In response to Anne's question, the US Food and Drug Administration's Office of Seafood developed a question and answer web page in 1999 which addresses many seafood HACCP regulations: http://vm.cfsan.fda.gov/~dms/qa2haccp.html
The information below comes from the FDA's Q/A web site and addresses Anne's question.
Sincerely,
Pamela Tom
University of California
Sea Grant Extension Program
"B. Importer Verification
12. Question: What verification steps are needed relative to lots purchased by an importer from other importers?
Answer: The U.S. firm which owns the product at the time of product entry or the U.S. consignee has to comply with the importer verification requirements. However, any entity purchasing the product after entry does not need to comply with the importer verification requirements. It would be prudent, however, to have invoices showing the importer's identification."
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