Dear Stephen,
You bring up a number of interesting questions surrounding the "blended
product" issue. We are running into this issue on products from
countries such as China where raw materials are brought from around the
world and reprocessed (substantially transformed) into finished
products.
As I read the regulations, the focus is on the consumer being advised
what is in each package. Your example/question of shrimp from Vietnam
and China is a good one. I would think that if no shrimp from Vietnam
was used on a particular day then it should not be on the label. From a
practical standpoint at the plant, I would be sure to use raw material
from both countries all the time to so that I would not have the expense
of separate stock keeping units.
Taking another look at this example, what happens when both are used in
the course of a day's production. Do the products have to be mixed
before being placed in the package? What if the proportion of each
product varies throughout the day so the prominence by weight changes
throughout the production run or bag to bag? Your
segregation/commingled question is a key issue.
Another excellent point you bring up is the use of "may contain shrimp
from." which does seem to go against the spirit of the regulation but
may be necessary from a practical standpoint. We have a situation where
we process in China groundfish mainly from Russia and also from Norway
(same species). Our label reads "harvested in Russia and Norway" and
"processed in China". With this labeling, the production will never
contain more Norwegian than Russian fish and will always contain at
least some Norwegian fish.
It will be interesting to hear from others, both from the production and
regulatory standpoints, to better understand how to best marry the
practical with regulatory intent.
George Souza
Endeavor Seafood
172 Thames St.
Suite 300
Newport, RI 02840
Phone 401-841-5412
Fax 401-841-8639
-----Original Message-----
From: owner-seafood@ucdavis.edu [mailto:owner-seafood@ucdavis.edu] On
Behalf Of Stephen Thompson
Sent: Monday, June 14, 2004 5:12 PM
To: UC Davis Seafood List
Subject: Country of Origin Labeling
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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