Annex N: Labelling of Meat and Poultry Meat Products Destined to the United States

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I. Purpose

This annex provides exporters with guidelines on the labelling requirements of meat and poultry products destined to the U.S. and which will be used by FSIS to determine compliance of imported products.

II. References

  • 9 CFR 301.2
  • 9 CFR 317.2
  • 9 CFR 317.5
  • 9 CFR 327.14
  • 9 CFR 381.133
  • 9 CFR 590.5
  • 9 CFR 590.410
  • 9 CFR 590.411
  • 9 CFR 590.950
  • 9 CFR 590.955
  • 9 CFR 590.956

III. Background

Operators exporting to the United States must adhere to the labelling standards incorporated in the USDA Federal meat and poultry inspection regulations. These operators will be fully accountable for the content and production of all labels, whether generically approved, modified without resubmission, or submitted to FSIS for review and approval. FSIS's Labeling and Program Delivery Division (LPDD) develops policies and inspection methods and administers programs to protect consumers from misbranded meat and poultry products. Further guidance on labelling issues may be obtained by accessing "A Guide to Federal Food Labeling Requirements of Meat and Poultry" - PDF (657 kb)

IV. Approval of labels on foreign meat and poultry products

  1. Operators are responsible for ensuring the accuracy of labelling for all products exported to the United States.
  2. Operators of establishments certified as eligible to export to the United States by a foreign inspection system have the authority to use generically approved labelling in accordance with 9 CFR 317.5 and 381.133
  3. Labels which display any printing, lithographing, embossing, stickers, seals or other written matter upon an immediate container (except for inspection legends or foreign establishment numbers printed or stamped on casings, bags, or wrappers) must be approved by FSIS, LPDD.
  4. Copies of label approvals may be requested through official import inspection establishment management to the importer of record who filed the application when accuracy of labelling by the foreign establishment is in question.

V. Labels of shipping containers

A. A shipping container is an outside container (box, bag, barrel, crate, or other receptacle for covering) containing or wholly/partly enclosing any product packed in one or more immediate containers (per 9 CFR 301.2), as well as imported meat and poultry products packed in bulk or in protective coverings. When hanging carcasses are shipped from Canada, the entire transportation unit (trailer, truck) is considered the shipping container.

B. Labelling Requirements - Shipping Containers

1. Shipping container labels will have, in a prominent and legible manner, the following information:

a. Name or descriptive designation of the product.

i. Single ingredient products, carcasses, primals, subprimals or cuts can be labelled:

  • as the species of origin (i.e., beef);
  • as species without identifying the primal or subprimal when certain terms associated with various portions are part of the product name (i.e., pork chop, pork cutlet, beef steak, lamb filet, beef roast);
  • as species and primal or subprimal cut (i.e. pork shoulder butt collar);
  • as species, primal or subprimal cut and coin name (i.e., butt, cala, daisy, picnic, etc.). The species and coin name are not appropriate as a complete product name since it is missing the primal or subprimal cut (i.e., "pork shoulder picnic" is incomplete without "shoulder").
  • as species with generic designation (e.g. Boneless Beef Boneless Cuts (cut name), Bone In Beef Cuts (cut name), etc.). For example: in cases such as this, a foreign health certificate could state "Boneless Beef Tenderloins," and the shipping container could be labelled "Boneless Beef Cuts" or vice versa.
  • it should be noted that beef cheek includes nodes while that beef cheek meat does not. Beef cheek should be described as followed: "beef cheek with lymph nodes and fat attached" or similar wording. The same applies to salivary glands, e.g., beef salivary glands with lymph nodes and fat. Similar products designation should be used for pork cheek meat and pork head meat.

Product descriptions should meet the standard U.S. meat nomenclature such as that found in "The Meat Buyers Guide" of the National Association of Meat Purveyors (NAMP), the "Institutional Meat Purchase Specifications" (IMPS) of the Agricultural Marketing Service (AMS), or the "Uniform Retail Meat Identification Standards" manual (URMIS).

Unidentifiable cuts of meat (i.e. sirloin ends and pieces) intended to be used for further processing in which a declaration will be made on the further processed product (i.e., Beef Sirloin Stew) will have the proper name of the cut identified on the container. The abbreviations of meat cuts (i.e. Sir-But, Top-Sir) are not acceptable terminology.

ii. Processed Products.

When the shipping container contains fully labelled immediate containers, the product name on the shipping container label must be the same as it appears on the label of the immediate container. Ingredient statements, "cured with" statements, "injected with" statements, and other statements of the same nature are not required on the shipping container when the shipping container contains fully labelled immediate containers.

iii. Qualifiers, Claims, Grades, Declarations

When a qualifier, special or nutrition claim, grading terminology, or declaration is present, refer to Annex N-1 for guidance.

b. Canada, preceded by "Product of." However, if the name of the country appears in the mark of inspection of the foreign country or the shipping container contains fully labelled immediate containers, the phrase "Product of" need not appear;

c. The establishment number.

Note:

The following requirements apply regarding how to indicate the official establishment number of the establishment in which the product was processed:

  1. the establishment number is indicated within the meat inspection legend; or
  2. the establishment number is indicated outside the inspection legend elsewhere on the exterior of the container or its labelling, e.g., the lid of a can, if shown in a prominent and legible manner in a size sufficient to insure easy visibility and recognition and accompanied by the prefix "EST"; or
  3. the establishment number is indicated off the exterior of the container, e.g., on a metal clip used to close casings or bags, or on the back of a paper label of a canned product, or on other packaging or labelling material in the container, e.g., on aluminum pans and trays placed within containers, when a statement of its location is printed contiguous to the official inspection legend, such as "EST. No. on Metal Clip" or "Est. No. on Pan", if shown in a prominent and legible manner in a size sufficient to insure easy visibility and recognition; or
  4. the establishment number is indicated on an insert label placed under a transparent covering if clearly visible and legible and accompanied by the prefix "EST".

d. A shipping mark (export stamp). This unique mark is used to link the product to the foreign health certificate.

e. The name and address of either the Canadian establishment, distributor, or importer; unless it appears on the labels of the immediate containers inside the shipping container; and

f. A special handling statement, where applicable, such as "keep refrigerated", "keep frozen", "perishable, keep under refrigeration", or such similar statement as LPDD may approve in specific cases (317.2). Keep chilled is not acceptable terminology. Handling statements should be accurate for the product being presented for reinspection or they must be corrected.

C. Labelling Information

1. The labelling information must be:

a. Mechanically printed, stenciled, or stamped directly on the shipping container or on a self-destructive label affixed to the shipping container. Hand written labels or labelling information are not acceptable.

b. In the English language; however, in the case of products distributed solely in Puerto Rico, Spanish may be substituted for English.

2. Duplicate labelling information may appear on other panels of the shipping container (e.g. shipping marks may be applied to areas in addition to the principal display panel, including the top of the carton).

3. If a net weight is declared, it must be in avoirdupois weight (i.e. pounds, ounces) or liquid measure (i.e. fluid ounces, quart). It is acceptable to state the net weight in metric weight in addition to the avoirdupois weight.

VI. Labels of immediate containers

  1. An immediate container is a receptacle or other covering in which any product is directly contained or wholly or partially enclosed (per 9 CFR 301.2) and must include all mandatory labelling features. The following mandatory features appear on the label of immediate containers, as required by 9 CFR 317.2 and 381.116.
  2. The mandatory features include:

    1. Name of product (Refer to Annex N-1 for use of qualifiers considered part of the product name)

    2. Ingredients statement, if needed

    3. Canadian establishment number

    Note:

    The following requirements apply regarding how to indicate the official establishment number of the establishment in which the product was processed:

    1. the establishment number is indicated within the meat inspection legend; or
    2. the establishment number is indicated outside the inspection legend elsewhere on the exterior of the container or its labelling, e.g., the lid of a can, if shown in a prominent and legible manner in a size sufficient to insure easy visibility and recognition and accompanied by the prefix "EST"; or
    3. the establishment number is indicated off the exterior of the container, e.g., on a metal clip used to close casings or bags, or on the back of a paper label of a canned product, or on other packaging or labelling material in the container, e.g., on aluminum pans and trays placed within containers, when a statement of its location is printed contiguous to the official inspection legend, such as "EST. No. on Metal Clip" or "Est. No. on Pan", if shown in a prominent and legible manner in a size sufficient to insure easy visibility and recognition; or
    4. the establishment number is indicated on an insert label placed under a transparent covering if clearly visible and legible and accompanied by the prefix "EST".

      4. Handling statements, such as "keep frozen" or "keep refrigerated", if needed

      5. Net quantity of contents, if needed

      6. Manufacturer's or distributor's name and address

      7. Nutrition labelling, if needed

      8. Name of the country of origin, preceded by the words "Product of". The phrase "Product of" is required on all immediate containers of meat and/or poultry products. The phrase "Product of " is not required on a red meat carcass, primal or subprimal cut that prominently displays the name of the foreign country within the marking itself, e.g., the Canadian mark of inspection is a circle surrounding the word Canada and the establishment number.

      9. Safe handling instructions for raw and partially cooked meat and poultry products that have not undergone further processing that would render them as ready-to-eat and are destined for the consuming public. Exemptions to this requirement include imported products intended for further processing at an FSIS official establishment and all ready-to-eat products.

VII. Protective coverings

  1. At this time, protective covering is defined in FSIS Labelling Policy Memo 090B. The use of protective coverings is intended solely to protect the product against soiling or excessive drying during transportation or storage.

    Note: Product not intended for distribution directly to consumers is exempt from internal examination for protective covering labelling (e.g. Bulk Packed Frozen Boneless Beef).

  2. To qualify as a protective covering exempt from mandatory labelling features, unprocessed red meat products must be:
    1. Packaged in transparent wrappings
    2. Bear the country of origin (the words "Product of" are not required)
    3. Bear the foreign establishment number
  3. Optional information allowed on protective coverings includes:
    1. Company brand names
    2. Trade marks
    3. Code numbers

    Note: Protective covering does not need to be marked with an official mark of inspection if the product is stamped and the stamp is clearly visible through the transparent protective covering.

  4. If any additional information is applied to protective coverings, such as the name of product, ingredient statement, handling statement, safe handling instructions, net weight, manufacturer or distributor name, or nutrition statement, the covering will be considered an immediate container and will have to comply with all product labelling requirements (refer to VI).

VIII. Application of the inspection legend - Carcasses and primal parts

  1. Title 9 of the Code of Federal Regulations, Part 327.14 (a) requires that portions of fresh red meat products that are susceptible of being marked bear the official marks of the country of origin, preceded by the words "Product of" on each cut of meat. However, if the name of the country appears in the mark of inspection of the foreign country or the shipping container contains fully labelled immediate containers, the phrase "Product of" need not appear. Imported products susceptible of being marked include carcasses, each primal part of a carcass, beef liver, beef tongue, and beef hearts. Primal parts include the wholesale cuts of carcasses as customarily distributed to retailers (9 CFR 316.9(b)).
  2. Carcasses and Parts of Carcasses Not Imported in Shipping Cartons
    1. Labelling Requirements

      Labelled carcasses or parts thereof of cattle, sheep, swine, goats, horses, mules or other equine that are not containerized in shipping containers must include:

      • the establishment number;
      • a unique shipping mark;
      • the name of the country of origin, preceded by the words "Product of", unless the name of the country of origin appears as part of the foreign country's mark of inspection and is prominently and legibly displayed

      Acceptable methods of labelling may include packaging enclosing the product, a placard on the container, or a tag affixed to each unit of product.

  3. Primal Parts

FSIS regulations (9 CFR 316.9) require that each primal part of a carcass and each liver, beef tongue, and beef heart which has been inspected and passed be marked with the official inspection legend containing the number of the official establishment before it leaves the establishment in which it is first inspected and passed. This requirement is also applicable to product inspected and passed in a foreign establishment.

Beef
  • Round
  • Flank
  • Loin
  • Rib
  • Plate
  • Briskets
  • Chuck
  • Shank
Veal, Mutton, Goat
  • Leg
  • Flank
  • Loin
  • Rack
  • Breast
  • Shoulder
Pork
  • Ham
  • Loin
  • Belly
  • Shoulder
  • Jowl
Equine
  • Round
  • Loin
  • Flank
  • Rib
  • Plate
  • Brisket
  • Chuck
  • Shank

Boning, trimming, or skinning a primal part does not change its muscle tissue content and it continues to be a primal part that requires marking. Primal parts cut into marketable sections or sub-primal parts do not require marking.

IX. Unmarked inspected product (products to which the meat inspection legend is not applied as required under section VIII above)

  1. Unmarked primal parts will be allowed to move from an official foreign establishment, through a USDA/FSIS official import inspection establishment to a USDA/FSIS inspected official establishment for further processing, provided the shipping container is sealed in a manner to prevent tampering or substitution of product.
    1. If the shipment/load is assigned a type of inspection (TOI), the shipping containers will have to be resealed by the official import inspection establishment with tamper proof tape or another acceptable security means.
    2. If unaware of the product's final destination, the official import inspection establishment management or importer of record must verify (in writing) the final destination to the FSIS import inspector.
  2. Options for tamper-proof sealing of shipments of unmarked foreign products which have been inspected and passed but do not bear the official inspection legend on the primal parts include the following:
    1. In fully marked cartons closed with a tape bearing the foreign meat inspection legend. The seal provided by the tape will be such that the container cannot be opened without breaking the seal/tape. (Some polypropylene tape has not been found satisfactory for this purpose on product held under freezer conditions).
    2. In fully marked cartons (non-waxed or waxed) to which a strap has been applied that bears in a permanent manner, the company name and address or foreign country and establishment number.
    3. In fully marked combo bins with a liner that can be sealed with a company seal bearing the company name. The company seal may be a plastic strap or a metallic seal and will be non-removable without breaking the seal or tearing the liner.
    4. In fully marked reusable containers and waxed cartons closed with a company seal bearing the company name and establishment number. Such a company seal must make it very difficult to open these reusable waxed cartons or returnable containers without breaking the seal.
    5. In fully marked containers closed by a pressure sensitive tamper evident label that doubles as a seal. This label sticker will display either the meat inspection legend or a complete label in compliance with shipping container label verification requirements.
    6. In fully marked containers shrink wrapped with a stick-on foreign meat inspection legend or a complete shipping container label on the outside of the shrink wrap.

    IIP will hold any shipments and contact the RIFO if shipments arrive with any other means of tamper proof sealing the carton/container. The RIFO will determine acceptance of any alternative means of sealing cartons on a case by case basis.

    Note: Applying a seal (either government or company) to the transportation vessel is not an acceptable option for tamper-proof sealing.

X. Alternative packaging procedures

Consumer packaged, fully marked and labelled meat and poultry products

i. Policy

Palletized, consumer packaged (including food service - hotel, restaurant or institution - HRI), fully marked and labelled meat and poultry products may be exported to the United States with the shipping marks and shipping container label applied to the outside of the pallet, rather than to individual tray packs or cartons. However, the pallet must move as an intact unit into distribution.

ii. Provisions for alternative packaging procedures

A. Packaging and palletizing

  1. Fully marked and labelled, packaged products are placed on pallets, most commonly in cartons or trays. The trays may be stretch wrapped in groups or individually. The products must be secured sufficiently to allow efficient handling during import reinspection sample selection.
  2. The trays or cartons are then palletized and subsequently stretch wrapped (or covered by corrugated material). The wrapped pallet is considered as one shipping container.
  3. Only one type of product may be assembled on a pallet.

B. Labelling

  1. When a pallet is identified as a shipping container, one main shipping label is required.
  2. A shipping container label must prominently and legibly display all required information.
  3. The shipping mark (for Canadian exports, this is defined as the export stamp number) must be applied to the pallet. Individual trays need not be marked with the shipping marks.

However, if the entire pallet does not move as an intact unit into distribution, then individual cartons or trays are considered shipping cartons and must bear the mandatory labelling requirements. Shipping marks must then be on the individual cartons or trays.

C. Certification

  1. When the pallet is presented as a shipping container, all production codes present on the retail package (such as date codes imprinted on the can or package) in the shipment must be provided as an addendum to the export certificate. This information can be provided either by the foreign inspection service or the importer.
  2. In the event that production codes are missing, incorrect or completely illegible, or the addendum does not accurately reflect the code present on the product, then the product will not permitted to move as an intact unit into the United States, until the information is provided. The importer can provide a corrected list of production codes associated with the product.

iii. Importer responsibility

  • when utilizing alternative packaging procedures, the importer is responsible for assuring that the entire pallet will be distributed to retail or the end user as an intact unit;
  • FSIS requires that individual units distributed prior to retail or to an end user must be identified with the appropriate labelling features, including the shipping mark, and must comply with 9 CFR 327.26 (a) or (b) or 9 CFR 381. 204 (a) or (b), as applicable;
  • if FSIS finds product in commerce that has not complied with these requirements, the product is subject to FSIS detention and/or seizure; and
  • if FSIS program officials determine that a company or importer consistently violates the provisions of this program, the establishment shall be removed from the program at the discretion of the Import Inspection Division (Deputy Director of Operations). The establishment will be notified through the Office of International Affairs that the plant has been suspended from the program. Establishments requesting program reinstatement must submit a letter, through the CFIA to FSIS, Office of International Affairs requesting reinstatement to the program. This correspondence must provide an explanation of which corrective actions have been taken to prevent future violations.

XI. Requirements for control programs for products and products bearing labelling claims (e.g., a reference to percentage lean)

Labelling claims such as reference to percentage lean to be marked on cartons of boneless meat entering the United States is not permitted unless the producing plant has a control program which can verify box label claims and a label approved by the FSIS in Washington.

Once the label approval has been received, a control program should be written, kept on file at the establishment, implemented by the operator and monitored by the operator and the inspection staff. No prior approval is needed, nor is it necessary to forward the program to Ottawa for transmittal to the U.S.

Certain other products such as mechanically separated meat or finely textured beef must also be produced under a control program to ensure that specific standards are met and confirm compliance. The operator is responsible to develop, implement and maintain the required control programs. The control programs must be auditable and effective.

The necessary elements of an adequate quality control system include:

  1. a statistically valid sampling system;
  2. a recognized analytical method;
  3. an acceptable record keeping system; and
  4. a detailed procedure for corrective action to be taken in case of process deviation.

The criteria for acceptability are that the control program must support the information shown on the label.

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