Export lists can be a useful tool for foreign food safety authorities to verify that commodities exported from the United States originate from a trusted source. These lists serve as an unofficial “certification” that the included establishments comply with U.S. food safety regulations or have claimed compliance with the importing country’s regulations. Certain countries require that exporters of specific food products appear on FDA’s export lists before those products may enter the market. Dairy exports to China, Chile, and the European Union are subject to this requirement, for example. Other shipments that require listing include collagen and gelatin exports to the European Union; infant formula exports to China; and seafood exports to China and the European Union.
FDA’s Export Listing Module (ELM), launched in July of this year, aims to streamline the process of adding establishments to export lists. The ELM receives and processes requests from companies that wish to be included on FDA’s export lists. The ELM is a replacement and expansion of FDA’s Dairy Listing Module (DLM), which previously facilitated the maintenance of the lists of eligible exporters of dairy to the European Union, China, and Chile.
Companies may request to be listed through the ELM at any time, but FDA updates the lists on a quarterly basis. For this reason, it’s a good idea for firms that are subject to listing requirements to request inclusion as early as possible. Even after FDA has updated the lists, the final listing decisions are made by the importing country’s competent authority. It’s important to note that products produced or shipped before official listing may be detained or rejected. Firms already appearing on FDA’s export lists are required to provide information through the ELM by June 15, 2019, in order to remain on the lists.
Navigating FDA’s systems can be burdensome. If your firm is subject to importing country listing requirements, let us help you request inclusion on the applicable export lists. Contact us today for more information.
