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Export Requirements

Vietnam Export Procedures

Firms desiring to export seafood products to Vietnam are required to be approved by the Vietnamese authority, NAFIQAD, prior to shipment. Once approved and listed on the NAFIQAD website firms must request an Export Health certificate from their local NOAA Fisheries Seafood Inspection Office (SIP).Products will be lot inspected prior to certification if the firm is not a participant in the HACCP QMP program with SIP.
In December 2011 NAFIQAD (the responsible Vietnamese government agency for receiving imports) audited the United States and its procedures for approving facilities to be on their list of establishments. A draft report came in February 2012.On March 2, 2012 a meeting was held with NAFIQAD in Hanoi and the Seafood Inspection program. The subject of the meeting was NOAA's response and questions regarding the draft audit report and conclusions from NAFIQAD's audit of the USA last December. A final report was issued from the audit in April 2012.All this documentation and discussion led to refinements of the Vietnamese requirements for listing Food Processing Organizations (FPOs) for shipment of seafood products to Vietnam. Those refinements follow:

In general, for being approved as a company eligible for exports of animal products to Vietnam by the Seafood Inspection Program, the company must provide all information described in the Appendix 3 (attached) (be sure to include the CFN or FEI number from FDA. The form must be signed by a representative of the company.

Send to Melissa.Beaudry@noaa.gov the completed Appendix 3 and an electronic version of the process flow diagrams for each of the products you want listed. Our agency will sign and stamp the documents and forward the hard copy to Vietnam. An email will also be sent to alert NAFIQAD the forms are on their way and they have agreed to begin processing at that point in order to minimize the time it will take to approve the listing. (If you are a broker only you are not required to be listed.)

All processors on the list must be an approved establishment in the Seafood Inspection Program if you want a certificate from our agency. If you are not we will give your firm until August 31 to participate. We will be glad to send any information needed to accomplish this.

Firms may check their status as to whether they are approved using the following link:
http://www.nafiqad.gov.vn/copy_of_list-company/fish-and-fishery-products-1/danh-sach-111uoc-cap-nhat-thuong-xuyen/

SIP personnel will use this link to ascertain if the firm has been approved. If the firm is not on this list they cannot issue an Export Health Certificate.

If there are any questions please contact Melissa Beaudry, Quality Officer at Melissa.Beaudry@noaa.gov or 301-427-8308.

Link to Appendix 3 form


Procedures for US Processors exporting fishery products to Brazil

In January, 2010, Brazilian Ministry, The Department of Fisheries and Aquaculture Control published aquatic health regulations on the fishery products into Brazil.  These new regulations are within the scope of their authority under OIE and WTO guidelines and are currently in effect. The Seafood Inspection Program (SIP) will continue to issue certification to those US facilities that have applied to be part of the USDC SIP program upon lot inspection and will give industry until December 30, 2011 to become a participant under the program.  The purposes of the new regulations are to protect wild and farmed resources and to maintain their health status in order for Brazil to export fishery products to the other countries.  Brazil will require importers in Brazil to obtain import permits prior to bringing seafood products into Brazil; US exporters to be under the US competent authority control; US exporters to submit prior facility approval; product shipments to have US competent authority documentation.
The Brazilian regulations request that the export certificates be bilingual with English/Portuguese text. This Regulation has been suspended until further notice. SIP will be requesting the approval of a bilingual certificate for US Exporters use until a Brazilian model is agreed upon and approved.

Impacts on US competent authority and exporters
The USDC NOAA Fisheries Seafood Inspection Program (SIP) is the competent US authority for aquatic health certification for wild-harvested seafood exports (live and products) intended for human consumption, as per MOU between NOAA Fisheries and USDA/APHIS.

For fishery products destined for Brazil, NOAA SIP has agreed to:

US Exporters will be required to follow the guidelines listed below for the exportation of fishery products to Brazil.

These requirements are the procedural points as agreed to by NOAA Fisheries through the US Embassy/USDA for Brazil during March 2012 meetings.

Follow these instructions to find an updated Approved List of US Exporters to Brazil:

http://sigsif.agricultura.gov.br/sigsif_cons/!ap_exportador_hab_pais_rep_net

Label Approval Packages can be requested from: Priscila.Ming@fas.usda.gov

Use the following instructions as guidance for completion of the Label Submittal processing.

Completing the Label Registration Package (Circular 42/2010) Annex I

Completing the Label Registration (Circular 42/2010) Annex III

All inspected product must have the SIP Export Health certification for Brazil prior to shipment. Questions regarding the status of label package reviews can be forwarded to Robert.Downs@NOAA.GOV


Procedures for US Processors exporting fishery products to the Russian Federation

Effective November 10, 2010 U.S. seafood firms in the supply chain desiring to produce, pack, store, or ship fish and fishery products for export to the Russian Federation must meet the requirements of the NOAA Seafood Inspection Program to be “approved establishments” in accordance with the regulations and policies of the NOAA Seafood Inspection Program.  Only establishments approved by the NOAA Seafood Inspection Program and subsequently approved by Rosselkhoznadzor, the Russian food safety agency, may receive certification from NOAA for export to the Russian Federation.  This export procedure is in required by Russian law and is in accordance with a Memorandum of Understanding approved by United States and Russian officials. 

Link to Federal Register Notice
Link to MOU

Any firm requesting an export health certificate for the Russian Federation must be listed on the Russian Federation website:

(http://www.fsvps.ru/fsvps/importExport/usa/enterprises.html?productType=7&_language=en)

and be an approved establishment with the NOAA Seafood Inspection Program:

http://www.seafood.nmfs.noaa.gov/Participants_List13.pdf

All operations within the supply chain for a specific lot of product being shipped to the Russian Federation, including vessels, storage warehouses, and processors, are to be approved establishments of the NOAA Seafood Inspection Program.  All supply chain points for a specific lot of product to be certified need not be listed on the Russian Federation website.  However the requestor of the certificate may only request certificates for products that have originated, been handled, or processed by firms that are on the List of approved establishments for SIP.  One exception exists, brokers, which may be listed on the Russian Federation site are not required to be approved establishments.  Brokers are still required to send products that have met all the requirements.

Firms desiring to be listed on the Russian site of approved shippers must follow the following procedures:

This is the information SIP has at the moment for the Russian Federation.  New Russian regulations are to be in force by January 1, 2012 and at this time it does not appear as if there will be any modifications to the MOU.  However there are a number of analytical tests performed by the Russian border inspection posts and at times there are issues related to these test results.  SIP will investigate any positive findings and report back to the Russian Federation.


Procedures for Export Health Certificates to the Republic of Korea

The Republic of Korea (ROK) requires Export Health Certificates for frozen cod heads, tuna heads, southern hake heads, visceral by-products such as edible fish roe, Pollock entrails, hard roe and the nidamental gland of squid.

Normal inspection procedures apply to these products, e.g. lot inspection, in-plant inspection or a current HACCP QMP system.  All frozen fish heads must be cut so the head with pectoral and ventral fins are attached and the frozen edible parts, e.g. meat from the neck, lower jaw and cheek, are included.

The ROK also requires that U.S. exporters be on a list of approved facilities.  Headquarters of the Seafood Inspection Program (SIP) has received an interim list from the US Food and Drug Administration of all seafood processors in good regulatory standing which will serve as our interim list until we are able to determine which firms actually export these products to ROK.  This list has been submitted to the Korean Ministry of Food, Agriculture, Forestry and Fisheries (MIFAFF). However to date we have not received word as to its acceptability or procedures to modify the list (add or delete list members).  Once this procedure is agreed upon between our two governments SIP will only provide certificates to those facilities.  Until that time certificates will be issued to all requestors under the conditions described above.


Requirements for Export to the People’s Republic of China

Fish Meal Inspection Program

Effective July 1, 2012 all fish meal, fish oil, and other aquatic animal proteins (used as feed and feed additives) to be exported from the United States to the People’s Republic of China (PRC) must meet the requirements of Administration of Quality Supervision Inspection and Quarantine (AQSIQ)  No. 118 Decree (copy attached).  According to this decree all manufacturing facilities that produce feed and feed additives must be registered with AQSIQ.  In order to be registered, a facility must participate in the NOAA Seafood Inspection Program (SIP) and be approved by SIP to export to the PRC.  Approval will only be given if all hygiene and quarantine requirements of the PRC for imports of fish oil, fish meal and other aquatic animal proteins are met.  Upon approval, the SIP will add the facility to the list of approved facilities provided to AQSIQ. 

SIP Requirements:
Facilities wishing to export fish meal, fish oil, and other aquatic animal proteins to the PRC must be under contract with SIP for at least 3 audits per year (for facilities storing product in bulk and exporting product outside of the fishing/production season the following is recommended: 1 audit prior to start of fishing season; 1 audit during the fishing season; and 1 audit after the close of the fishing season).  SIP regional offices and auditors will assure that all facilities are in compliance with AQSIQ requirements as well as the SIP Hazard Analysis Critical Control Point (HACCP) Program and Quality Management Program (QMP).  The facilities management controls and responsibilities; feed safety programs; sanitation and prerequisite programs; and quality systems will be audited according to the Policies, Procedures, and Requirements for the Approval of Facilities and Systems (available on the SIP website).  During each audit, a minimum of 5 verification samples collected randomly from multiple lots of finished product will be collected aseptically by SIP auditors and sent to the National Seafood Inspection Laboratory for Salmonella, Enterobactericeae, and Total Plate Count analyses.   Laboratory results from third party and in house laboratories will also be reviewed to determine compliance with the hygiene standards set by AQSIQ.

Laboratory Testing Requirements:

Product for export to the PRC must be in compliance with the PRC Hygiene standards listed below and be tested at the frequency indicated.  These tests may be performed by a third party laboratory that has been recognized by the National Seafood Inspection Laboratory as a laboratory accredited against ISO standards for the specific analyses being performed.

Hygiene Standards
Testing Requirements for Meal:
Mercury   < 0.5 mg/kg   Annual
Cadmium (Cd)  < 2.0 mg/kg   Annual
Lead   < 10 mg/kg Annual
Chromium (Cr)   < 8 mg/kg   Annual
Arsenic (As)  <  10 mg/kg Annual
Total count of mold <  20000 cfu/g Annual
Salmonella Not detected Each Lot/Consignment 
Shigella Not detected Annual
Enterobacteriaceae < 300 MPN/g Each Lot/Consignment
Total plate count < 2000000 cfu/g Each Audit
Melamine < 2.0 mg/kg Annual
Malachite green Not detected *
Dioxin < 1.25 ng/kg Annual
Testing Requirements for Oil:    
Salmonella Not detected **
Coli group < 300 MPN/g **
Malachite green Not detected *
Dioxin <  6.0 ng/kg  Each Audit

*Not required for wild caught fish.  For aquacultured fish, annual testing is required.

**The water activity of fish oil is too low to support the growth of bacteria, therefore microbiological testing of oil that has been properly heat treated is not required as long as processing CCPs are met.

 

Testing for ruminant protein:   For facilities that handle only fisheries products, PCR testing (by a laboratory approved by APHIS) for ruminant protein will be required annually.  For facilities that handle other animal proteins as well as fisheries products, PCR analysis for ruminant proteins will be required for each shipment of fish meal to the PRC.

 Verification Testing and Monitoring:  In addition to third party laboratory testing, verification sampling/testing and monitoring will be conducted in Federal Laboratories.  The National Seafood Inspection Laboratory (USDC) will analyze verification samples collected by SIP auditors for microbiological analysis including Salmonella, Enterobacteriaceae, Mold, and Total Plate Count.  Test results from the Food and Drug Administration’s Feed Contaminants Program, Feed Manufacturing compliance Program, Illegal Drug Residue Program, and BSE/Ruminant Feed Ban Inspections will also be used as additional verification of the safety and wholesomeness of the feed supply. www.fda.gov/AnimalVeterinary/GuidanceComplianceEnforcement/ComplianceEnforcement/ucm112583.htm

A list of FDA Regional Laboratories may be found at http://www.fda.gov/ICECI/Inspections/IOM/ucm124067.htm.  Verification testing for aquatic animal diseases and BSE will be done by USDA/APHIS approved laboratories http://www.aphis.usda.gov/animal_health/lab_info_services/approved_labs.shtml and http://www.aphis.usda.gov/animal_health/nahln/labs.shtml

Specific Requirements of the PRC:
A list of facilities approved by SIP will be provided to AQSIQ.  Facilities will be included on the list only if the following requirements are met:

Request for Export Certification:
Export certificates for product to be exported to the PRC will only be issued by SIP if the facility is approved for export based upon compliance with PRC requirements as indicated by audit reports and laboratory testing results.   The request for inspection and results from third party laboratories must be submitted via email to NMFS.SI.Fishmeal@noaa.gov prior to any export documentation being issued.  All laboratory results and audit reports will be reviewed by the SIP Regional Office responsible for issuing export certification to verify compliance with all PRC and SIP requirements.   

Procedures for industry requesting Fishmeal Exports

Link to Request Form

 


Exports to Canada

"The requirements for imports of aquatic animals (finfish, molluscs, and crustaceans) into Canada are changing. Beginning December 10, 2012, aquatic animals listed on Schedule III of the Health of Animals Regulations will require an import permit to enter the country. This measure is aimed at protecting Canada's aquatic animal resources. The enforcement of these new requirements will be phased in and will come into effect either on December 10, 2012, February 4, 2013 or April 8, 2013 depending on the specific end uses and the applicable HS codes."

All US exporters should be aware that the products they handle may be affected by the implementation of these new regulations. The three U.S. federal agencies that function as Competent Authorities for exported aquatic animals (the U.S. Department of Agriculture, Animal and Plant Health Inspection Service [USDA-APHIS]; the U.S. Department of Commerce, National Oceanic and Atmospheric Administration, National Marine Fisheries Service [NOAA Fisheries]; and the U.S. Department of Interior, Fish and Wildlife Services [FWS]) have worked with the Canadian Food Inspection Agency (CFIA) on specific export requirements that will facilitate continued US trade in aquatic animals and products with Canada. As of December 10, 2012, each shipment must be accompanied by an import permit issued from CFIA and possibly a health certificate from NOAA-SIP / APHIS / FWS.

The regulated species and the diseases of concern are at the link below. http://www.inspection.gc.ca/animals/aquatic-animals/diseases/susceptible-species/eng/1327162574928/1327162766981

NOAA-SIP will be issuing certification for these exports:

April 8, 2013, marked the enforcement of the third and final phase of Canada's aquatic animal import requirements, which applies to animals intended for Food Service, Retail Use and Further Processing (ie. human consumption). The U.S. Department of Commerce (US DC), National Oceanic and Atmospheric Administration - Seafood Inspection Program (NOAA - SIP) and the United States Department of Agriculture (USDA), Animal and Plant Health Inspection Service -Veterinary Services (APHIS- VS) have recently negotiated with the Canadian Food Inspection Agency (CFIA), the health certificate for live molluscs intended for Food Service, Retail Use and Further Processing. As a result of this negotiation, beginning April 11, 2013 NOAA-SIP will endorse all live marine molluscan shellfish certificates destined for Canada for the end uses of Food Service, Retail Use and Further Processing. This is an interim measure which will be evaluated over the coming year.

In many cases, regionalization has been established and animals can move without a health/zoosanitary certificate from the origin. To determine is this is possible please utilize Canada's Automotive Information Reference System (AIRS).

http://www.inspection.gc.ca/animals/aquatic-animals/imports/airs/eng/1300127512994/1326599589537#

Contacts for CFIA Area Offices can be found at:
http://www.inspection.gc.ca/about-the-cfia/offices/eng/1313255382836/1313256130232

Website for USDA APHIS / Canada Exports: http://www.aphis.usda.gov/regulations/vs/iregs/animals/animal_canada.shtml

Website for OIE: http://www.oie.int/en/


Australia Exports

All firms requesting an export certificate to Australia must be listed as an Approved Establishment in the USDC Seafood Inspection Program. This is a requirement at the request of the Australian authorities for the appropriate use of the attestations on each US export certificate.

Eg: I, the undersigned official of the Seafood Inspection Program, United States Department of Commerce, declare with respect to the consignment of……. 1)the fish were processed in a premises (including vessels/refrigerated warehouses) approved by and under the control of the competent authority….. 2)the fish were subjected to an inspection system supervised by the competent authority…3) The non-salmonid finfish for export were processed in a premises under the supervision of the NMFS, which monitors the acceptability of the processing of fish for export…4) product for export is derived from fish that were harvested from a population for which a documented health surveillance program exists which is administered by NMFS….5) processed, including inspection and grading, under a system monitored by the NMFS…

All consignments must have the Australian Import permit, a USDC SIP Lot inspection and a USDC SIP Export Health certificate unique to the product and shipment.

 

 

   
U.S. Department of Commerce/NOAA Fisheries • 1315 East West Highway • Silver Spring, MD 20910 • Phone (301) 427-8300 • Toll Free (800) 422-2750
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