Starting on August 2, USDA required all shipments of siluriformes (colloquially catfish)[1] fish and fish products’ to be presented to USDA’s FSIS for re-inspection. While FSIS will perform 100% “re-inspection” for all imported shipments, the agency does not intend to sample and test 100% of the shipments. FSIS will only sample some shipments, and for the rest, FSIS will most likely release it after a document review.
This started a month earlier than September 1, the date of full enforcement published in the final rule. FSIS was forced to speed up the process because Congress made a change in the Fiscal Year 2017 budget.
More Details on the Full Re-inspection Regime
Prior to this change, FSIS only had to re-inspect imported catfish on at least a quarterly basis. During this period, FSIS only selected a small portion of shipments that had to be sent to an FSIS inspection location. When FSIS selected a shipment for re-inspection, it conducted testing as well, such as for drug residues or pathogenic bacteria.
Starting on August 2, all the imported catfish shipments must be sent to an FSIS inspection location. Unlike before, product sent to an FSIS inspection house will not be automatically tested. Rather the re-inspection will commonly consist of verifying the paperwork and reviewing the labeling.
This is a significant change that has a major impact on supply-chains as the re-inspection process will impose additional time between arrival at the port and arrival at the distribution center. Failure to follow this process is significant: FSIS will require a recall for any imported product that “fails to present” for re-inspection.
Any failed to present catfish must be exported or destroyed.
A Comment on Labeling Compliance
With the catfish labeling enforcement date soon approaching on September 1, manufacturers and importers should remember to verify their labeling:
- Label declares “added solution” if the weight is increased from this added solution
- The immediate container label: name of product, country of origin, ingredients statement if there are two or more, foreign establishment number, handling statement, net quantity of contents, manufacturer’s or distributor’s name and address, nutrition labeling, and safe handling instructions
- The shipper container label contains: name of product, country of origin, foreign establishment number, handling statement, and shipping or identification mark.
Importers, manufacturers and foreign producers can turn to FDAImports.com for guidance. Our team of regulatory advisors and affiliated attorneys have years of experience helping companies navigate USDA regulations and get their product into the US marketplace. Contact us today.
[1] We using catfish colloquially as compared to the narrow definition contained in the law that limits the name to just “fish classified within the family Ictaluridae.”
