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Export Library

Q&A

When does a label on product to be exported need to be approved as a sketch by Labeling and Consumer Protection Staff in Washington?

The FSIS Export Library must be consulted to determine if a country has special requirements. Additionally, changes may be desired in ingredients, product names, etc. which cause the label to deviate from permitted domestic requirements (See E below). The following are possible export labeling situations and their approval requirements:

 

Label Attributes

Approval Required

Regulatory Authority

A

1. English only

2. Meets FSIS requirements

SAME APPROVAL AS FOR DOMESTIC USE; generic approval allowed if allowed domestically

 

Meat - 9 CFR 317.4 or 9 CFR 317.5 Poultry - 9 CFR 381.132 or 9 CFR 381.133

B

1. Bilingual1

2. Meets FSIS Requirements

3. Containers NOT marked "For Export Only" (implies possible usage for domestic or export)

LCPS Sketch Approval required

Meat - 9 CFR 317.4 or 9 CFR 317.5 Poultry - 9 CFR 381.132 or 9 CFR 381.133

C

1. Bilingual1

2. Meets FSIS requirements

3. Containers marked "For Export Only"

GENERIC APPROVAL allowed for addition or deletion of direct translation of foreign language on English label which qualifies for generic approval or which has already been sketch approved by LCPS

Meat - 9 CFR 317.4 or 9 CFR 317.5 Poultry - 9 CFR 381.132 or 9 CFR 381.133

D

1. English or bilingual1

2. Containers marked "For Export Only"

3. Meets FSIS requirements

4. Accompanied by foreign language "sticker" with special labeling information required by the country

1. Labeling

a. If English only , see A

b. English and foreign language -

see C

2. "Sticker" - allowed without LCPS approval if Letter of Guarantee provided by exporter

1. Meat 9 CFR 317.4 or 9 CFR 317.5 Poultry - 9 CFR 381.132 or 9 CFR 381.133

2. Letter of guarantee required by FSIS Directive 9000.1 for foreign language "Stickers"

E

1. English or bilingual1

2. Containers marked "For Export Only"

3. Does not meet FSIS requirements

1. LCPS Sketch approval required

2. Requires support documentation verifying foreign government acceptance of the labeling deviation.

1. Meat - 9 CFR 317.4 or 9 CFR 317.5 Poultry - 9 CFR 381.132 or 9 CFR 381.133

2. 9 CFR 317.7 / 381.128

F

1. Foreign language only (must have Est. Number and Inspection Legend in English)

2. Marked "For Export Only"

3. May or may not meet FSIS requirements (translated)

1. LCPS Sketch approval required

2. If does not meet FSIS requirements see E above.

Meat - 9 CFR 317.4 Poultry - 9 CFR 381.132

1 Bilingual can mean contiguous insertion of the foreign language or a separate foreign language label.

 

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