Product Imports Into the U.S That Contain Meat and Poultry: Maneuvering the Process?

By Ronnie Dunn, EAS Consulting Group Independent Consultant

Importing meat, poultry, and egg products into the U.S. can be a daunting and confusing task. There are numerous regulations and processes that must be followed spanning many U.S. government agencies. Much research needs to be done prior to the start of the process, or you can obtain assistance from a certified consulting service who are knowledgeable in the many steps and processes to accomplish this.

To import product into the U.S. that contain meat, poultry, and egg products, you must meet the requirements of two United States Department of Agriculture (USDA) agencies: FSIS and APHIS.

1. The Food Safety and Inspection Service (FSIS) is responsible for assuring that U.S. imported meat, poultry and egg products are safe, wholesome, unadulterated, and properly labeled and packaged.
2. The Animal Plant Health Inspection Service (APHIS) restricts certain animal products from entering the United States because of animal disease conditions in the country of origin.

If you choose to import product regulated by FSIS, you must make sure that the product originates from an FSIS approved source. This can be determined by visiting the FSIS Import & Export Library which lists all eligible countries and facilities in those countries eligible to import into the U.S. If not approved, the product then cannot be imported into the U.S.

FSIS allows for an exemption from inspection for certain foods that contain small amounts of meat, poultry or egg products as an ingredient, provided that the meat, poultry, or egg product component of these products is from an approved or eligible source. These food products are typically regulated by the FDA.

For meat and poultry “relatively small proportions” of meat ingredients are:

• 3% or less raw meat.
• Less than 2% cooked meat or other portions of the carcass; or
• 30% or less fat, tallow or meat extract, alone or in combination.

In the case of poultry, the “relatively small proportions” are:

• Less than 2% cooked poultry meat
• Less than 10% cooked poultry skins, giblets, or fat, separately; or
• Less than 10% cooked poultry skins, giblets, fat, and poultry meat (limited to less than 2%) in any combination.

The meat or poultry ingredients used in FSIS-exempted products must be from an eligible source. To be from an eligible source, the product must be prepared under USDA/FSIS inspection or in a foreign establishment certified by a foreign inspection system determined equivalent by FSIS.

Egg product requirements are a little different than meat and poultry.

For egg products, FSIS recognizes four approved sources. The egg product ingredient must be:

1. prepared under USDA/FSIS inspection
2. prepared for export to the United States in a foreign establishment certified by a foreign inspection system that has been determined equivalent by FSIS
3. derived from shell eggs that were broken, pasteurized, and properly stored prior to being incorporated into the food product
4. derived directly from shell eggs broken and immediately incorporated into the resulting food product.

Egg ingredients from broken shell eggs, as noted in item (4) above, that are not immediately incorporated into the resulting food product, must meet the requirements of item (3) above.

Importing meat and poultry, or products containing small amounts of meat, poultry, or egg products used as an ingredient and originating from countries with animal health restrictions that are exempt from FSIS reinspection, require that you apply for and obtain a VS-permit from APHIS. You must get this permit approved prior to importing the product. If these finished product foods are regulated by FDA, there may be additional import requirements, such as the Foreign Supplier Verification Program.

Once you maneuver your way through FSIS, APHIS, and potentially FDA, don’t forget that you also have to meet the requirements of Customs and Border Protection (CBP).

To avoid potential problems in the clearance of your merchandise once it enters a U.S. port, CBP strongly recommends that you familiarize yourself with CBP policies and procedures prior to importing/exporting your goods. Importing food for commercial use (resale)