March 12, 2004
Revoked March 14, 2008

Subject: CITES Universal Labeling Requirements for Sturgeon Caviar

Background: At the 11th Conference of the Parties to the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), member nations adopted a resolution calling for the use of non-reusable labels on commercial exports of sturgeon and paddlefish caviar. At the 12th Conference of the Parties to CITES, a resolution was adopted calling for additional marking requirements for caviar re-exports and caviar in domestic markets. Member nations also agreed that as of January 2004 they would only accept caviar shipments marked according to the universal labeling system.

Action: Effective immediately, all imports, exports, and re-exports of sturgeon and paddlefish caviar must be marked with a non-reusable label as described below. CITES permitting requirements and all other wildlife import/export requirements must still be met. Specific labeling requirements are as follows:

(1) Any primary container of caviar (tin, jar, or box into which caviar is directly packed) must bear a non-reusable label or mark. A non-reusable label or mark means that the label or mark cannot be removed without damage or transferred to another container. For the United States, the design of the non-reusable label or mark will be determined by the labeler.

(A) For exports and re-exports when re-packaging has not occurred, the label or mark must include a formula that provides the following information:

(i) Standard three-letter species code. Hybrids should be identified using the codes for the male and female parents, separated by the letter 'x'. For example: GUE x BAE.

(ii) One-letter source code of the specimen.

(iii) Two-letter International Organization for Standardization (ISO) code of the country of origin.

(iv) Four-digit year of harvest.

(v) Processing plant code (represents the plant that produces caviar or the exporter). This code can be letters or numbers, or a combination, as determined by the labeler.

(vi) Lot identification number (corresponds with the caviar tracking system used by the processing or repackaging plant). It does not have to be four digits.

(B) Example of label or mark. HUS/W/RU/2003/xxxx/yyyy, where xxxx=processing plant code and yyyy=lot identification number.

(C) If no repackaging occurs in an intermediary country, the non-reusable label from the country of origin is considered acceptable labeling.

(D) For exports or re-exports when re-packaging occurs, the label or mark on the primary container must be non-reusable and include the following information:

(i) Three-letter standardized species code.

(ii) One-letter source code of the specimen.

(iii) Two-letter ISO code of the country of origin.

(iv) Four-digit year of repackaging.

(v) Repackaging plant code that includes the two-letter ISO code for the repackaging country if different from the country of origin (indicated as DE-wwww in the label example below).

(vi) Lot identification or CITES document number (indicated as zzzz in the code example below).

(E) Example of repackaging label or mark. PER/W/IR/2003/DE-wwww/zzzz.

(F) Primary containers of mixed or pressed caviar must identify all of the species in each container and the quantity of each species. The United States does not recognize the use of the three-letter “MIX” species code.

(2) Labels on secondary containers (receptacle into which primary containers are packed) must indicate the exact quantity of caviar and provide a description of the contents.

(3) The CITES document or an annex attached to the document must contain all the information presented on the labels.

(4) For exports or re-exports from the United States, applicants must provide labeling information when applying for a U.S. CITES export or re-export document.

Contact:
U.S. Fish & Wildlife Service
Office of Law Enforcement
703-358-1949 703-358-2271 (fax)