FDA and NOAA Update Certification Procedures for Seafood Exported to the European Union

New Seafood Export Certification Procedures Take Effect September 3

The U.S. Food and Drug Administration (FDA) is updating its listing and certification procedures for seafood products exported to the European Union (EU) in response to new EU export certification requirements.

Beginning September 3, 2026, seafood products exported to the EU will need to be accompanied by a certificate issued using the new FDA and National Oceanic and Atmospheric Administration (NOAA) procedures.

The new simplified export certificates will be required in addition to new EU catch certificates currently being implemented by the EU.

New Declaration Requirements for Seafood Facilities

The updated procedures address EU certification requirements prohibiting the use of certain antibiotics for growth promotion or for human medicine that apply to seafood products.

To satisfy these requirements, FDA will collect declarations of non-use from seafood facilities exporting products to the EU.

The declarations will be uploaded into FDA’s Export Listing Module (ELM) application for each affected facility. This information will then facilitate NOAA’s issuance of the required certificate for seafood exported by that facility.

Additional FDA and NOAA Guidance Is Coming

FDA has indicated that it will provide additional information regarding the new declaration procedures, along with a declaration template, through its Food Export Library.

NOAA will also update its industry guidance explaining how seafood exporters can request the new simplified export certificate.

Companies exporting seafood products to the EU should monitor both agencies for these additional resources as the September implementation date approaches.

What Seafood Exporters Should Know

Seafood products exported to the EU after September 3, 2026, will need to be accompanied by a certificate issued under the new FDA and NOAA procedures.

Seafood facilities currently exporting to the EU may wish to:

• Review the updated certification requirements
• Evaluate their FDA Export Listing Module information
• Prepare for the new declaration of non-use procedures
• Monitor FDA for the declaration template and additional instructions
• Review forthcoming NOAA guidance for requesting the new export certificate
• Prepare internal export procedures for the September 3 implementation date

EAS Perspective

The September 3 implementation date gives seafood exporters a relatively short period to understand and prepare for the updated certification procedures. Facilities exporting seafood to the EU should monitor FDA and NOAA guidance closely, particularly the forthcoming declaration procedures and template, and evaluate whether internal export documentation processes will need to be updated.

EAS Consulting Group will continue monitoring FDA and NOAA updates as additional implementation information becomes available.