This is a very interesting discussion. Country of origin has always been a
difficult issue to determine for the Federal Government
procurement/inspection offices and the new labeling will make my job a bit
easier. As you may be aware the Federal government (military, school lunch
program, prisons) are only allowed to by seafood from USA (Buy American
Act, Berry Amendment). Our requirements go as far as to state they must be
caught by a US Flagged vessel. Do the new labeling requirements address
this? If wild fish is caught by a Vietnam Fishing Boat, transferred to a
Cambodian tender and landed in China, would you name all three or is it a
product of Vietnam because that is the flag on the ship that caught it?
v/r
Gregory R. Scher
CW2, USA
Food Safety & Hygiene
Alaska District Veterinary Command
(907)353-5546 Fax: 4854
"George Souza"
<george@endeavors
eafood.com> To
Sent by: "'Stephen Thompson'"
owner-seafood@ucd <stephen.thompson3@verizon.net>,
avis.edu "'UC Davis Seafood List'"
<seafood@ucdavis.edu>
cc
06/15/2004 09:36
AM Subject
RE: Country of Origin Labeling
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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