The Food Safety and Inspection Service (FSIS) of the United States Department of Agriculture’s Directive 7120.1 will result, we expect, in a negative impact on trade at least related to the importation of catfish.
FSIS’s 126-page directive is entitled the “Safe and Suitable Ingredients Used In The Production of Meat, Poultry, and Egg Products” (“Directive”). The Directive updates lists of substances and approved On-Line Reprocessing (OLR) and Off-Line Reprocessing (OFLR) antimicrobial intervention systems. You can find the Directive here.
USDA is starting to apply this Directive to Catfish
Although we have not seen the full impact of this Directive, we are already starting to see some of its effects with respect to FSIS implementation of its programs covering imported Siluriformes (e.g., Catfish, Swai, Basa and others). FSIS recently started detaining shipments of catfish treated with tasteless smoke (carbon monoxide) citing its own list, and noting FDA has not previously reviewed the use of CO treatment for catfish or other Siluriformes species. We expect there to be an increase in Customs rejection of entries in the near future for all those shipments that are being transported by shipping lines.
We are discussing the issue with FSIS and FDA. In the meantime, Importers, Customs brokers, Freight Forwarders and Carriers should review the Directive and monitor its implementation in the next few weeks. We will continue to monitor the impact that the Directive will have on trade. For questions and concerns regarding this information please contact us.
