Can a warehouse legally export products from a delisted plant?

Question: My warehouse is approved for export to China. I have a customer who wants us to repack some pork product in boxes bearing our company name, USDA legend, and establishment number. The product arrives to us fresh in 2,000 lb. combo bins. All the export documents will have our name and establishment number. If some of the product arrives from pork plants that are delisted to China, can we still export it since we are approved for China and our establishment number appears on all the export documentation?

Answer: After checking the USDA Food Safety and Inspection Service (FSIS) export requirements for China, it would be problematic for you to export product from a plant that has been delisted. Below is language from FSIS that raises concern.  The sentence below applies to the situation.

“Plants Not Eligible to Export

Meat and poultry products produced or stored at the establishments listed below are not eligible for export to China until further notice. Meat and poultry products produced at other establishments from raw materials originating from these establishments are also not eligible for export to China.”

Please visit the FSIS website for more details, including the list of establishments ineligible for export to China.  If some of the product in question is coming from one of the plants listed on this site, then including that product in a shipment to China could be a problem and put your facility in a vulnerable position.

Answer provided by Lowell Randel, GCCA Vice President of Government and Legal Affairs


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