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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:

Brokers are not required to be on the list, only the final processor. Any brokers currently on the list will be removed. Brokers may only ship products to Vietnam that originate from a processor on the list.
It was confirmed NAFIQAD wants the competent authority to send originals of the Appendix 3 forms for each firm requesting approval and listing. This is to be accompanied with the authority’s completion of Appendix 1.(Electronic delivery is desired but not possible at this time.) It was requested the firms that have already submitted requests be approved and NOAA will correct their submissions. However NAFIQAD stated this is not possible. Additional information, in the form of the process flow diagram, is required for each submission.
NAFIQAD desires NOAA to inspect and certify the products being sent to Vietnam. Firms should join the Seafood Inspection Program as approved establishments. NAFIQAD requires a pre-shipment clearance process for each shipment to Vietnam. However our Program policies and procedures are understood and NAFIQAD has agreed to its terms. This means that, depending upon your level of participation in our Program, not every shipment must be lot inspected.
A certificate must accompany every shipment to Vietnam. Further the certificate must have the name of the producer on the list.
The name of the producer on must be on the label. This includes the primary and shipping containers. Also the labels must be bilingual (stated in Vietnam Circular 13).It was understood product has been entering the country without this being accomplished. However at any time a shipment could be stopped for this reason.
Firms shipping product destined for reprocessing for export do not have to be on the list, but a certificate is still required. The statement “Product is destined for reprocessing and export.” will be entered on the certificate.
It was determined a new certificate would be developed based on the Codex model. A sample certificate was provided and is under discussion.

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/united-state-approved-list-updated-26-01-2011/view

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:

Forward “Letters of Request for Approval” from US exporters to DIPOA
Approve processing facilities under the USDC SIP Approved facilities program prior to export certification
Certify the product and species being exported
Verify that the exporter is on the Brazilian Approved List (Ministério da Agricultura, Pecuária e Abastecimento – MAPA , Secretaria de Defesa Agropecuária – SDA, Departamento de Inspeção de Produtos de Origem Animal – DIPOA, Serviço de Inspeção Federal – SIF)
Verify the exporter completed label registration forms prior to submission. (Label Packages will be scanned and sent to SIP HQ after supervisory review. SIP HQ will return electronic approval and then the packages will be forwarded to US Embassy Brazil via the regional offices)
Lot inspect all shipments
Issue SIP Export Health certificates for all shipments. (English/Portuguese certificate to be Approved) The standard US Export Health certificate designed for Brazil will continue to be issued.

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

Forward a “Letter of Request for Approval” to the regional SIP office, to be forwarded by the SIP to gain placement on the Brazilian Approved list. Regional SIP will review and verify the letters then forward to SIP HQ for final approval and forwarding to US Embassy Brazil
US Processing facility must be under the USDC SIP Approved facilities program prior to export
After Facility Registration is approved, the US facility must identify a Brazilian importer and complete a label registration form. (NOAA will sign this for verification, only for USDC SIP Approved Facilities)
The label registration form package must be presented to Regional SIP offices, to be forwarded to FAS on to DIPOA for approval after review and verification from the regional supervisor and approval from SIP HQ. All products destined for Brazil will have a USDC/NOAA/SIP inspection prior to departure.
All inspected product must have the SIP Export Health certification for Brazil prior to shipment.

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

Then choose: Pais: "Estados Unidos"
Area: " Pescado"
Do not choose anything on " Produto" leave in blank
Then press " relatorio"
Every time it generates an updated pdf list.

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.

2 Copies must be submitted for each label
Sketches in original form and color (if not actual size dimension shall be indicated)
Each label will have at least the following information:

Trade name of fish (from Infopesca list in Portuguese)
Firm name, address, CFN or FEI number
How product is preserved
Production and expiration dates on primary and master packaging (actual dates)

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

1.1 Enter the “NOAA Seafood Inspection Program”
1.2 Blank space for U.S.
1.3 Enter sequential label number/CFN
1.4 Leave Blank
1.5 Company Name
1.6 Company Address
2 Petition to DIPOA with Name and signature
3 Check the appropriate box
4.1 Enter name of product (Infopesca in Portuguese)
4.2 Enter the Brand Name
5.1 Check appropriate box
5.2 Check appropriate box
6.1 Enter declared net weights
6.2 Enter all possible net weights firm may use
7 Enter producer address
8 Enter signature and typed name of plant legal representative and address
9.1 Enter the “NOAAA Seafood Inspection Program”
9.2 Enter sequential plant label number/CFN
10 Enter all ingredients in rounded percentages (e.g. 19% or <1%
11 Enter flow diagram of production and complete description of production methodology
12 Enter a complete description of methodology
13 Enter a description of storage conditions (e.g.. required temperatures)
14 Enter a complete description of the food safety and quality controls
15 Enter a complete description of transportation conditions and controls
16 Generally should be left blank
17 Enter all specialized regulatory requirements specific to the product (e.g. LACF registration, time/temperature parameters)
18 Enter address of production firm
19 Enter name of legal representative and signature

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

1 Trade name of product (Infopesca in Portuguese)
2 Ingredients in descending order including additives
3 Name of producer
4 CFN or FEI
5 Lot Identification
6 Date of Production (day/month/year)
7 Date of Expiration (day/month/year)
8 Net Weight
9 Registration number of SIF/DIPOA (4 figures/sanitary control number), country of origin,

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_List11.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:

Submit your request to the nearest Seafood Inspection Program Regional Inspection Branch. When submitting the request firms must provide the full name of the firm to be listed, the CFN or FEI number, address, type of operation (broker, processor, vessel, etc.) and products to be included on the list.

Submission requests for inclusion on the list are collected by SIP and submitted monthly. Inclusion on the list takes a minimum of 45 days from the time it is submitted by the NOAA Seafood Inspection Program to Rosselkhoznadzor.

Once a firm is listed and desires a certificate, they are to contact the servicing Regional Inspection Branch for such a request. The product lot must not only originate from and be handled by approved establishments it must also be inspected either through in-plant inspection service or lot inspected. Firms must be able to provide evidence the product came through approved establishments throughout the supply chain. (Note: As we work the final elements of the MOU, we are now only requiring the product be processed by an approved establishment. The industry will be notified through this website when it is required to have all points in the chain approved.)

Certificates must be issued prior to shipment.

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:

The establishment must implement HACCP and have a system to ensure the recall and traceability of products;
Products must meet the requirements of the United States and be allowed for free sale;
Raw materials used to produce fish oil, fish meal or other aquatic animal proteins may be aquatic animals caught in domestic waters or in the open sea; aquacultured animals; or by-products from plants manufacturing aquatic products for human consumption. Aquatic animals killed for disease eradication cannot be used as raw materials.
The product must not contain any ingredients of non-aquatic animals and must not be contaminated by any products of animal origin from third countries.
Products must be subjected to a heat treatment of at least 85C for 15 minutes or other time/temperature combinations that have been validated to be equivalent;
Effective measures must be taken to prevent contamination both during and post processing;
Fish oil, fish meal and other aquatic animal proteins must not contain hazardous substances which pose a risk to public or animal health and must be in compliance with the safety and hygiene standards listed below;
All fish oil, fish meal or other aquatic animal proteins intended for export to the PRC must be tested and found to be negative for ruminant proteins by PCR or other effective methods;
Products for export must meet the following microbiological requirements:

Salmonella: Absent in 25 g: n=5, c=0, m=0, M=0
Enterobacteriaceae: n=5, c=2, m=10, M=300 in 1 g

The end product must be packaged in new, clean, sealed, impermeable, moisture resistant and not easily broken materials and labeled in compliance with standards set by the PRC; or for bulk shipments, the containers or other means of transport should be thoroughly cleaned and disinfected with a disinfectant approved by the competent authority before use;
Each shipment must be accompanied with an original health certificate.

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

Obtain the appropriate laboratory analysis for shipment. Verification that each shipment meets the import country regulations will be done by SIP prior to issuance of the export documentation.
Obtain and complete the Request for Certification / Fishmeal Exports (available online or from the local SIP inspection office.
Forward the completed form to: NMFS.SI.Fishmeal@noaa.gov within the same email forward all 3rd party laboratory reports or NOAA/NSIL reports that support the shipment requirements to the destination country. All reports must identify “Lots sampled to the Lots being shipped.”
When submitting the request, make sure to use the following instruction to label the subject line in the email message: Company Name AND Facility FEI Number, country of destination, then use A-Z to mark multiple shipments on a single day. Example: Roberts Fish House, #3014244321, China, A Please make sure to use the correct FEI or CFN # listed officially on the Country of Destination Approved Fishmeal Exporter List
Allow up to 72 business hours for completion of documentation.
All certificates will be delivered overnight via UPS unless otherwise noted.

Link to Request Form

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

Resources

Notice to Companies Shipping Frozen Seafood to the People's Republic of China

AQSIQ and NOAA Agree in Principle to a New Fish and Fishery Product Health Certificate

Canada Begins Enforcement of New Aquatic Animal Import Regulations

New Registration Requirement for the People's Republic of China

Meetings between NOAA Fisheries and the Animal Plant Quarantine Inspection Service (AQSIQ) of the People’s Republic of China (PRC).

Our Vision:

"An informed society that has confidence in the seafood that they purchase, sell and consume today and in the future."

Our Mission:

To ensure the safety and quality as well as enhance the marketability and sustainability of seafood products for the benefit of the American consumer by providing science based inspection services to the seafood industry.