7 replies to this topic

[Naamfon]

Would anybody kindly tell me is there any regulations about
1. For Raw Ready to eat product , can export to USA or not ?
2. If can export, Have any standard/specifications of Raw RTE, finished product, (I only found minimal cooking by consumer product in www.fda.gov)
Thank you & regards,
naamfon

[Charles.C]

Dear Naamfon,

Welcome to the forum!

RRTE what exactly ? Fresh oysters???

I am guessing the answer is probably no for many items but it may "depend" on what it is.

Rgds / Charles.C

[Naamfon]

Thank you for you kindness reply ka Charles.C .
RRTE is fresh salmon , fresh srimp.
Regards,
naamfon

[Charles.C]

Dear Naamfon,

Just to avoid any possible confusion. These items are to be consumed raw, correct? Presumably for the sashimi/sushi market or to be subsequently used in marinated form perhaps ?

Although I hv some experience with general seafood business, I hv not encountered export of the products you mention to USA in the RRTE category. Do you plan to ship by ice/air or frozen/sea ?? (just curious )

My initial suggestion would be to consult yr local fishery organisation as to whether export to USA is permitted at all / has special requirements (may relate to the specific species/origin of the raw material for example). If export is possible, I anticipate you will be faced with 2 types of specification, (1) the official import requirements imposed by the US/FDA on arrival and (2) the requirements for the customer/intended use.

No.2 is typically defined by the contractual purchasing specification of course (ie from the receiver). No.1 is usually a composite of (mainly but not exclusively safety related) BCPA characteristics. In case of Japan, I believe the official specs for RRTE are predictably more strict (eg microbiological) compared to "raw-to-be-cooked" items but USA hv no idea, sorry. I hv some knowledge of typical US micro. import specs for raw non-RTE shrimp/fish (available on the IT) but i don't remember seeing the category which you are currently interested in. Nonetheless it may well exist.

Hopefully, there are some RRTE seafood experts to USA here ?

Rgds / Charles.C

[Naamfon]

Now Naamfon don't have any plan to export those products to USA but in the future maybe
ohh..yes sahimi/sushi are same my meaning. I only found chemical/microbiological specification of RTE (minimal cooking by consumer) but don't know specification or standard of RRTE.
However , Thank you Charles.C for your kinfdness replied
Have a nice day,
naamfon

[Naamfon]

today I found FDA and EPA Safety Levels in Regulations and Guidance for seafood
http://www.fda.gov/d...e/UCM252448.pdf

told about level of microbiological and chemicals in seafood - POST-HARVEST PROCESSED CLAMS, MUSSELS, OYSTERS, AND WHOLE AND ROE-ON SCALLOPS, FRESH OR FROZEN, THAT MAKE A LABEL CLAIM OF “PROCESSED TO REDUCE VIBRIO PARAHAEMOLYTICUS TO NON-DETECTABLE LEVELS”
- The term “fish” refers to fresh or saltwater finfish, crustaceans, other forms of aquatic life other than birds or mammals, and all mollusks, where such animal life is intended for human consumption , as defined in the Fish and Fishery Products, “Definitions,” 21 CFR 123.3(d).

not sure it meaning of fresh oysters and fish ready to eat or must cooking before eat

[Charles.C]

Dear Naamfon,

Regarding yr first paragraph, I agree the table text is somewhat mysterious. An explanation is given here –
http://www.fda.gov/F...ogram/UCM053543

Regarding 2nd paragraph, without reading up yr ref.i expect “fish” is only being used as a generic short form for the various types of seafood mentioned. I doubt that any assumption regarding subsequent usage is intended. Some countries also use “fish” to literally mean "only fish".

Most of the parameters referred in yr linked table clearly define their applicability. It is possible to make some deductions where no specific restriction is mentioned, eg V.parahaemolyticus is not normally controlled for non-RTE products (see row5) unless otherwise stated for a specific product type (eg row6).

Rgds / Charles.C

[Naamfon]

Thank you Charles.C