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Export Certificates for FDA-Regulated Foods Containing Egg Products as an Ingredient

The USDA’s Food Safety and Inspection Service (FSIS) plans, effective November 10, 2014, to halt issuing export certificates for FDA-regulated foods that contain an egg product(s) as an ingredient because USDA’s Agricultural Marketing Service (AMS) now provides this service.

FDA regulates the safe production, sanitary processing, and labeling of food products containing egg products.  Nevertheless, since it assumed responsibility for conducting the federal egg products inspection program from AMS on May 28, 1995, FSIS has been issuing export certificates of wholesomeness for prepared or manufactured food products that contain egg products as an ingredient.

On April 3, 2013, AMS announced the establishment of the Processed Egg and Egg Products Export Program.  The AMS program pertains to FDA-regulated, further processed eggs and egg products and composite foods containing egg products.  Pursuant to a Letter of Agreement between USDA’s Foreign Agricultural Service and the Office of International Affairs at FDA, AMS was provided with the authority to perform onsite verification of public health certification statements and issue export certificates on a fee for service basis.  The extent of the onsite verification process is directly related to the complexity of the certification statements required by the foreign country of destination for the food product.

Establishment of the export certification program is intended to allow U.S. processors access to expanding global markets, supporting AMS’ goal of promoting the marketing of U.S. agricultural products.  Companies interested in requesting the service should file an application with AMS.  Once the application is submitted, AMS will determine the import requirements of the foreign authority(s) for the food product(s) identified in the application.  AMS has established a program for verification of the source of the eggs and egg products used in the production of the food products identified for certification.  Additionally, AMS will verify that the product was produced in a processing facility in accordance with good manufacturing practices under sanitary conditions to certify that the products are fit for human consumption, as well as that the product meets the foreign government import requirements.  The verification of a product will require a minimum of two onsite visits per year.  If AMS determines that a company meets the established certification requirements, the company will be listed as eligible for export by product and country.  An eligible company then may contact AMS for an export certificate covering an accepted product(s) and identifying the foreign country.

Prior to shipping certified food products, exporters should have their importers confirm that the foreign country will accept AMS’ certification statements.  Additional packaging and labeling requirements also may need to be addressed with the importer before the food product will be allowed into the foreign country.

If you are an exporter of a FDA-regulated food that contains an egg product as an ingredient and need an export certificate(s), you should engage the AMS soon.  Please feel free to come to us with any questions related to AMS’ new verification and export certification program.

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