Food product label requirements when exporting into USA

Question posted by Mike Webb, on behalf of Natural Sports Nutrition in HU17

We are planning to export to the USA, we have a food product: Performance Meals www.performancemeals.com

We already have quotations for reviewing and recommending alterations to the label for the USA.

My question is: Is changing the label to a USA format a legal requirement by that country? I would have thought it would be exempt as it is an import and that it meets the strict labelling criteria of the UK.

Any help and guidance is much appreciated.

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Hello Mike,
Well the bad news is that you have to label your product to meet the regulations in each country of import. The formats and requirements are not standardised around the world and just because your product meets the UK requirements that does not mean it will be acceptable for import anywhere else. (See my recent blog re. Irn Bru)

It is not just the label but the contents of the product that change that matter country to country. You will find that some ingredients are fine in one country and absolutely forbidden in another.

For each of your intended destinations you need to research the ingredients rules and the labelling rules (these can vary between States in USA).

These rules are legal requirements and if you do not meet them your product will be impounded at import (or soon after) and most likely destroyed.

Regards,
Susan
enquiries@morley-consulting.co.uk
www.morley-consulting.co.uk

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Paul Bennett, on behalf of British Wonder LLC in United States.

Mike, I have posed the question to my customs agent here I will get back to you shortly with some information. I take it you are talking about the 4 items that appear on your home page?

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Mike Webb, on behalf of Natural Sports Nutrition in HU17.

Thankyou for the info, I feared that this may be the case.

Yes, it's for the 5 products listed on the website plus 6 new vegetarian ones.

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Dear Mike

Just wondered if you have FDA approval for the products going into the USA? I know that there can be some exemptions for payment, for a period of time for SMEs (if you are one, of course) but using FDA officials would help you to get a steer also, for what is OK to put on the labels and which ingredients might be problematic. Would be good to do some of the research yourself, if at all possible, which might be cheaper than completely outsourcing. I have a contact who knows this sector very well having imported drinks to the USA, I'll see what I can get from him for free!
All the best
Carol

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http://www.registrarcorp.com/fda-food/labeling/regulations.jsp?lang=en

Good information on the FDA website and LiveChat advisors there to help with any questions.

Carol

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Paul Bennett, on behalf of British Wonder LLC in United States.

Mike, this will require FDA Prior Notice.. Information on that is here
http://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/FoodDefense/ucm078911.htm

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Paul Bennett, on behalf of British Wonder LLC in United States.

Mike, you may have a issue here. This is what I got back from my customs broker.
"Paul,
See below - besides FDA and PN -
this all USDA!
Meat and poultry needs to be produced in a facility that has a mark of inspection and uses proteins (meat and poultry) from an approved source.
UK not approved, prohibited from exporting beef and chicken onto the US, would have to prove raw material (beef, chicken) from an approved country, and even then FSIS would be suspicious of blending."
https://help.cbp.gov/app/answers/detail/a_id/944

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Mike Webb, on behalf of Natural Sports Nutrition in HU17.

This is all fantastic info, many thanks everyone.

I am aware that there is a restriction on chicken from the UK and my intention was to source chicken from France (permitted) and use in the manufacture of our product here in the UK.

So if I understand correctly, this would be permitted even if the FSIS maybe suspicious of blending?

In regards to the beef, the british beef ban was lifted 5 months ago so there is some time before we get up to speed with the registration, but at least the ban has been removed.

It's our intention to launch our 6 vegetarian meals into the US to begin with before following up with the meat products next year.

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Paul Bennett, on behalf of British Wonder LLC in United States.

Keep an eye on you Beef... The ban may be lifted but the USDA are still not slowing it.
Here is a chart from their website http://www.fsis.usda.gov/wps/wcm/connect/4872809d-90c6-4fa6-a2a8-baa77f48e9af/Countries_Products_Eligible_for_Export.pdf?MOD=AJPERES

Either way, will get back to you will requirements for Vegetarian meals

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