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The short answer
To import frozen fish from Nigeria you need a Safe Food for Canadians licence to import and a written preventive control plan that identifies the hazards, sets controls, monitoring, corrective action and verification, and, as an importer, shows how your Nigerian processor's controls give at least the same protection as Canadian rules. You must also give import information before or at the time of import, keep lot-level traceability records and maintain a recall procedure tested every 12 months.
Frozen catfish, croaker, tilapia and shrimp from Nigeria have a loyal customer base among West African shoppers in Canada. Fish is one of the more demanding foods to import: it is perishable, temperature-sensitive and, under the Safe Food for Canadians Regulations (SFCR), it sits within the same licence and preventive control framework as other foods, with some fish-specific provisions. This article focuses on the plan you need to write, because that is where most first-time importers struggle.
The licence and the basic rules
SFCR section 5(2) prohibits importing food without a licence, and section 33 says a licence lasts two years from issue or renewal. The regulations define fish broadly, including shellfish, crustaceans and other marine animals. Section 11 requires imported food to meet a standard that provides at least the same level of protection as the Canadian requirements in sections 47 to 81. Whether you need the licence at all is covered in do you need an SFC licence to import Nigerian food; for frozen fish sold on, you will.
Section 13 requires you to give the import information, including your name and address, the first destination in Canada, and the common name and quantity of the fish, before or at the time of import. For live or raw shellfish, the foreign establishment's registration or identification number is also required. If further inspection is required, section 14 says the food must be kept at that first destination until the inspection is completed.
What the preventive control plan covers
Section 86 requires a written preventive control plan (PCP) for each licensed activity, and section 89 sets the content. For a frozen fish importer, that translates into the following sections:
- Hazard analysis. Biological, chemical and physical hazards for each species and product form: for frozen fish, think temperature abuse in transit and storage, contamination at processing, and chemical residues.
- Control measures and critical control points. For frozen product, temperature is central: the product must arrive frozen solid and stay frozen.
- Critical limits. The temperature and condition you accept on arrival, written as numbers in your plan.
- Monitoring. Who checks container temperature records and product temperature on arrival, how often, and where it is recorded.
- Corrective action. What you do with a lot that arrives partly thawed: hold, assess, reject or destroy, and how you record it.
- Verification. How you confirm the plan works: reviewing records, periodic product testing, supplier reviews.
- Importer requirements (section 89(4)). How you know the Nigerian processor meets the section 11 standard: supplier approval, its food safety programme, specifications, and the documents that come with each shipment.
Section 86(3) narrows the plan for licence holders with food gross sales of CAN$100,000 or less, and section 89(2) says supporting documents are kept for two years.
Traceability and recall
Section 90 requires a lot code or other unique identifier and the names and addresses of the people you bought from and sold to. Section 84 requires a recall procedure with named contacts, a recall simulation at least every 12 months, and immediate notice to the Minister if a recall is needed because of a health risk.
The Nigerian export side
Your supplier needs its own papers before the fish leaves. NAFDAC's export guideline lists a Health Certificate for processed and semi-processed food, sets out the documents an exporter submits, and gives a total processing time of 28 working days from document vetting through inspection and laboratory work. It also says NAFDAC does not issue certificates for products that have already left Nigeria, so the certificate must be issued before shipment. The supplier will also complete the CBN's Form NXP for the export; see Form NXP and export proceeds rules.
Ask CFIA, or check its import reference tools, whether fish from Nigeria needs any additional certification or foreign establishment listing for your species and product form. We could not open CFIA's current fish import pages for this article.
Worked example: a temperature log check
Example only: your plan sets a critical limit that product must be frozen solid with no sign of thawing and refreezing. A 20-foot reefer arrives with a data-logger showing a six-hour gap during transhipment. Your corrective action says: hold the lot, check core temperature of samples from the door end and the back, record results, and release only if every sample meets the limit. Two of ten samples show signs of thaw and refreeze, so the lot is rejected and the supplier and insurer notified in writing.
Where Pryme fits
Nigerian fish processors often invoice in naira or dollars and want part payment before loading. A Pryme business account gives your business NGN and USD account details, and the Finance agent can prepare the balance payment once your arrival checks pass, for a person to approve. For other fish products, see bringing stockfish and dried fish into Canada.
Questions people ask
Do I need an SFC licence to import frozen fish from Nigeria?
Yes in most cases. The Safe Food for Canadians Regulations prohibit importing food without a licence, and fish is included.
What must a preventive control plan cover for imported fish?
Hazards, control measures, critical limits, monitoring, corrective action and verification, plus how your Nigerian supplier meets Canadian-level protection (section 89(4)).
How long do I keep import records under the SFCR?
Section 89(2) says plan supporting documents are kept for two years; recall records are also kept for two years.
What certificate does a Nigerian fish exporter need?
NAFDAC's export guideline lists a Health Certificate for processed and semi-processed food, issued before the goods leave Nigeria.
Sources
- Justice Laws: Safe Food for Canadians Regulations, SOR/2018-108 · accessed Oct 2026
- NAFDAC: Guideline for export of regulated products (2018) · accessed Oct 2026
- Mondaq (Deloitte): CBN introduces e-Form NXP (14 Nov 2019) · accessed Oct 2026
This article is general information, not financial, legal or tax advice. Products described are provided under the terms on this site and are subject to regulation and eligibility.