, the U.S. allows certain materials, such as the skull, the eyes, trigeminal and dorsal root ganglia, and tonsils from OTM cattle, and the distal ileum from cattle of all ages to be used for non-ruminant feed, fertilizer, and pet food. The proposed amendments would enable these same tissues to be handled as PM and to be used as inputs in non-ruminant feed, fertilizer, and pet food in Canada, thereby aligning with the U.S. approach. Both Canada and the U.S. prohibit SRM in food and ruminant feed.

A risk-based approach is consistent with practices in other negligible-risk jurisdictions. For example, Australia relies on its long-standing ruminant feed ban and negligible BSE risk status as its primary mitigation framework, permitting animal by-products (including tissues that would be considered SRM in Canada) to be used in non-ruminant feed and fertilizers, provided they are excluded from ruminant feed. Similarly, Brazil, which is also recognized by WOAH as having a negligible BSE risk, allows rendered cattle by-products in pet food and fertilizers, while prohibiting their use in ruminant feed, and permits the import and manufacture of pet food containing animal proteins from negligible risk countries. Japan, despite maintaining stringent SRM controls from human food, allows SRM to be rendered and diverted into non-food channels, including industrial and agricultural uses, under controlled conditions.

As of May 2025, 59 WOAH members hold a negligible BSE risk status. It is likely that other countries will modify their mitigation measures (e.g. the nature of their feed ban) to adapt to the BSE global epidemiological situation. For example, the EU has expressed that their current rules exceed 2023 WOAH standards, driving unnecessary product destruction, waste, costs, and limiting circular-economy opportunities. As a result, the EU has started the revision of their Transmissible Spongiform Encephalopathies (TSE) Regulations. It is, however, unlikely they would align their SRM-list with that of the U.S. or Canada, as their livestock industry practices and trade preferences are different.

Effects on the environment

In accordance with the Cabinet Directive on Strategic Environmental and Economic Assessment (SEEA Directive), a comprehensive strategic environmental and economic assessment has been conducted. Regulatory proposals subject to the Cabinet Directive on Regulation are exempted from the economic analysis elements of the SEEA Directive. The findings from the strategic environmental and economic assessment concluded that there are no significant impacts on the environment as a result of the amendments.

The proposal may result in minor positive environmental effects by reducing the volume of SRM requiring disposal, including energy-intensive disposal methods such as incineration. By enabling the controlled repurposing of eligible lower-risk SRM under existing regulatory safeguards, the amendments could improve material efficiency and reduce waste, while maintaining ongoing protections for human health and Canada’s food supply. These effects are expected to be limited in scale and do not constitute important environmental impacts under the SEEA Directive.

Gender-based analysis plus

The proposed regulatory amendments would directly impact slaughter and meat processing establishments that adopt the changes. The meat product manufacturing workforce is predominantly made up of male workers aged 25–54.

The CFIA expects that most indirect benefits would likely be concentrated in rural and peri-urban regions, where larger slaughter and processing establishments and rendering facilities are located, with additional spillover to nearby industrial hubs hosting feed and fertilizer manufacturers.

Cost savings for slaughter and processing establishments would strengthen the economic competitiveness of Canada’s cattle processing sector. A more competitive and resilient processing sector supports stable demand for cattle by enabling more establishments to bid on available animals, which, in turn, helps sustain prices for cattle producers over time. Strengthening the sector from producer to processor would also enhance the overall stability of the domestic beef supply chain, contributing to food security across Canada.

Consideration of food security

Food security and affordability were considered and assessed during the development of the regulations. The proposed changes are not expected to have direct impacts on food security or affordability because food safety rules would remain unchanged. There could be positive indirect impacts on food security through an increased availability of materials eligible to be used in feed and fertilizer. This could support an increase in the supply of agricultural inputs, contributing to stable domestic food production and domestic food security. The potential effects on food security will depend on the extent to which businesses adopt regulatory flexibility.

Implementation, compliance and enforcement, and service standards

Implementation

The proposed amendments would come into force on the date of registration.

The CFIA will continue to engage with and provide information to all stakeholders to ensure they are aware of upcoming regulatory changes. Outreach activities may include the development of guidance documents, webinars, presentations, and targeted meetings.

The proposed regulations would not require additional CFIA resources to implement, as the amendments would leverage the existing permitting authorities and operational processes within the current oversight framework.

As needed, the CFIA would engage with PT authorities to verify inspection presence and confirm eligibility when assessing whether a permit may be issued. Once a permit is granted, oversight and inspection responsibility would rest with the CFIA or the relevant PT authorities, as appropriate, and would be carried out through existing oversight activities.

Compliance and enforcement

CFIA would maintain existing compliance and enforcement tools and enforce the amended EFB requirements, including the permit-based framework established under the Health of Animals Regulations. Compliance would be assessed against permit conditions, regulatory requirements, and PCPs, including obligations related to segregation, traceability, authorized uses, transportation, record keeping, and final disposition of SRM.

Enforcement tools include written non-compliance letters, requests for corrective action, administrative monetary penalties, and, where warranted, control actions such as seizure, detention, recall, disposal, or removal from Canada. In serious or repeated cases, enforcement may include actions on registrations or prosecution under the respective Acts.

Contact

Dr. Martin Appelt
Executive Director
Terrestrial Animal Health Programs
Canadian Food Inspection Agency
1400 Merivale Road
Ottawa, Ontario
K1A 0Y9
Email: cfia.BSE_EFB_consult-ESB_IRAB_consulter.acia@inspection.gc.ca

PROPOSED REGULATORY TEXT

Notice is given that the Governor in Council proposes to make the annexed Regulations Amending Certain Regulations Relating to Harmonization of the Enhanced Feed Ban under

Interested persons may make representations concerning the proposed Regulations within 60 days after the date of publication of this notice. They are strongly encouraged to use the online commenting feature that is available on the Canada Gazette website but if they use email, the representations should cite the Canada Gazette, Part I, and the date of publication of this notice, and be sent to: cfia.BSE_EFB_consult-ESB_IRAB_consulter.acia@inspection.gc.ca.

Ottawa, July 6, 2026

Janna Rinaldi
Assistant Clerk of the Privy Council

Regulations Amending Certain Regulations Relating to Harmonization of the Enhanced Feed Ban

Health of Animals Act

Health of Animals Regulations

1 The Health of Animals Regulations footnote 1 are amended by adding the following after section 6.1:

6.11 In this Part, eligible specified risk material means any of the following specified risk materials:

2 Section 6.21 of the Regulations is amended by adding the following after subsection (1):

(1.1) Subsection (1) does not apply in respect of eligible specified risk material.

3 Section 6.22 of the Regulations is amended by adding following after subsection (3):

(4) Subsections (1) and (2) do not apply in respect of eligible specified risk material.

4 (1) The portion of subsection 6.23(1) of the Regulations before paragraph (a) is replaced by the following:

(1) Subject to subsections (3) and (4), this section applies to every person

(2) Paragraph 6.23(1)(a) of the French version of the Regulations is replaced by the following:

(3) Section 6.23 of the Regulations is amended by adding the following after subsection (3):

(4) This section does not apply in respect of eligible specified risk material.

5 Section 6.4 of the Regulations is amended by adding the following after subsection (7):

(8) Subsection (1) does not apply in respect of eligible specified risk material.

6 Section 6.5 of the Regulations is amended by adding the following after subsection (2):

(3) Subsection (1) does not apply in respect of eligible specified risk material that is fed to an animal other than a ruminant.

7 Section 171.1 of the Regulations is amended by adding the following after subsection (2):

(2.1) Subsections (1) and (2) do not apply in respect of eligible specified risk material.

(3) In this section, specified risk material has the same meaning as in section 6.1 and eligible specified risk material has the same meaning as in section 6.11.

Feeds Act

Feeds Regulations, 2024

8 Subparagraph 35(e)(i) of the Feeds Regulations, 2024 footnote 2 is replaced by the following:

Fertilizers Act

Fertilizers Regulations

9 Subsection 2(1) of the Fertilizers Regulations footnote 3 is amended by adding the following in alphabetical order:

eligible specified risk material
means any of the following specified risk materials:
  • (a) the skull, trigeminal ganglia, eyes, tonsils, dorsal root ganglia and distal ileum of cattle aged 30 months or older, if the materials have been completely separated, segregated and collected in accordance with a permit issued by the Minister under section 160 of the Health of Animals Regulations, and
  • (b) the distal ileum of cattle under 30 months of age, whether it has been removed from the carcass or is contained in the carcass; (matériel à risque spécifié admissible)

10 Subparagraph 9(a)(ii) of the Regulations is replaced by the following:

Food and Drugs Act

Food and Drug Regulations

11 Subsection B.01.047.1(3) of the Food and Drug Regulations footnote 4 is repealed.

Safe Food for Canadians Act

Safe Food for Canadians Regulations

12 Subsection 155(3) of the Safe Food for Canadians Regulations footnote 5 is repealed.

Coming into Force

13 These Regulations come into force on the day on which they are registered.

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