After an 18-month transition period, full enforcement of USDA inspection of siluriformes fish, including catfish began on Sep 1, 2017. According to some Vietnam news reports, “the change will have potentially disastrous consequences for Vietnam catfish producers, because while the FDA does spot checks on a small sample of imports as they arrive, the USDA requires on-site inspections of production facilities. For countries like Vietnam, setting up an equivalent system could take years and effectively cripple the industry.”U.S. imports of fish and shellfish from Vietnam are very large, and reached $1.4 billion in 2016, about 7.2% of the $19.4 billion U.S. total imports of fish and shellfish that year
The USDA Food Safety Inspection Service (FSIS) recently published “compliance guidelines.”
The compliance guidelines contain information, in part, on how establishments can apply for a Grant of Inspection (GOI); submit labels for approval; develop written recall plans; comply with Sanitation Performance Standards (SPS) and Sanitation SOP requirements; and comply with HACCP requirements. This compliance guideline also contains information to help establishments understand sampling requirements and requirements for exporting and importing Siluriformes fish and fish products.
FSIS developed the guideline for the domestic industry. However, foreign countries that are interested in obtaining an equivalence determination from FSIS can also use it to inform the design of their inspection program.
Of particular interest to Vietnam are the differences between the “Transitional Period,” and “Full Enforcement”
During the 18-month transition period, Mar 1, 2016 – Sep 1, 2017,
▪ FSIS used “interim reispection strategy’ … Imported Siluriformes fish and fish product shipments were selected for reinspection and subjected to species and residue testing on at least a quarterly basis.
- Plants Eligible to Export Meat (Siluriformes Only) to the United States In accordance with the FSIS rule published on December 2, 2015 (80 FR, 75590), Vietnam and other countries have submitted documentation to FSIS showing that they have laws or other legal measures in place that provide the authority to regulate the growing and processing of Siluriformes fish for human food, and that will ensure compliance with the Food and Drug Administration’s regulatory requirements in 21 CFR part 123, Fish and Fishery Products, and have submitted a list of facilities approved to export Siluriformes fish from Vietnam
After Full Enforcement, beginning Sep 1, 2017,
1.For exporters, All imported shipments of Siluriformes fish/fish products into the U.S. will be required to be presented for reinspection to USDA.
By the end of the 18-month transitional period, September 1, 2017, foreign countries seeking to continue exporting such products to the United States must submit adequate documentation showing the equivalence of their Siluriformes inspection systems with that of the United States.[See Compliance Guidelines below]. As of April 7, 2017, Vietnam was at “Step 1” of the Initial Equivalencs process.
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