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Annex N: Guideline for the marking and the labelling of meat and poultry meat products destined to the US

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I. Purpose

This document provides exporters with guidelines on the labelling requirements of meat and poultry products destined to the U.S. and which will be used by Food Safety Inspection Service (FSIS) to determine compliance of imported products.

II. References

III. Background

Operators exporting to the United States must adhere to the labelling standards incorporated in the USDA Federal meat and poultry inspection regulations. These operators will be fully accountable for the content and production of all labels, whether generically approved, modified without resubmission, or submitted to FSIS for review and approval. Labelling and Program Delivery Staff (LPDS) develops policies and inspection methods and administers programs to protect consumers from misbranded meat and poultry products. Further guidance on labelling issues may be obtained by accessing "A Guide to Federal Food Labelling Requirements of Meat and Poultry" (PDF – 516 kb).

IV. Approval of labels on foreign meat and poultry products

  1. Operators are responsible for ensuring the accuracy of labelling for all products exported to the United States.
  2. Operators of establishments certified as eligible to export to the United States by a foreign inspection system have the authority to use generically approved labelling in accordance with 9 CFR 317.5.
  3. Labels which display any printing, lithographing, embossing, stickers, seals or other written matter upon an immediate container (except for inspection legends or foreign establishment numbers printed or stamped on casings, bags, or wrappers) must be approved by FSIS, LPDS.
  4. Copies of label approvals may be requested through official import inspection establishment management to the importer of record who filed the application when accuracy of labelling by the foreign establishment is in question.

V. Labels of shipping containers

  1. A shipping container is an outside container (box, bag, barrel, crate, or other receptacle for covering) containing or wholly/partly enclosing any product packed in one or more immediate containers (per 9 CFR 301.2), as well as imported meat and poultry products packed in bulk or in protective coverings. When hanging carcasses are shipped from Canada, the entire transportation unit (trailer, truck) is considered the shipping container.
  2. Labelling requirements – shipping containers
    1. Shipping container labels will have, in a prominent and legible manner, the following information:
      1. Name or descriptive designation of the product
        1. Single ingredient products, carcasses, primals, subprimals or cuts can be labelled:

          • as the species of origin (for example, beef)
          • as species without identifying the primal or subprimal when certain terms associated with various portions are part of the product name (for example, pork chop, pork cutlet, beef steak, lamb filet, beef roast)
          • as species and primal or subprimal cut (for example pork shoulder butt collar)
          • as species, primal or subprimal cut and coin name (for example, butt, cala, daisy, picnic, etc.). The species and coin name are not appropriate as a complete product name since it is missing the primal or subprimal cut (for example, "pork shoulder picnic" is incomplete without "shoulder")
          • as species with generic designation (for example boneless beef boneless cuts (cut name), bone in beef cuts (cut name), etc). For example: in cases such as this, a foreign health certificate could state "boneless beef tenderloins," and the shipping container could be labelled "boneless beef cuts" or vice versa
          • it should be noted that beef cheek includes nodes while that beef cheek meat does not. Beef cheek should be described as followed: "beef cheek with lymph nodes and fat attached" or similar wording. The same applies to salivary glands, for example, beef salivary glands with lymph nodes and fat. Similar products designation should be used for pork cheek meat and pork head meat
          • ready-to-cook poultry which is to be or is labelled with descriptive terms such as "fresh frozen", "quick frozen" or "frozen fresh" or any other term implying a rapid change from a fresh state to a frozen state shall be placed into a freezer within 48 hours after initial chilling. During this period, if such poultry is not immediately placed into a freezer after chilling and packaging, it shall be held at 36°F (2.2°C) or lower (9 CFR 381.66 (f)(1))

          Product descriptions should meet the standard U.S. meat nomenclature such as that found in "The Meat Buyers Guide" of the National Association of Meat Purveyors (NAMP), the "Institutional Meat Purchase Specifications" (IMPS) of the Agricultural Marketing Service (AMS), or Canadian Food Inspection Agency's Uniform Meat Cut Nomenclature System (UMCNS).

          Unidentifiable cuts of meat (for example sirloin ends and pieces) intended to be used for further processing in which a declaration will be made on the further processed product (for example beef sirloin stew) will have the proper name of the cut identified on the container. The abbreviations of meat cuts (for example sir-but, top-sir) are not acceptable terminology.

        2. Processed products

          When the shipping container contains fully labelled immediate containers, the product name on the shipping container label must be the same as it appears on the label of the immediate container. Ingredient statements, "cured with" statements, "injected' with" statements, and other statements of the same nature are not required on the shipping container when the shipping container contains fully labelled immediate containers.

        3. Qualifiers, claims, grades, declarations

          When a qualifier, special or nutrition claim, grading terminology, or declaration is present, refer to Attachment 1 for details.

      2. Canada, preceded by "Product of." However, if the name of the country appears in the mark of inspection of the foreign country or the shipping container contains fully labelled immediate containers, the phrase "Product of" need not appear.
      3. The establishment number.

        Note

        The following requirements apply regarding how to indicate the official establishment number of the establishment in which the product was processed:

        1. the establishment number is indicated within the meat inspection legend or
        2. the establishment number is indicated outside the inspection legend elsewhere on the exterior of the container or its labelling, for example, the lid of a can, if shown in a prominent and legible manner in a size sufficient to insure easy visibility and recognition and accompanied by the prefix "est" or
        3. the establishment number is indicated off the exterior of the container, for example, on a metal clip used to close casings or bags, or on the back of a paper label of a canned product, or on other packaging or labelling material in the container, for example, on aluminum pans and trays placed within containers, when a statement of its location is printed contiguous to the official inspection legend, such as 'est. No. on metal clip" or "est. no. on pan", if shown in a prominent and legible manner in a size sufficient to insure easy visibility and recognition or
        4. the establishment number is indicated on an insert label placed under a transparent covering if clearly visible and legible and accompanied by the prefix "est"
      4. A shipping mark (export stamp). This unique mark is used to link the product to the foreign health certificate.
      5. The name and address of either the Canadian establishment, distributor, or importer; unless it appears on the labels of the immediate containers inside the shipping container; and
      6. a special handling statement, where applicable, such as "keep refrigerated", "keep frozen", "perishable, keep under refrigeration", or such similar statement as FSIS's Labelling and Program Delivery Staff (LPDS) may approve in specific cases (317.2). Keep chilled is not acceptable terminology. Handling statements should be accurate for the product being presented for reinspection or they must be corrected.
      7. Production dates within the range certified by the foreign inspection system, when the production dates are required by PHIS (for example period of ineligibility of country, establishment, product) at the time the application was submitted, or when the lot was received; and
      8. weight expressed in terms of avoirdupois weight (for example, pounds) or liquid (for example, ounces) measure.
  3. Labelling information
    1. The labelling information must be:
      1. Mechanically printed, stenciled, or stamped directly on the shipping container or on a self-destructive label affixed to the shipping container. Handwriting is not acceptable on labelling, except for the following: 1) adding the value of random net weights in open net weight statements; or 2) marking checks in pre-printed check-off boxes. Handwriting must be in permanent ink and
      2. in the English language; however, in the case of products distributed solely in Puerto Rico, Spanish may be substituted for English
    2. Duplicate labelling information may appear on other panels of the shipping container (for example shipping marks may be applied to areas in addition to the principal display panel, including the top of the carton).
    3. The product description on the labels on the shipping containers must match with the product description on the export certificate CFIA 5733.

VI. Labels of immediate containers

  1. Immediate Containers (meat and poultry) If the shipping containers contain fully labelled immediate containers, IPP are to verify that the immediate containers bear all of the mandatory label features, as required by 9 CFR 317.2 or 381.116.

    Note

    9 CFR 301.2 defines the immediate container as "the receptacle or other covering in which any product is directly contained or wholly or partially enclosed." If the product inside the box is not fully labelled, then the outside container for example, shipping container) is considered the immediate container and needs to bear all required labelling features of an immediate container including those stated in Section B above. Some features may not be included because of the type of product (for example, if the product is fully cooked, it does not need safe handling instructions; if the product is not sold at retail and it does not bear a nutrient content claim, then it does not need nutrition labelling).

  2. The mandatory features include:
    1. Name of product or descriptive designation of product (refer to Annex N-1 for use of qualifiers considered part of the product name)
    2. Ingredients statement, if the product is fabricated from two or more ingredients

      Note

      Products encased in casings must be labelled as to the source of its casings for example natural casings (indicating the species of origin) when not derived from the same species as the meat products contained in the casings or indicate that the casings are regenerated collagen casings in other cases. Please also note that APHIS has restrictions on the eligibility of casings of ruminant origin.

    3. Canadian establishment number;

      Note

      The following requirements apply regarding how to indicate the official establishment number of the establishment in which the product was processed:

      1. the establishment number is indicated within the meat inspection legend or
      2. the establishment number is indicated outside the inspection legend elsewhere on the exterior of the container or its labelling, for example, the lid of a can, if shown in a prominent and legible manner in a size sufficient to insure easy visibility and recognition and accompanied by the prefix "est" or
      3. the establishment number is indicated off the exterior of the container, for example, on a metal clip used to close casings or bags, or on the back of a paper label of a canned product, or on other packaging or labelling material in the container, for example, on aluminum pans and trays placed within containers, when a statement of its location is printed contiguous to the official inspection legend, such as "est. no. on metal clip" or "est. no. on pan", if shown in a prominent and legible manner in a size sufficient to insure easy visibility and recognition or
      4. the establishment number is indicated on an insert label placed under a transparent covering if clearly visible and legible and accompanied by the prefix "est"
    4. Special handling statements, such as "keep frozen" or "keep refrigerated", if applicable;
    5. Net quantity of contents, if applicable;
    6. Manufacturer's or distributor's name and address;
    7. Nutrition labelling, if applicable;
    8. Name of the country of origin, preceded by the words "Product of". The phrase "Product of" is required on all immediate containers of meat and/or poultry products. The phrase "Product of " is not required on a red meat carcass, primal or subprimal cut that prominently displays the name of the foreign country within the marking itself, for example, the Canadian mark of inspection is a circle surrounding the word Canada and the establishment number; and
    9. Safe handling instructions for not-ready-to-eat (NRTE) meat and poultry products that have not undergone further processing that would render them ready-to-eat (RTE) and are destined for the consuming public.

      Note

      Exemptions to the safe handling instructions include imported products identified in writing by the applicant as for further processing at an FSIS official establishment (see Section IX below). IPP are to refer to 9 CFR 317. 2(l) and 381.125 for further information on safe handling instructions.

VII. Protective coverings

Note

Products inside shipping containers may be packaged or wrapped in protective coverings without mandatory labelling provided that the shipping containers include all mandatory labelling requirements for immediate containers as referenced in VI above.

If shipping containers contain product wrapped in protective coverings, IPP are to verify that the protective coverings meet the regulatory requirements in 9 CFR 317.1(a). Specifically, IPP are to verify that:

  1. Processed or prepared product packaged in protective coverings include a statement of limited distribution on the shipping container (for example, "Packed for institutional use," etc.) and that protective coverings bear no required labelling features; unlabelled product may not be removed from shipping containers for further distribution nor displayed or offered for sale.
  2. Unprocessed meat cuts packaged in protective coverings bear no required labelling features except that such protective coverings may bear the foreign mark of inspection with country of origin and the establishment number, although this is not required.

    Note

    Primal parts as defined in 9 CFR 316.9(b) are required to bear the foreign mark of inspection.

  1. Optional information allowed on protective coverings includes:
    1. Company brand names
    2. Trademarks and
    3. Code numbers
  2. When any other mandatory labelling feature appears on a protective covering, IPP are to consider the protective covering an immediate container and verify that all regulatory requirements for labels on immediate containers are met (refer to VI).

VIII. Application of the inspection legend – carcasses and primal parts

  1. Title 9 of the Code of Federal Regulations, Part 327.14(a) requires that portions of fresh red meat products that are susceptible of being marked bear the official marks of the country of origin, preceded by the words "Product of" on each cut of meat. However, if the name of the country appears in the mark of inspection of the foreign country or the shipping container contains fully labelled immediate containers, the phrase "Product of" need not appear. Imported products susceptible of being marked include carcasses, each primal part of a carcass, beef liver, beef tongue, and beef hearts. Primal parts include the wholesale cuts of carcasses as customarily distributed to retailers 9 CFR 316.9(b)
  2. Carcasses and parts of carcasses not imported in shipping cartons
    1. Labelling requirements

      Labelled carcasses or parts thereof of cattle, sheep, swine, goats, that are not containerized in shipping containers must include:

      • the establishment number
      • a unique shipping mark
      • the name of the country of origin, preceded by the words "product of ", unless the name of the country of origin appears as part of the foreign country's mark of inspection and is prominently and legibly displayed
    2. Acceptable methods of labelling may include packaging enclosing the product, a placard on the container, or a tag affixed to each unit of product.
  3. Primal parts

    FSIS regulations (9 CFR 316.9) require that each primal part of a carcass and each liver, beef tongue, and beef heart which has been inspected and passed be marked with the official inspection legend containing the number of the official establishment before it leaves the establishment in which it is first inspected and passed. This requirement is also applicable to product inspected and passed in a foreign establishment.

    Primal parts as defined in 9 CFR 316.9(b)
    Beef Veal, mutton, goatte Pork Equine
    Round
    Flank
    Loin
    Rib
    Plate
    Briskets
    Chuck
    Shank
    Leg
    Flank
    Loin
    Rack
    Breast
    Shoulder
    Ham
    Loin
    Belly
    Shoulder
    Jowl
    Round
    Loin
    Flank
    Rib
    Plate
    Brisket
    Chuck
    Shank

    Boning, trimming, or skinning a primal part does not change its muscle tissue content and it continues to be a primal part that requires marking. Primal parts cut into marketable sections or sub-primal parts do not require marking.

IX. Unmarked inspected product (products to which the meat inspection legend is not applied as required under section VIII above)

Unmarked carcasses and Primal parts (Intended use). If the shipping conveyance (for example truck, or other such container) contains unmarked carcasses or unmarked primal parts, IPP are to allow the movement of the product to an FSIS official establishment for further processing, provided the shipping conveyance or the individual shipping containers are sealed to prevent tampering or substitution of product. Specifically, IPP are to:

X. Alternative packaging procedures

Consumer packaged, fully marked and labelled meat and poultry products

  1. Policy

    Palletized, consumer packaged (including food service – hotel, restaurant or institution – HRI), fully marked and labelled meat and poultry products may be exported to the United States with the shipping marks and shipping container label applied to the outside of the pallet, rather than to individual tray packs or cartons. However, the pallet must move as an intact unit into distribution.

  2. Provisions for alternative packaging procedures
    1. Packaging and palletizing:
      1. Fully marked and labelled, packaged products are placed on pallets, most commonly in cartons or trays. The trays may be stretch wrapped in groups or individually. The products must be secured sufficiently to allow efficient handling during import reinspection sample selection
      2. The trays or cartons are then palletized and subsequently stretch wrapped (or covered by corrugated material). The wrapped pallet is considered as one shipping container
      3. Only one type of product may be assembled on a pallet
    2. Labelling
      1. When a pallet is identified as a shipping container, one main shipping label is required.
      2. A shipping container label must prominently and legibly display all required information.
      3. The shipping mark (for Canadian exports, this is defined as the export stamp number) must be applied to the pallet. Individual trays need not be marked with the shipping marks.

        However, if the entire pallet does not move as an intact unit into distribution, then individual cartons or trays are considered shipping cartons and must bear the mandatory labelling requirements. Shipping marks must then be on the individual cartons or trays.

    3. Certification
      1. When the pallet is presented as a shipping container, all production codes present on the retail package (such as date codes imprinted on the can or package) in the shipment must be provided as an addendum to the export certificate. This information can be provided either by the foreign inspection service or the importer.
      2. In the event that production codes are missing, incorrect or completely illegible, or the addendum does not accurately reflect the code present on the product, then the product will not permitted to move as an intact unit into the United States. A corrected certificate must be provided with the required information.
  3. Importer responsibility
    • when utilizing alternative packaging procedures, the importer is responsible for assuring that the entire pallet will be distributed to retail or the end user as an intact unit;
    • FSIS requires that individual units distributed prior to retail or to an end user must be identified with the appropriate labelling features, including the shipping mark, and must comply with 9 CFR 327.26 (a) or (b) or 9 CFR 381. 204 (a) or (b), as applicable;
    • if FSIS finds product in commerce that has not complied with these requirements, the product is subject to FSIS detention and/or seizure; and
    • if FSIS program officials determine that a company or importer consistently violates the provisions of this program, the establishment shall be removed from the program at the discretion of the Office of Field Operations (OFO), Recall Management and Technical Analysis Division (RMTAD). The establishment will be notified through the Office of International Affairs that the plant has been suspended from the program. Establishments requesting program reinstatement must submit a letter, through the CFIA to FSIS, Office of International Affairs requesting reinstatement to the program. This correspondence must provide an explanation of which corrective actions have been taken to prevent future violations.

XI. Requirements for control programs fro products and products bearing labelling claims (for example, a reference to percentage lean)

Labelling claims such as reference to percentage lean to be marked on cartons of boneless meat entering the United States is not permitted unless the producing plant has a control program which can verify box label claims and a label approved by the FSIS in Washington.

Once the label approval has been received, a control program should be written, kept on file at the establishment, implemented by the operator and monitored by the operator and the inspection staff. No prior approval is needed, nor is it necessary to forward the program to Ottawa for transmittal to the U.S.

Certain other products such as mechanically separated meat or finely textured beef must also be produced under a control program to ensure that specific standards are met and confirm compliance. The operator is responsible to develop, implement and maintain the required control programs. The control programs must be auditable and effective.

The necessary elements of an adequate quality control system include:

  1. a statistically valid sampling system
  2. a recognized analytical method
  3. an acceptable record keeping system and
  4. a detailed procedure for corrective action to be taken in case of process deviation

The criteria for acceptability are that the control program must support the information shown on the label.

Attachment 1 – Labelling Claims, Qualifiers, Grades, and Standards

I. Qualifiers

  1. Examples that shall be included in the product name on the shipping container:
    • With natural juices
    • Water Added
    • X% water product
  2. Examples that do not have to be included in the product name on the shipping container:
    • Caramel colour added
    • Smoke flavour added
    • Containing up to X% of a solution
    • BHA.BHT added to help protect flavour
    • Binders added
    • Flavoured with (name of flavouring)
    • Calcium propionate added to prevent spoilage
    • Sprayed with a solution of potassium sorbate to maintain freshness

II. Animal production and raising claims

Animal production or raising claims are not considered part of the product name. Therefore, it is acceptable for the immediate container to contain the labelling "claim" but the shipping container doesn't. Some examples of animal production and organic claims are:

III. Negative and natural claims

Negative and natural claims are not considered part of the product name. Therefore, it is acceptable for the immediate container to contain the labelling "claim" but the shipping container does not. Some examples of negative and natural claims are:

IV. Nutrient content claims

Nutrient content claims are not considered part of the product name. Therefore, it is acceptable for the immediate container to contain the labelling "claim" but the shipping container doesn't. Some examples of nutrient content claims are:

V. Quality or yield grades

  1. Meat

    The use of "USDA" and/or a USDA quality grade (for example prime, choice, select) on the shipping or immediate container of imported meat products is unacceptable. Exceptions are:

    • Canada has a "prime" grade designation, so it is acceptable for product to be labelled "Canada prime"
    • The foreign country must have prior approval from USDA's Agriculture Marketing Service (AMS) to receive USDA graded product, process, repackage, and export it back to the U.S

    Any imported meat products with USDA quality or yield grades will be placed on HOLD. The product will remain on HOLD until the Agriculture Marketing Service (AMS) confirms that a control procedure has been approved for the foreign establishment that produced the product. IIP should contact their Regional Import Field Office (RIFO) for assistance.

    IIP may also refer to FSIS Labelling Policy Memo 101A, "Use of Quality Grade Terms and Subjective Terms on Labels," dated 8/30/88 and/or the Food Standards and Labelling Policy Book for information related to an individual company's claims of Choice, Select, Prime, and other grade term designations.

  2. Poultry

    AMS recognizes the Canadian Food Inspection Agency's (CFIA) poultry product grade designations provided the poultry graded for export to the United States satisfies the criteria for U.S. grades. Canadian product labelled with CFIA grades will be accepted provided the shipment is accompanied by an official CFIA grading certificate stating that the product meets USDA grade standards (for example "young turkey Canada A"). This certificate is in addition to FSIS's foreign inspection (health) certificate requirement for poultry.

    If graded product is received without the accompanying grading certificate, IIP will reject the shipment until a grading certificate is provided, or the reference to the poultry product grade has been obliterated or removed.

VI. Religious claims

USDA/FSIS does not require any certification for labelling in reference to a religious organization. This should not be confused with religious slaughter exemptions.

VII. USDA approved or certified establishment claims

Statements on imported products or their containers referencing that the foreign plant is approved or certified by USDA are inaccurate and should not be accepted. Some examples are:

Statements that are not false or misleading can be allowed. Some examples are:

VIII. Boneless beef trimmings or for manufacturing

Boneless beef labelled as "beef trimmings" is derived from the skeletal muscle from a beef carcass, including beef from advanced meat recovery (AMR) systems. Beef trimmings must have visible lean which historically has represented 12% lean tissue. Head meat and cheek meat are considered meat; however, they are restricted in certain products and therefore, must be declared as such (for example cannot be in a product declared only as "beef trimmings"). Beef tongue, lips, internal organs (for example., heart meat), and spinal cords are not considered to be "meat" and therefore, are not permitted in "beef trimmings."

IX. Labelling declaration requirements: "Microbial claims"

"For cooking only" or "For full lethality treatment" instructional statement claims for raw beef products can only be applied to raw beef testing negative for STEC or that is untested. Raw, non-intact beef and raw beef intended for non-intact use presented for importation and determined to be either positive or presumptive positive for STEC at the time it is offered for importation is adulterated and is not permitted entry into the United States (U.S.) (9 CFR 327).

Use of these instructional statement claims is optional, pending label approval by FSIS Labelling and Program Delivery Staff (LPDS) (these claims do not fall under the generic approval process). The instructional statement claims are not a control for Shiga Toxin-Producing Escherichia Coli (STEC). Labels will be approved only for countries that are eligible to export raw beef products to the U.S.

Raw beef products negative for STEC or untested, are eligible to bear the "For cooking only" or "For full lethality treatment" instructional statement claims and can only be further processed in official US establishments. These products cannot be re-exported, sent to State-inspected establishments, or enter commerce.

These products can be shipped through ID Warehouses or official establishments, pending delivery to the official establishment which applies cooking or full lethality treatment to eliminate STEC.

The responsibility of proving that the intended destination is a cooking establishment falls on the importer of record.

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