To: Seafood HACCP Discussion List
On January 11, 2007, the US Food and Drug Administration posted "Import
Alert #16-128, 'Misbranded Catfish'" on its web site at:
http://www.fda.gov/ora/fiars/ora_import_ia16128.html This Alert
represents FDA's current guidance on labeling catfish. The revised
guidance is based on information that several countries are
aquaculturing Ictaluridae species and exporting them to the US. The
revision provides guidance to prevent the refusal of properly labeled
imported aquaculture catfish.
Because of the new provision added by Section 403(t) of the Federal
Food, Drug, and Cosmetic Act (21 U.S.C. 343 Misbranded
Foods), only catfish from the Ictaluridae family can be labeled as
catfish:
"The article is subject to refusal of admission pursuant to
section 801(a)(3) in that it appears to be misbranded
because it purports to be or is represented as catfish
but
is not a fish classified within the family Ictaluridae
[Misbranding, Section 403(t)]."
FDA's Seafood List (http://www.cfsan.fda.gov/~frf/seaintro.html)
provides Agency guidance on common or usual names for fish that meet the
provisions of 21 CFR 102. The species that are scientifically listed in
the Ictaluridae family and thus may be labeled as catfish under Section
403(t) are listed by their genus name below:
Ictalurus spp.
Ameiurus spp.
Pylodictis spp.
Trogloglanis spp.
Satan spp.
Noturus spp.
Prietella spp.
In the past, several non-Ictalurid fish species have been labeled using
the term "catfish" as part of their common or market
name. The non-Ictalurid fish that have been or were to be listed in the
Seafood List as having common or usual names containing
the term catfish and are affected by the new law are referenced in
Attachment A (visit the Import Alert #16-128 web site to view Attachment
A).
Here is what the FDA guidance from the Import Alert says about
procedures for identifying the species:
"Ictaluridae species are indigenous to North America. However, we have
been made aware that currently several countries are aquaculturing
Ictaluridae species and importing them into the United States. To assist
in preventing refusal of admission of properly labeled, imported
aquaculture-catfish, an importer/shipper may provide to FDA with each
shipment, the name and address of the aquaculture farm and include at
least one of the following documents or equivalent assurances that
support the identity of the species:
1) Proof of original purchase of the eggs from North
America and documentation that the farm raised
catfish are from eggs that are a species within the
Ictaluridae Family.
2) Positive species identification through Isoelectric
focusing or an equivalent procedure performed by an
accredited laboratory. Private Laboratory Guidance
can
be found at the following internet address:
http://www.fda.gov/ora/science_ref/lm/vol3/section/07.pdf
If testing of product to provide authenticity of species
is
performed or required, then all lots or codes should be
sampled. If only one lot or code is in the entry, the
testing lab should collect at least two units to test.
3) A letter from the country's competent authority
confirming that the shipment being imported into the
US is Ictaluridae catfish.
If the importer does not have any documentation supporting the identity
of the species, the shipment may be subject to detention
without physical examination. The district compliance officer will
determine whether the information provided by the
importer/shipper is sufficient to allow entry.
For questions regarding these criteria and/or products covered, contact
CFSAN/DOEP/Imports Branch, HFS-606, (301) 436-2146 or
HFS-417, (301) 436-1421.
If a suspected catfish species substitution is encountered that is not
covered by this alert, refer to The Seafood List
("FDA's Guide to Acceptable Market Names for Seafood Sold in Interstate
Commerce") at: http://www.cfsan.fda.gov/~frf/seaintro.html for name
verification. If the name is not on the List or if you have additional
questions, contact the Office of Seafood at 301-436-2300.
For questions or issues concerning science, science policy, sample
collection, analysis, preparation, or analytical
methodology, contact the Division of Field Science at (301)827-7605."
Pamela Tom
===========================================
Pamela Tom, Seafood Extension Program Manager
University of California
California Sea Grant
Web: http://seafood.ucdavis.edu <http://seafood.ucdavis.edu/>
(SeafoodNIC)
E-mail: pdtom@ucdavis.edu <mailto:pdtom@ucdavis.edu>
This archive was generated by hypermail 2b29 : Thu Jan 11 2007 - 20:45:35 PST