There are two departments in the United States that have responsibilities for meat products, the United States Department of Agriculture, Food Safety and Inspection Service (USDA/FSIS), and the Food and Drug Administration (FDA). The majority of meat products exported from Canada to the United States fall under the legal jurisdiction of the FSIS, since FSIS regulates the import of meat from common food animals, such as beef, pork and poultry. These are known as "amenable species" (refer to Annex Q, paragraph Q.1.2 for details on amenable species). The FDA regulates the meat imports from game and exotic animals which are the "non-amenable species" under FSIS. The FDA is also responsible for products that contain a very small quantity of meat (less than 2% cooked or 3% raw), and casings. It should be noted that the meat included in products containing small amount of meat falling under the jurisdiction of the FDA must originate from a source approved by the FSIS, when applicable (e.g., beef, pork, poultry meat). All Canadian registered establishments are eligible to export meat products under FDA jurisdiction, while there is a list of approved establishments to export products under the jurisdiction of FSIS (refer to Annex W). It is important that the exporter know which Department regulates the meat products to be exported because the certification requirements for FSIS and FDA regulated products are very different.
It is important to note, that in addition to meeting the meat hygiene requirements of either the FDA or FSIS, all meat products must also fulfill the animal health requirements of the Animal and Plant Health Inspection Service (APHIS) branch of the USDA. These restrictions may be found in this section on the United States under "Import Prohibitions or Restrictions" (11.7.3.2). APHIS is also responsible for issuing import permits, when required.
The conditions for export to the United States are influenced by the fact that the FSIS recognizes the Canadian federal meat inspection system as equivalent to the United States system. Equivalence means that Canada's system does not have to be the same as the importing country's system (i.e. the United States), but is based on the ability of an exporting country's system or a sanitary measure to achieve the same outcome or, in the language of the Agreement on the Application of Sanitary and Phytosanitary Measures (SPS Agreement), provides the same "appropriate level of sanitary or phytosanitary protection" as the importing country's system or sanitary measure. Determinations of equivalence generally entail a thorough review and assessment by the importing country of all aspects of the exporting country's system, including all relevant legislation, policies, standards, procedures and infrastructure, to support a judgement on whether the system achieves the same level of sanitary protection as the importing country's system. The FSIS carries out regular reviews of the Canadian meat inspection system to verify that equivalence is being maintained. During these reviews, the FSIS uses the Canadian legislation and manuals of procedures to assess ongoing equivalence. The only items that are judged according to FSIS standards are those for which Canada does not have equivalence, (e.g. frequency of inspection and pre-shipment review). It is these additional requirements which are described in this section.
For detailed and most current procedures applicable to samples and to obtain Form 9540-5, the applicant must visit the USDA/FSIS web site.
The FSIS authorizes requests for the importation of samples of meat and or poultry products destined for laboratory examination, research, evaluative testing or trade show exhibition. Provided there are no animal health restrictions imposed by the USDA, APHIS, meat and poultry samples can originate from any foreign country. Importers who want to import samples into the United States that originate in countries with animal health restrictions shall apply to APHIS for a permit prior to importing.
Samples are certified to be exported to the United States with a CFIA/ACIA 1454 stating "Samples intended for laboratory examination, research, evaluative testing, or trade show exhibition."
Further details are provided in Annex B. Exporters should advise the CFIA should the information obtained from the FSIS differ from the information provided in this section.
It should be noted that products exported as samples are not permitted to be consumed. In addition, samples do not require label approval in order to be certified for export.
The USDA/FSIS is responsible for the adherence of the requirements of all shipments of imported Red Meat and/or Poultry products intended for personal consumption. Products for personal consumption are exempted from FSIS import requirements when the following conditions are met.
Personal consumption shipments of Red Meat and/or Poultry products must also meet USDA, APHIS requirements. It is the responsibility of the person(s) bringing the product into the United States to notify APHIS of the shipment.
Meat products derived from ovine and caprine animals are prohibited.
In the case of hunter harvested cervid meat, the importers will need to present to the Customs and Border Protection (CBP) inspector evidence that the product is cervid meat, (e.g. a hunting license or commercially prepared labels found on unopened packages or other official documents).
The following conditions apply:
All marine containers that are in transit through the United States or arriving by vessel at a port of entry in the United States must be sealed with a seal that meets the ISO/PAS 17712 standard. It is the responsibility of the exporter to ensure that an acceptable seal – PDF (52 kb) is applied when required. It is not required that this seal number to be recorded on the CFIA/ACIA 1454 unless noted in the country-specific section.
After filing the necessary forms for the United States Customs and Border Protection, and meeting animal disease requirements of APHIS, all imported meat, poultry and processed egg products must be presented for inspection by FSIS at an official import inspection establishment. The exporter/importer is fully responsible for taking the necessary steps to ensure that all applicable United States government Port of Entry procedures can be satisfied. Basic information is provided in Annex L of this section. See details on specific FSIS import inspection requirements.
The exporters/importers are urged to familiarize themselves with requirements that apply to the type of products they wish to export to the United States.
Imported meat and poultry products must meet the same labelling requirements as the United States domestically-produced products. Canadian operators exporting to the United States must adhere to the labelling standards incorporated in Federal meat and poultry inspection regulations (USDA). These operators will be fully accountable for the content and production of all labels, whether generically approved, modified without resubmission, or submitted to FSIS for review and approval. FSIS's Labelling and Program Delivery Division (LPDD) develops policies and inspection methods and administers programs to protect consumers from misbranded meat and poultry products. Further guidance on labelling issues may be obtained by accessing "A Guide to Federal Food Labeling Requirements of Meat and Poultry – PDF (55 kb)". Refer also to section 11.7.3.5 below and Annex N for more details.
Frozen meat cuts in combo bins are not acceptable for export unless the product has been frozen in such a way that any individual meat cut can be removed for inspection without the need to thaw the entire combo.
Meat products imported into Canada are not eligible for export to the United States unless processed as defined in the Meat Inspection Regulations, 1990 (includes imported products repackaged and placed in Canadian containers).
Only imported shipments that are considered by the USDA as a trans-shipment (i.e. in bond), and covered by an original certificate from the country of origin showing the name and address of a consignee located in the United States will be accepted.
For products subject to FSIS requirements, it is the responsibility of the operator to ensure that only eligible meat products from eligible establishments are exported or used for further processing in products intended for export to the United States. (See Annex W for the list of approved Canadian establishments and Annex Q for criteria on how to determine the eligibility of imported meat products).
In addition to the animal health restrictions outlined in sub-section 11.7.3.2.2.1.1 below, operators of establishments where eligible and non-eligible products are handled must develop, implement and maintain control programs that will ensure that non-eligible products can be distinguished from those that are eligible through receiving, processing, shipping and distribution. These control programs must be implemented as written, be effective and verifiable.
The written procedures must be reviewed and found satisfactory by the IIC. Inspectors are then responsible for monitoring the operator's controls to ensure that they are adequately followed. This verification task is addressed by completing the appropriate Compliance Verification System (CVS) task at the prescribed frequency.
Operators wishing to have their establishment added to the eligibility list should make a written request for approval through their inspector and Area Office. Annex I from the introduction to Chapter 11 should be used for that purpose. Upon receipt of recommendation for approval from the appropriate Area Office, the CFIA will certify to FSIS that the establishment meets USDA/FSIS requirements.
For details on the steps to be followed when applying for export eligibility, refer to Chapter 11, Introduction, section 11.2.3.2 (2). It is important that operators prepare and apply with Annex I well in advance of their anticipated start of export to the United States.
USDA/APHIS regulations prohibit the importation (directly or indirectly through third countries) of raw meat products from regions not recognized as being free of disease of concern to them (prohibited meat products).
In Canada it is permitted to import raw poultry meat from Brazil and Hungary under the conditions outlined in Chapter 10 of the Meat Hygiene Manual Of Procedures (MOP). However, these two countries are not recognized by APHIS as being free of exotic Newcastle disease (9 CFR section 94.6) and the raw poultry meat products imported from Brazil and Hungary are therefore considered to be "prohibited poultry meat products". As a result, APHIS has advised that the following animal health restrictions will apply:
(A) Establishments handling exposed prohibited poultry meat products
Unless requirements outlined in subsection (C) regarding approved segregation procedures below have been fulfilled, Canadian registered establishments, other than storages (S-XXX) where import inspection is performed, that receive and handle exposed prohibited poultry meat products become ineligible to export poultry meat products to the United States. Refer to Annex W-1 for a list of establishments that are not eligible to export poultry meat to the United States or to supply establishments eligible to export poultry meat products to the United States. Establishments eligible to export poultry meat to the United States that wish to keep their privileges to export poultry meat to the United States must not handle exposed poultry meat from those establishments.
An establishment may be removed from Annex W-1, in circumstances other than those described in subsection (C) below, when the operator of the establishment is able to demonstrate to the satisfaction of the CFIA that handling of exposed prohibited poultry meat products has been discontinued and that measures are taken to prevent handling of exposed prohibited poultry meat products in the facilities. The application to remove an establishment from Annex W-1 must be submitted through the CFIA inspector and the Area Office Export specialist. When an application is accepted, the CFIA will amend Annex W-1 accordingly. Once the establishment has been removed from Annex W-1, operators interested in obtaining approval for export of poultry meat products to the United States must submit an application as per routine procedures (see section 11.2.3.2).
Auditable receiving procedures should be developed, implemented and maintained by the operator to address this animal health requirement (e.g., to include a letter from the suppliers to guarantee that they do not receive prohibited poultry meat products). Inventory records must be maintained by the operator regarding the origin of the poultry meat products present in the establishment and the destination of the poultry meat products shipped from the establishment. These records must be made available to the Inspector in Charge (IIC) upon request.
(B) Establishments where packaged prohibited poultry meat products are stored
Prohibited poultry meat products may be received and stored in any registered establishments provided they are stored separately from products derived from poultry destined for export. The separation must include separate stacking of the packaged products not in contact with eligible packaged products and clear identification of the ineligible product (e.g., poultry meat from Brazil or Hungary) with respect to its origin and export restriction (not eligible for export to the United States). The CFIA IIC will monitor the operator's control procedures to verify that the storage of non-eligible meat products is being done in the prescribed manner in order to prevent the export of non eligible poultry meat products to the United States.
Inventory records must be maintained by the operator regarding the origin of the poultry meat products present in the establishment and the destination of the poultry meat products shipped from the establishment. These records must be made available to the IIC upon request.
(C) Approval requirements for establishments handling exposed prohibited poultry meat products
Inventory records must be maintained by the operator regarding the origin of the poultry meat products present in the establishment and the destination of the poultry meat products shipped from the establishment. These records must be made available to the IIC upon request.
Note: In the case of poultry meat products derived from species not falling under the jurisdiction of the USDA/FSIS (e.g., quails), the approval of the segregation procedures referred to above is the responsibility of the CFIA inspector only.
Special procedures related to Hazard Analysis Critical Control Point (HACCP) systems as well as specific E. coli and Salmonella spp. testing programs are required because of the implementation of the "Pathogen Reduction and (HACCP) Systems; Final Rule" published July 25, 1996. All establishments exporting to the United States must meet the requirements of the Final Rule. Furthermore, all product used in the fabrication of meat products exported to the United States must come from establishments which also meet these requirements.
The requirements of this Final Rule include: HACCP implementation, Standard Sanitary Operating Procedures (SSOP), generic Escherichia coli (Biotype 1) in slaughter plants and Salmonella performance standards where applicable. The Canadian Requirements are considered equivalent to the United States with the exception of pre-shipment review, generic E. coli, and the Salmonella performance standards. For a full description of the additional requirements, refer to Annex Q, Annex T and Annex U.
Special procedures must be implemented in poultry abattoirs in order to meet FSIS import requirements, and all such establishments exporting to the United States must meet these requirements. This means that each evisceration line on which poultry carcasses are being processed must have one (1) on-line carcass inspection station staffed by CFIA inspectors. Furthermore, all meat ingredients used in the production of meat products destined to the United States must come from establishments which also meet the applicable requirements. Please refer to Annex E for details.
Poultry carcasses shall be chilled to 4°C (40°F) or lower within the following specified times:
| Weight of carcass | Time (hours) |
|---|---|
| Under 1.8 kg (4 lb) | 4 |
| 1.8 - 3.6 kg (4 to 8 lb) | 6 |
| Over 3.6 kg (8 lb) | 8 |
The operator is responsible to develop, implement and maintain control programs to ensure that all applicable specific FSIS product requirements are met. The control programs must be effective and auditable.
In the case of prepared products, only meat products for which the formulation, method of manufacture and label approval have been received from the FSIS may be exported to the United States.
Prior to manufacturing prepared meat products intended for export to the United States, the operator must provide evidence to the CFIA inspector that the product and label meet applicable FSIS requirements. The FSIS approval form can be found in Annex O. The formulation and label approval must be made available to the inspector on request for verification, or when requested by the FSIS as part of the audit procedures.
The USDA/FSIS implements a zero tolerance level of protection for Listeria monocytogenes, in all categories of Ready-to-Eat (RTE) meat products. No RTE meat product from a lot that tested positive for L. monocytogenes is eligible for export to the United States. Any RTE meat product that contacts a food contact surface that has tested positive for L. monocytogenes is not eligible for export to the United States without first having undergone a process that is destructive of L. monocytogenes (9 CFR § 430.4(b)). If a food contact surface tests positive for Listeria species, it must be confirmed by further testing that it is not L. monocytogenes before the product is shipped to the United States. RTE products cannot be exported to the United States pending laboratory test results. The signing veterinarian shall review the test results for food contact surface and product, as applicable, to ensure that product being exported to the United States is free of L. monocytogenes before signing the health certificate.
It is generally accepted that E. coli O157:H7 contamination is a food safety hazard that is reasonably likely to occur in establishments that process raw beef products, such as ground beef, other non-intact beef products, and raw intact beef products. Therefore, this hazard must be addressed in the establishment's HACCP plan (refer to Chapter 17 for details on applicable control measures). More details on the laboratory methodology, including the list of methods deemed equivalent to those of FSIS can be found in Annex D and Annex D-1.
Pork jowls must be incised for abscess detection if intended for export to the United States.
The FSIS regulations limit water retained by raw single-ingredient meat and poultry products1 from post-evisceration processing, such as carcass washing and chilling, to the amount that is unavoidable in meeting applicable food safety requirements. The Regulations also require labelling for the amount of water retained in the product. Raw livestock and poultry carcasses and parts are not permitted to retain water resulting from post-evisceration processing unless the establishment preparing the carcasses and parts demonstrates, with data collected in accordance with a written protocol, that any water retained in the carcasses and parts is an inevitable consequence of the process used to meet applicable food safety requirements. Where water is retained, the establishment is required to disclose on the label of the meat or poultry product the maximum percentage of retained water in the raw product. Establishments having data demonstrating that there is no retained water in their products can choose not to label the products with the retained-water statement or they can choose to make a no-retained-water claim on the product label. The labelling requirements apply to all raw single-ingredient products destined to the United States.
The same requirements are being incorporated into the Canadian federal red meat inspection program so that no additional requirements will apply for exported red meat products and for meat from ratites. As an interim measure, establishments that have not yet implemented water retention protocols for all - products subject to the FSIS requirements must, if they wish to remain eligible to export to the United States, identify non-complying products as being ineligible for export to the United States as raw single-ingredient products when they leave the establishment.
In the case of the poultry sector, the FSIS requirements will be implemented as an export requirement, i.e. without concomitant changes to the domestic program. The operator will be responsible for processing raw single-ingredient poultry products destined to the United States in accordance with the FSIS water retention requirements. In addition, all raw single-ingredient poultry products intended for direct or indirect export to the United States as raw single-ingredient products must be labelled with a water retention declaration (if the products have retained water) and a positive declaration clearly indicating that the product is eligible for export to the United States (e.g. "eligible for the United States"). The requirement to clearly identify the product as eligible for the United States is to facilitate the rapid identification of eligible poultry product without the need for tracking and verifying transfer certificates and log books. The declaration "eligible for the United States" can be waived for raw single-ingredient poultry exported directly to the United States from the slaughter establishment of origin.
It should be noted that all pre-evisceration and some post-evisceration processes do not require a written water retention protocol (see Annex Y, point 1-A for details). Also, meat products not subject to Salmonella standards, such as offal, cheek meat and giblets, must be chilled according to an approved protocol which demonstrates that water retention has been minimized to the extent possible with the existing chilling equipment and facilities.
Detailed information on the requirements is provided in Annex Y, Annex Y-1 and Annex Y-2. They will need to be implemented to the satisfaction of the CFIA by operators who wish to export raw single-ingredient meat and poultry products to the United States.
Prepared and multi-ingredient meat and poultry products are not affected by the new requirements as retained water is not considered to be an ingredient.
Operators of establishments that use a post-eviscerating process that results in water retention in raw meat or poultry carcasses or parts must maintain on file a written data-collection protocol in accordance with the above mentioned annexes and advise the IIC when a new protocol is developed or an existing protocol is modified, or when processing procedures have been changed in a manner that would require a new or revised protocol. An operator does not have to maintain a protocol on file if they have data or information that clearly demonstrate that their products do not retain water as a result of the process (e.g., spraying boneless meat with an antimicrobial solution where the end product does not retain water from the antimicrobial application process).
The IIC will verify that the establishment has on file and available to CFIA its written data collection protocol or data that demonstrate that post-evisceration contact with water does not result in retained water in excess of naturally occurring moisture and will review revised and new protocols. The IIC will verify that the establishment is following its protocols, and that the protocols reflect the actual processing system in use. The inspector will also verify the labelling of products produced under the applicable protocols.
APHIS basic requirements are that products encased in casings of ruminant origin are not eligible to be exported to the United States. The only exceptions are:
Freezing for trichina treatment is not required for routine exports of raw pork to the United States. The following information applies when such treatment is required.
Canadian procedures to treat pork for trichina by freezing are in accordance with USDA / FSIS domestic requirements. Pork treated according to the requirements of Chapter 4 of the Manual of Procedures can be certified to the United States as treated for trichina. The export certificate should bear one of the following statements as applicable in the remarks section:
Section 318.10 of the USDA meat and poultry inspection regulations indicates the "prescribed treatment of pork and products containing pork to destroy trichinae". The prescribed treatment methods include heating, freezing (see point (i) above), salting and drying.
Additional methods for the destruction of trichinae in pork products are described in the USDA/FSIS document 9 CFR Part 318.
Manufacturers of Prosciutto hams must use a production method that has been proven to destroy trichinae cysts. Prosciutto producers are required by the USDA to institute research to validate the safety of their process or change to an already approved process. Those producers wishing to verify that their process will destroy live trichinae in the product must submit an experimental protocol to the USDA, Food Safety Inspection Service (FSIS). A procedural outline designed by USDA/FSIS may be provided to assist the producers in designing acceptable experiments which will demonstrate that a process, other than the one prescribed in 318.10(C) will destroy live trichina in the product.
Please contact the Labeling and Program Delivery Division for further information.
Specific Bovine Spongiform Encephalopathy (BSE) related requirements apply to certain products derived from ruminants. Refer to Annex Z for details.
FSIS Meat Inspection Regulations require that cured pork bellies prepared for slicing and labelling as bacon must not exceed the weight of the fresh uncured pork bellies. Establishments that manufacture cured pork bellies that will be exported to the United States either as bellies or bacon must utilize processing procedures that will produce product that is in compliance with the applicable regulations.
To demonstrate compliance, the following information must be documented on a production lot basis as part of the establishment's quality control program:
For bacon yield determination, the guidelines to be used can be found in the Directive FSIS 7000.1 – PDF (200 kb).
The CFIA inspector must monitor production procedures and plant records to determine compliance and must not certify shipments of cured pork bellies to be sliced or labelled as bacon for export to the United States unless the procedures and records outlined above have been complied with.
Ante-mortem and post-mortem inspection must be conducted according to Canadian requirements as described elsewhere in this Manual (Chapter 17 - red meat and Chapter 19 and section 11.7.3.2.2.1.3 - poultry). This means that the inspections were carried out by a CFIA veterinarian or under the direct supervision of a CFIA veterinarian. This requires that a veterinarian has been assigned to carry out these functions or to provide line or functional supervision to the inspector(s)2 responsible for carrying out them out. Direct supervision means that the veterinarian has direct authority over the inspector(s) in relation to these duties. When inspectors are performing such duties, a veterinarian must be available on a timely basis to fulfil the supervisory role, as well as specific veterinary responsibilities which, as an example in the case of ante-mortem inspection, would include the diagnosis and disposition of suspect animals.
Meat food products must be prepared under "continuous supervision", which means prepared in an establishment to which an official inspector has been assigned by the CFIA to carry out inspection in accordance with this Manual.
Frequency of CFIA visits to establishments eligible to export to the United States
The USDA/FSIS has informed the CFIA that every plant that produces meat products for export to the United States must receive at least one visit by a CFIA inspector during each twelve (12) hour shift every day while the plant is in production. These visits are required because of a legal interpretation indicating they must be performed to satisfy the United States regulatory requirement for "continuous inspection". It is important that the visits are planned so that the times chosen are random during each of the twelve (12) hour shifts. These visits must be recorded on the CVS Verification Worksheet.
Note: this requirement does not apply to establishments when they are only producing meat products that fall under the jurisdiction of the Food and Drug Administration (FDA) (e.g. bison meat) or when the establishment is not processing meat products (e.g. meatless/vegetarian product).
Annex A-9 is required for all commercial shipments of poultry meat intended for human consumption destined to the United States and those in overland transit in the United States.
Note: Annex A-9 is not required for product containing less than 2% cooked poultry and which are not under FSIS jurisdiction.
For meat products derived from ruminants, the specific requirements relative to overland transit in the United States of meat derived from ruminants are described in Annex Z. Below are the annexes that must be issued along with either the CFIA/ACIA 4546 or 1454 for the various ruminant products:
Form CFIA/ACIA 4546 (for a sample, see Annex A) Official Meat Inspection Certificate for fresh meat, meat by-products, meat food products and poultry products must be issued. If necessary form CFIA/ACIA 4566 (also found in Annex A.1) should be used.
For completion of forms CFIA/ACIA 4546 and 4566 see instructions in Annex A.2.
With the exception of the animal health restrictions outlined in section 11.7.3.2.2.1.1, a meat product manufactured or processed at an establishment not currently eligible to export to the United States may be exported to the United States under the following conditions:
Note: When a production code is used, it must be linked to a production date readily verifiable by the inspector and would have to be made available to the FSIS on request.
When FSIS was amending the federal meat and poultry products inspection regulations in 1995, to replace the phrase "at least equal to" with the words "equivalent to" they overlooked one of the changes that should have been made. As a result, the paragraph dealing with certification of poultry products still contains the statement that the products "... are otherwise in compliance with requirements at least equal to those in the Poultry Products Inspection Act and said regulations." By agreement with FSIS this statement on the CFIA certificate shall be interpreted to have the same meaning as "... are otherwise in compliance with requirements equivalent to those in the Poultry Products Inspection Act and said regulations."
CFIA/ACIA 1454 shall be issued for export of meat products derived from food animals which in the United States fall under voluntary inspection (e.g. bison, rabbit, quail, etc.) and require inspection by the FDA in the United States upon entry.
In the case of bison meat products, Annex A-1 shall also be issued.
Use CFIA/ACIA 1454 and Annex C. See Annex Z for restrictions in the case of ovine casings.
Bone-in and boneless fresh beef - Annex A-5
Beef viscera - Annex A-6
Cooked poultry - Annex A-10
Fresh pork - Annex A-11
Annex A-5, A-6, A-10 or A-11 can be issued as applicable
It is important to note that the above annexes are not a FSIS import requirement. It can however be issued at the request of the exporter, provided that all applicable Mexican requirements are met.
Annex A-7 can be issued.
It is important to note that Annex A-7 is not a FSIS import requirement. It can however be issued at the request of the exporter, provided that all applicable Japanese requirements are met.
The shipment must be accompanied by CFIA/ACIA 1454. In the block: "Country of Destination/Pays de destination" - "Ship stores" shall be entered. The statement "For ship stores only. Not for commerce within the United States" must appear in the block "Additional certification/Attestation supplémentaire".
The certification for these products is provided by the Terrestrial Animal Health Division. CFIA inspectors must use certificates available for this purpose.
As required, please contact your local Terrestrial Animal Health District office for additional information.
Prior approval by the FSIS is required for all labels used for meat and poultry products before these products may be marketed in commerce. There are distinct categories of prior approval that dictate the precise manner in which a label is approved. One category is "Generically approved labels", which means the labels need not be presented to the FSIS for prior sketch approval. Generically approved labels may be used for products such as: those that have a product standard and that bear no claims, single-ingredient products that bear no claims, and labelling of shipping containers that contain fully and properly labelled immediate (inner) containers. Labels which cannot be approved under this category must be individually approved by FSIS.
See detailed, up-to-date information on labelling, including generic labelling.
See Information on acceptable claims that may be used in labelling, including "organic" claims ingredients, packaging materials, and other related topics as well as and "A Guide to Federal Food Labeling Requirements For Meat and Poultry Products – PDF (55 kb)".
Contact information for FSIS staff for questions regarding labelling or for labelling approval products.
In contrast, the FDA does not require prior label approval for food products under its jurisdiction. The FDA has promulgated regulations establishing requirements for all aspects of labelling and monitors labelling compliance primarily through random post-marketing surveillance.
See information on labelling of FDA regulated products.
The operator is responsible for obtaining and maintaining label approvals and records for all products destined to the United States market.
The following is some supplementary marking and packaging information that can be of use to exporters. However, the information is not exhaustive and should be complemented with information obtained from the FSIS, as required. More information can also be found in Annex N and Annex N-1.
If a net weight is declared, it must be in avoirdupois weight (i.e. pounds, ounces) or liquid measure (i.e. fluid ounces, quart). It is acceptable to state the net weight in metric weight in addition to the avoirdupois weight.
Specific requirements apply. Refer to Annex N for details.
The larger cuts of horsemeat must be stamped "horsemeat" with green ink. At least one stamp is required for each ten pounds of boneless meat in bulk.
Country of origin labelling in the United States is a mandatory domestic retail labelling requirement. As such, the CFIA does not verify compliance to COOL prior to export and FSIS does not verify compliance at the border. In Canada, country of origin in a voluntary claim that may be applied when the product meets the requirement for the claim. Meat products may not meet the Canadian standard to be labelled as "Product of Canada" as they are manufactured with imported meat.
However, "Product of Canada" is generally required on a label for export to the United States. For example, the phrase "Product of" is required on all immediate containers of meat and/or poultry products. However, the phrase is not required on a red meat carcass, primal or subprimal cut that prominently displays the name of the foreign country within the marking itself, (the Canadian mark of inspection is a circle surrounding the word Canada and the establishment number).
This difference between Canadian and United States requirements of "Product of Canada" may require exporters to develop procedures to ensure the correct labelling for export to the United States.
Labels that bear certain declarations used on products destined to the United States and that are not approved by the FSIS, such as labels used to make claims to address microbial requirements, are not permitted for use.
A product claim such as: "for cooking only," "not for grinding," or any other similar claims to address E. coli O157:H7 or any other microbiological issue is not permitted on imported products. FSIS, LPDD will not approve such claims for imported products from any foreign country and/or establishment. Labels, previously approved with such claims have been rescinded.
Products encased in casings must be labelled as to the source of its casings i.e. natural casings (indicating the species of origin) when not derived from the same species as the meat products contained in the casings or indicate that the casings are regenerated collagen casings in other cases.
Note: APHIS has restrictions on the use of casings of ruminant origin. Please refer to sub-section 11.7.3.2.2.2.5 on Import Restrictions for details.
The products must be labelled "Inedible Not for Human Food - For Pharmaceutical Use Only".
Antioxidants used in the preparation of rendered animal fat exported by tank or similar bulk container must be identified on the placard attached to the tank or the container. They also must be identified on the accompanying certificate. Should antioxidants not be present, this information should also be indicated. The serial number of official seals used on the vehicle or bulk container must be recorded on the certificate.
The import into the United States of meat products not regulated by the USDA/FSIS, such as game meat, and casings which meet the requirements under section 11.7.3.2.2.2.5, falls under the jurisdiction of the FDA. Exporters should contact the FDA for entry requirements applicable to the products they wish to export. For example, as a result of the implementation of the provisions of The Bioterrorism Act, registration requirements for establishments and products, record maintenance, and prior notice of intent to export requirements will apply.
The product prepared under religious dietary laws must be distinguished from product slaughtered under the Poultry Act and Regulations by a USDA exemption permit number.
All persons desiring exemptions as provided by under CFR 9 381.11-381.14 based on religious dietary laws are required to send an application (Annex V) for an exemption permit number through their Area of Operation to the Director of Meat Programs Division together with a statement from an official of the religion having authority over the enforcement of the religious dietary laws with respect to poultry and poultry products. The statement shall:
Upon receiving the exemption permit number, the Canadian establishment is required to submit labels for approval prior to shipping, to
USDA, FSIS,
OPPD, Labeling and Program Delivery Division
1400 Independence Avenue, SW
Room 2540 - South Building
Washington, DC 20250-3700
All mandatory labelling requirements must be present on the package, including product name that specifies the exemption. In addition, the shipping container labels for slaughtered poultry processed under exemption must bear the packer's name, address, plant number and the statement "Eviscerated Poultry Slaughtered / Processed under CFIA Inspection - USDA Exemption Permit No. 000". Product may or may not carry the mark of inspection.
Note: Poultry feet and heads detached from the carcasses cannot be exported for edible purpose under Buddhist ritual. They are considered as inedible meat product and may be exported for animal food only.
Section 11.5 must be consulted as needed for basic requirements applicable to exported meat products returned to Canada.
In the case of a shipment which has been refused entry by FSIS, a written Application to return the product into Canada must be presented by the Exporter identified on the export certificate CFIA/ACIA 1454 or 4546, as applicable, to an Import Service Centre (ISC). The application should be sent to the ISC of the area where the product will land in Canada (Annex J of this section). The details concerning the application procedures and the distribution of the documents are outlined in Annex J-1. Permission will not be refused except under exceptional circumstances.
When returning refused products to Canada, the USDA Import Inspector will seal the truck using a tamper-evident seal. The applicant must inform all concerned not to break the USDA seal until permission is obtained from a CFIA inspector.
Canadian exported meat products which have passed USDA import inspection become ipso facto American meat products. These products may be imported into Canada in their original and unopened containers, provided an application is made using Annex J of this section as indicated above in section 11.7.3.6.5.1 and the condition in either (i) or (ii) below are met:
The APNM will forward the approval to the applicant and the ISC for processing and distribution as per operating procedures (see Annex J-2). The applicant is responsible for forwarding the approval to the Customs Broker.
Procedures to follow at the receiving establishment are the same as described in section 11.7.3.6.5.1 (ii) above except that the USDA documents will be replaced with the conditions issued by the APNM.
FSIS carries out regular reviews of the Canadian meat inspection system to verify that equivalence is being maintained. The outcome may be (1) acceptable, (2) marginally acceptable (plant receives a 30 day notice of intent to delist), or (3) unacceptable (immediate delistment from export eligibility). During these reviews, a number of establishments from across Canada may be audited. They may be chosen at random, or may be targeted based on a specific concern (i.e. BSE, food pathogen of interest), or a history of non-compliance at a facility. During these audits, the FSIS uses the Canadian legislation and manuals of procedures to assess ongoing equivalence except where there are specific United States requirements.
If the plant is found acceptable, this means it meets the United States requirements, and the establishment maintains its export eligibility to the United States. While only minor issues may have been identified during the audit, these issues must be recorded, corrected and tracked in the CVS.
USDA/FSIS has advised of the following policy for establishments judged marginally acceptable as a result of their audit.
Operators of establishments to which a notice of intent to de-list was issued by the CFIA at the request of the FSIS reviewer will be required to correct the deviations identified during the visit. The deviations will be reported on the CVS Verification Worksheet and the Inspection Report - Corrective Action Request (CVS task 3301) and include a statement to the effect that an action plan must be developed to re-establish full compliance with requirements if the establishment wishes to maintain its export privileges. Annex H of this section will also be issued to the operator in such cases. Annex H will have to accompany the documentation forwarded to confirm that appropriate action was taken to correct deficiencies observed and prevent reoccurrence, as applicable.
The CFIA designated area supervisor for the establishment and the IIC will conduct the necessary on-site follow-up review(s) of the establishment and determine if the necessary corrective actions were taken (CVS task 3301 recorded on the Inspection Report - Corrective Action Request). When preparing the action plan and taking the necessary measures, all concerned have to keep in mind that the necessary information has to be provided to FSIS, within 30 days following the visit, by the Director of the MPD. When applicable, the CFIA designated supervisor has to provide the necessary information (action plan by the operator, IIC and supervisor confirmation that all deviations were corrected) to the Director of the MPD through the Area Office (export officer). The information will be forwarded to the FSIS by the Director of the MPD. Establishments for which the required information will not be provided to the FSIS within the prescribed period of time will be removed from the list of establishments eligible to export to the United States.
In addition, any establishment to which a notice of intent to delist was issued during an audit, will be re audited at the time of the FSIS next systems audit of Canada's inspection system, provided that establishment was successful in maintaining its eligibility status for export to the United States.
In the event that an establishment is judged unacceptable by the FSIS reviewer and is de-listed as a result of deficiencies observed during an audit, FSIS will not accept the establishment as re-certified until the government of Canada provides FSIS with a written description of all corrective actions that have been taken.
At the time of the review, the deviations observed will be reported on the CVS Verification Worksheet and the Inspection Report - Corrective Action Request (CVS task 3301) and include a statement to the effect that the establishment is removed from the eligibility list and that an action plan has to be developed to re-establish compliance with requirements if the establishment wishes to regain its export privileges.
The CFIA designated area supervisor for the establishment and the IIC will conduct the necessary on-site follow-up review(s) of the establishment to determine that all the necessary corrective actions were taken (CVS task 3301 recorded on the Inspection Report - Corrective Action Request).
When applicable, the CFIA designated supervisor has to provide the necessary information (action plan by the operator, IIC and supervisor confirmation that all deviations were corrected) to the Director of the MPD through the Area Office (export officer). The information will be forwarded to the FSIS by the Director of the MPD.
In addition, any establishment that is de-listed during an audit, will be re audited at the time of the FSIS next systems audit of Canada's inspection system, provided that establishment was successfully re certified for export to the United States.
If a re-certified establishment is de-listed again during the following up audit, FSIS will not list the establishment as re certified until FSIS auditors return for another follow up audit and are able to verify that all deficiencies have been corrected.
Products under intensified inspection due to laboratory violations will be sampled upon re-inspection in the United States and will be held at the import establishment pending laboratory results.
The follow-up for such non-compliances to the United States import requirements will have to be conducted as provided by the CVS (task 3302) and any other FSIS specific requests, as applicable. Unless advised otherwise, the operator will have to conduct the required follow-up within 30 days of the date of notification of the non-compliance to allow the CFIA to provide the information requested by the FSIS in response to the non-compliance within the prescribed timeframe and avoid that the establishment be removed from the list of establishments eligible to export to the United States.
All meat products exported to the United States and identified for animal food must be denatured, unless a derogation has been obtained from the USDA. "Application and permit for importation of undenatured inedible meat and poultry product" (see Annex P) shall be used to obtain such a derogation. Applicable American restrictions and conditions for transporting undenatured inedible product are mentioned on the form. The import permit shall accompany the shipment. Requests shall be addressed to:
Office of International Affairs (OIA), Import Inspection Division
Washington, DC
Phone: (202) 720-9904
Fax: (202) 720-6050
Hours of Operation: 0700 - 1630 ET, Monday through Friday, excluding holidays
FSIS product standards for MSM differ from Canadian standards. Please refer to 9 CFR section 319.5 (for red meat species) and 381.173 (for poultry species) for applicable standards.
Operators preparing MSM intended for export to the United States must develop, implement and maintain appropriate control programs to ensure compliance with applicable requirements.
Note: MSM derived from bovine is prohibited (ref. MOP 11.7.3.2.1.2)
FSIS product standards for meat recovered using AMR systems differ from Canadian standards. Please refer to 9 CFR section 318.24 for applicable standards.
Operators recovering meat using AMR systems intended for export to the United States must develop, implement and maintain appropriate control programs to ensure compliance with applicable requirements.
Note: Dorsal Root Ganglia (DRG) is not allowed in meat (all red meat) recovered using AMR system as per U.S. Regulations.
Footnotes
1 including mechanically separated meat and finely textured meat
2 In MPIP establishments the veterinarian also has functional supervisory authority over company employees conducting ante-mortem and post-mortem examinations.
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