We spend a great deal of energy in this country worrying about imported food. FSMA gave FDA the Foreign Supplier Verification Program, which makes the American importer responsible for confirming that a foreign supplier produces food in a way that meets our standards. We keep import alerts. We detain shipments without physical examination. The premise behind all of it is that food grown somewhere else deserves an extra look before it reaches an American table.
Canada applies that same premise to us, and the commodity it applies it to is romaine lettuce grown in California.
What Canada requires
The Canadian Food Inspection Agency maintains a page titled Temporary import requirements for romaine lettuce from the United States. The 2026 edition takes effect September 24 and runs through December 17. The conditions are imposed under section 20(3) of the Safe Food for Canadians Act, which allows the Minister to attach conditions to a licence.
The reason is stated plainly at the top of the page. Romaine imported from the United States has been associated with several E. coli O157:H7 outbreaks in Canada and the United States, and American investigations have identified a recurring geographic source: the Salinas Valley counties of Santa Cruz, Santa Clara, San Benito and Monterey.
If the lettuce comes from anywhere else in the United States, the importer must hold a proof of origin, meaning a signed and dated letter on the exporter’s letterhead naming the state and county of harvest. If it comes from those four counties, or if no proof of origin exists, the importer has to do more.
This is the seventh consecutive fall. The first round ran October 7 through December 31, 2020, and CFIA has renewed the conditions every harvest season since.
Why Canada did it in the first place
Canadians were among the sick.
In the 2017 outbreak, the Public Health Agency of Canada counted 42 cases across five eastern provinces, 17 hospitalizations and one death. Romaine was identified as the source. The cause of the contamination never was.
In the spring 2018 Yuma outbreak, eight Canadian illnesses were genetically similar to the American cases, reported from British Columbia to Quebec.
In the fall 2018 outbreak, FDA traced the lettuce to the Central Coast growing regions of northern and central California. PHAC noted that romaine grown in Canada, including hydroponic and greenhouse romaine, was not involved. CFIA imposed import controls during that outbreak and said it was reviewing control measures going forward. The seasonal rule is what came out of that review.
What changed for 2026
Until this year, a shipment from those four counties needed an attestation form and a Certificate of Analysis for every consignment, uploaded at the time of the import declaration. The testing protocol is not casual: 60 individual random sample units of 25 grams each, 1,500 grams per sampling lot, analyzed by a laboratory accredited to ISO/IEC 17025, with a presumptive positive treated as a positive unless confirmed negative within 24 hours.
Three things changed. The attestation form is gone. Supporting documents no longer have to be uploaded with the import declaration, and importers simply retain them and produce them if CFIA asks. And there is now an alternative to lot-by-lot testing.
An importer may instead obtain a letter confirming that the LGMA member supplying the lettuce participates in the California LGMA Romaine Test & Learn Program. The letter needs the member’s name, a date, a statement of participation, and a signature. CFIA says it may be obtained once at the beginning of the import period.
A season of shipments can now ride on one signed letter that nobody looks at unless something goes wrong.
CFIA gives its reason: the absence of reported E. coli O157:H7 outbreaks linked to romaine lettuce in recent years, together with strengthened control measures for Salinas Valley romaine.
The timing
That page was last modified July 23, 2026.
On September 10, 2026, FDA closed CORE investigation #1382 and named romaine lettuce as the vehicle in a 14-case E. coli O157:H7 outbreak. FDA had carried that file since July 1 with no food identified, and it identified one on the way out the door, with no grower and no processor named. I wrote about it yesterday.
CFIA’s stated premise for relaxing its rule was published six weeks before FDA acknowledged a 2026 romaine O157:H7 outbreak, and the season that rule governs had not yet begun when FDA acknowledged it.
I do not fault CFIA for failing to know in July what FDA would publish in September. That is the problem, not the excuse. A foreign regulator calibrating its controls on American lettuce can only work from what our agency publishes, and our agency published nothing until the file was closed.
What a participation letter is, and what it is not
Test & Learn is a good idea. LGMA launched it in July 2023 as a two-year study, folded it into the required food safety standards that September with audits starting in January 2024, and in August 2025 extended data collection through September 30, 2027 while adding a root cause interview for any member that submits a positive sample. Members’ pre-harvest and finished-product results are aggregated on Western Growers’ GreenLink platform. The model was borrowed, deliberately, from aviation safety data sharing.
But it is a data collection and analysis program. It is not a release test for a truckload. A letter confirming that a handler participates tells an importer something about the supplier’s program. It tells the importer nothing about the lettuce in the trailer. That is the trade CFIA made, and it made it with its eyes open, since the page lays both options out side by side.
A caution for Ottawa
There is one more thing the Canadians should hear, and I offer it as a friend of the rule they just relaxed.
CFIA’s stated reason was the absence of reported E. coli O157:H7 outbreaks linked to romaine lettuce in recent years. Read that sentence again, and put the weight where it belongs. Reported.
In November 2024, while CFIA’s temporary conditions were in force for that season, an E. coli O157:H7 outbreak tied to romaine lettuce sickened 89 people in 15 states. Thirty-six were hospitalized. Seven developed hemolytic uremic syndrome. One person died. FDA issued no public announcement while it was happening. Its first public mention of the outbreak was a line on the CORE table after the investigation was closed.
I spent the year after that prying the traceback summary loose. When the redactions finally came off, the file led to a single processor, Taylor Farms of California in Salinas, and a single grower, Anthony Costa & Sons in Soledad, which sits in Monterey County, one of the four counties on CFIA’s own list. Taylor Farms has denied that its product was the source. The documents are here.
Now put #1382 next to it. FDA posted that file on July 1, 2026 with no food identified, carried it that way for ten weeks, and named romaine on September 10 as it closed. Measured by CFIA’s test, there was no reported American romaine outbreak this summer, right up to the day there was, seven weeks after CFIA published its rationale.
A regulator in Ottawa scanning for reported American romaine outbreaks is scanning a feed whose contents FDA decides. The absence of reported outbreaks is not the same thing as the absence of outbreaks. It can just as easily be the absence of reporting.
The part that should sting
Set what the Canadian system asks of us against what our own system delivered this summer.
A Canadian importer has to be able to produce a document naming the state and the county where the lettuce was harvested. FDA closed a romaine outbreak without naming a grower, a processor, a county or a brand.
Canada tells its importers exactly which four California counties are the recurring problem. FDA’s handling of #1382 told American consumers nothing of the kind, and told them nothing at all until the investigation was over.
We ask the rest of the world to verify its suppliers before food crosses our border. A neighbor asks the same thing of us, and our answer this fall is a letter obtained once in September saying the grower is enrolled in a program.
I have been suing lettuce companies for nearly thirty years. The counties have not changed. The pathogen has not changed. What changes is how much the public gets told, and when.
If Canada wants to know whether the lighter touch was the right call, the thing to watch is not whether FDA announces a romaine outbreak. It is what shows up on the CORE table after the file is closed.
Recent Comments