FSIS Says Small Amounts of Meat/Poultry/Eggs in Products Not Needing APHIS Permit Must Still be from Approved Source
The Food Safety and Inspection Service is advising importers that the meat, poultry, or processed egg product ingredients used in the formulation of products that can enter the U.S. without the APHIS veterinary permit VS Form 16-6A (because they are not from animal disease countries, etc.,1) must still originate from an approved source in order to qualify for FSIS import eligibility.
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FSIS sources state that affected products include products with small amounts of meat, poultry, or egg products (less than 2%) and are generally dehydrated products or extracts such as bouillon cubes, stocks, and dehydrated soup mixes or extracts.
(See ITT's Online Archives or 06/19/09 news, 09061910, for BP summary of APHIS' new requirement that small amounts of meat/poultry from an animal disease country must have their source approved by FSIS before APHIS issues its permit.)
Approved Sources Prepare Ingredients under FSIS/Equivalent Inspection System
To be from an approved source, the meat, poultry or processed egg ingredient must have been prepared under FSIS inspection or in a certified establishment operating in a foreign inspection system found to be equivalent by FSIS. See below for link to FSIS' list of countries/establishments eligible to export meat, poultry, or egg products.
FSIS May Require Documentation to Support Claimed Origin or Detain Product
As FSIS monitors imported food products at U.S. ports of entry and in-commerce to ensure that they contain eligible meat, poultry, and processed egg product ingredients, it may request that importers provide documentary evidence to support the origin of small amounts of meat, poultry, and processed egg product ingredients in their product.
If the supporting documentation is insufficient for FSIS to make a determination of eligibility, the importer will need to provide additional evidence of the source. Imported food products without sufficient documentation will be detained by FSIS pending receipt of adequate source evidence.
Must Identify Percent of Meat/Poultry/Eggs, Country of Origin, Establishment, Etc.
Supporting documentation can take various forms, but at a minimum, FSIS will need information that:
identifies the proportion/percentage of the meat or poultry product ingredients in the product formulation of the finished food product;
identifies the country of origin of these ingredients;
identifies the establishment (name and address and establishment number) where the ingredients were prepared;
provides assurance that no other meat or poultry, product ingredient is incorporated into the finished product;
evidence that the product labeling does not represent the finished product as a meat or poultry product; and
identifies the establishment (name, address and country of origin) where the finished product was prepared.
FSIS & APHIS Working Together to Ensure Both Agencies' Requirements Met
FSIS recognizes that APHIS issues veterinary permits for many, but not all imported food products containing a small amount of meat, poultry or processed egg product ingredients. The need for a permit is based on the contents of the food product and on the animal health restrictions, if any, APHIS places on the country from which the food product is being imported.
The issuance of APHIS permits is one means by which FSIS becomes aware of the importation of food products containing a small amount or meat, poultry, and processed egg product ingredients. In that regard, FSIS and APHIS are working together to ensure that the import requirements of both USDA agencies are met.
(APHIS regulates products of animal (and plant) origin to ensure they do not pose a disease risk to U.S. animal (and plant) health, while FSIS regulates meat, poultry, and processed egg products for public health purposes.)
1VS Form 16-6A is APHIS' "Veterinary Permit for Importation and Transportation of Controlled Materials and Organisms and Vectors" such as those from countries APHIS considers to be affected with animal diseases of concern; and VS Form 16-3 is the application for this permit.
(See ITT's Online Archives or 04/22/09 news, 09042210, for BP summary of APHIS changing its import permit process for products containing small amounts of meat/poultry from an animal disease country.)
FSIS notice (dated 09/25/09) available at http://www.fsis.usda.gov/pdf/Imported_Food_Products_Notice_to_Importers.pdf
FSIS list of countries/establishments eligible to export meat, poultry, egg products to U.S. (last updated 10/01/08) available at http://www.fsis.usda.gov/regulations/Eligible_Foreign_Establishments/index.asp