The NOAA Seafood Inspection Program (SIP) announces changes in the Seafood Inspection Service Portal (SISP) that will directly affect those US stakeholders that export fishery products directly to the European Union (EU) as well as US stakeholders shipping fishery products to non-EU destinations, intended for further processing and re-export to the EU. The export health certification requirements have not changed. The revised options for IUU and Origin/Harvest documentation for EU and non-EU destinations is explained below.
When requesting an EU/EFTA export certificate package, customers will now receive the EU Export Health certificate for the destination country and be allowed to choose EU IUU, Annex IV 14.1, Annex IV 14.2 or any variation of these three Catch certificates. Product will be assigned to the appropriate Catch certificate by the customer completing the online request based on the source of the raw materials. This change was enacted to fully support the need to have both Health Certificates and multiple Catch documents on source materials for specific EU shipment documentation packages.
If a customer is shipping outside of the EU/EFTA, SIP will no longer issue the EU IUU Catch Certificate, Annex IV 14.1 or Annex IV 14.2 for that shipment. In this case, to obtain a catch/harvest certificate, customers will need to choose either the "Certificate of Origin - USA" or "Certificate of Origin - Non USA" depending on whether the raw material is US or Foreign sourced. The international norm for certification policy is to issue certification only to the destination country. Issuing a catch document that attests to EU requirements for a shipment destined to a non-EU country puts the SIP certification process at risk of losing its integrity. Therefore, SIP developed an origin certificate that indicates that SIP has verified the source of the product, whether it is sourced domestically or from a foreign country consignment with documentation referencing legal catch. If the shipment is later determined to be destined for the EU, either as is or part of further processing, SIP will issue the EU IUU Catch Certificate for that shipment as this form is required first to get an Annex IV document signed by the third (non-EU) country of transit/further processing and second to clear the corresponding shipment through EU border inspection posts. If a Certificate of Origin was initially issued, SIP will not charge for the issuance of this EU IUU Catch Certificate.
All these SIP documents are designed to follow traceability requirements of the various countries requiring this documentation. It is also not necessary, unless specifically required by a specific competent authority, to have the catch document issued prior to departure from the United States. It may be prudent if the shipment may end up in whole or in part in the EU to wait to be certain.
Please contact us if you have any issues with market access as a result of these changes.