Dear Subscribers,
We are working with several clients in the development of Country of
Origin Labeling programs for retail products. Although the ruling has
not been published, preliminary requirements appear to be ambiguous at
best and we are hoping those involved might have some comment.
In particular is a situation where a foreign processor is
"substantially" transforming product from other countries sometimes
during the same production. According to current Customs and FDA
regulation, this product would be labeled "Product of" that particular
country even though the raw material was from several source countries.
For the situation, we will ignore the "Wild Caught" vs. "Farm Raised"
method of processing requirement.
If the product was shrimp, we may be able to list the countries as
"Shrimp from Vietnam and China. Processed in Thailand". Would this meet
FDA and Customs regulations?
And, what if on a given day's production, no shrimp from Vietnam was
used in production? A separate label? "May contain shrimp from." seems
to defeat the spirit of the proposed rule. But, will it be necessary to
carry label inventories for every situation? Where is the line between
"segregation" and "commingled" products?
Thoughts and comments will be greatly appreciated.
Stephen Thompson
Seafood Quality Systems, LLC
A Division of Surefish, Seafood Quality Specialists, Inc.
1659 Drift Rd.
Westport, MA 02790-1623
Tel: 508.636.0728
Fax: 508.636.0729
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