New Requirements for Imports of Food Products Containing Small Amounts of Meat, Poultry, or Processed Egg Product Ingredients

Issue 33, April 15, 2009

The U.S. Animal and Plant Health Inspection Service (APHIS) has informed U.S. Customs and Border Protection (CBP) that an import permit will now be required for all FSIS-exempted food products containing small amounts (less than two percent) of meat and/or poultry ingredients. Products such as bouillon cubes, extracts, and soup mixes, which have previously gained entry solely under a health certificate indicating product being concentrated by boiling, will now also require a U.S. Department of Agriculture (USDA) import permit. CBP enforcement of this USDA administrative change is scheduled to start on June 22, 2009.

While Food Safety and Inspection Service (FSIS) statutes provide authority to exempt certain foods containing relatively small amounts of meat, poultry or processed egg product ingredients from FSIS inspection, FSIS states they must ensure that these ingredients are not adulterated. Accordingly, the meat, poultry, or processed egg product ingredients used in FSIS-exempted products must be confirmed to be from an eligible source, i.e., prepared under USDA/FSIS inspection or in a foreign establishment certified by a foreign inspection system approved by FSIS. Importers of FSIS-exempted products originating from countries with animal health restrictions must apply for and obtain a VS-permit from APHIS.

Any new permit application submitted to APHIS after June 22, 2009, will be reviewed by FSIS to ensure the meat or poultry ingredient originates from an eligible source. The importer must provide FSIS the supporting documentation necessary to allow the food product to enter the United States. If this condition is not met, the imported food is ineligible for importation into U.S. commerce. APHIS warns that ineligible products found in commerce may be subject to destruction.

Questions for APHIS may be directed to Dr. Christopher Robinson at Christopher.c.robinson@aphis.usda.gov or at phone number (301) 734-3277.

Questions for FSIS may be directed to FSIS at the following email address: permits@fsis.usda.gov or at toll free number 1-888-287-7194.

Additional information may also be found on the APHIS website at http://www.fsis.usda.gov/Regulations_&_Policies/Imported_Food_Products/index.asp

Regards,

Paul E. Vroman
Manager, Regulatory & Compliance Consulting and Projects
DHL Global Forwarding