Panama Canal woes present nightmare for Latin American perishables trade: analyst
SOURCE: Journal of Commerce (joc.com)             
By: Richard Bright, Journal of Commerce analyst            
Nov 14, 2023, 11:26 AM EST

With delays on the Panama Canal already standing at 10 days for vessels that have not pre-booked a transit, there are growing concerns over the impact that drought-linked restrictions will have on the trade in perishable products from the West Coast of South America to the US East Coast and continental Europe.

The spot banana business out of Ecuador and the specialized reefer-centric Chilean grape season are especially vulnerable. There is considerable jeopardy: Unlike the regular weekly banana services out of Ecuador operated by Seatrade (Rayo to the UK and Northern Europe) and Cool Carriers (to St. Petersburg), which have pre-booked transit slots, seasonal deciduous fruit and spot banana cargoes do not.

To illustrate the point, both the recently loaded MV Fegulus and MV Green Costa Rica spot banana charters are having to wait patiently for their turn to cross the waterway. Under current circumstances, the vessels will likely be the last spot banana cargoes for the next six to eight months, particularly as Central America is about to enter the dry season. While this may be a lost opportunity from the perspective of a reefer operator, it could have serious implications for the Ecuadorean banana industry.  

If, for example, there is a surge in Ecuadorean banana production, as is usual early in the new year, shippers that might have chartered in tonnage to sell the excess on a spot voyage into the Mediterranean now have no option but to hope that the carriers have positioned enough equipment to handle the increase. With both the Seatrade and Cool Carriers’ liner services fully loaded, there will be no specialized reefer alternative if spot charters become impractical. 

At its maximum, the Panama Canal can handle 40 ship transits a day, a figure that has been eroded this year as months of record drought have taken their toll. By February next year, the number will fall to 18. The imbalance in the supply/demand equation has already had an impact, causing the daily slot auction values to spike. Last week, Japan’s Eneos Group paid $3.975 million to jump the queue, smashing the record of $2.85 million set the previous week. 

The position may be precarious for Ecuadorean bananas, but it will be significantly more problematic for Chile. Vessels loading table grapes, berries and stonefruit in Chile can be affected by any number of predictable and unforeseeable variables at both ends of the chain. These include weather-related picking and packing delays, inaccurate crop timing and volume estimations, berthing issues and port congestion in Valparaiso, and port congestion and delays in the Delaware River prior to a return voyage. To make the forthcoming season work, the dedicated reefer services will have no choice but to become as disciplined as those services operated by the carriers in order to meet their pre-booked transits.  

Delays poised to grow as transits cut further

If a vessel misses its laycan at Balboa, it will have to wait. That is not ideal for perishable cargo. And with the Canal authorities staggering the reduction in the number of transits over the course of the next few months, a 10- day delay today could readily become a 20-day delay by mid-January – and likely worse by February. With all Chilean grapes needing to arrive in the US before the April marketing order deadline, the situation in March could verge on the critical. 

In order for the Seatrade and Cool Carriers’ services to meet their laycans at the Canal, they may in some instances be obliged to cut and run, thereby sailing light. In which case in order to meet their volume contracts with shippers, the operators may have to employ additional “buffer” vessels to cover commitments. Logistically, this should not be a problem – there is enough tonnage. Commercially, however, it would not be ideal given that the yield on the Chilean program freight rates this year is already poor on fully laden ships. Meanwhile, in an absolute worst-case scenario, vessels destined for the USEC missing their Canal laycans will divert to the US West Coast and rail or truck cross-country. 

The carriers operating services on the same trade lane will be affected partly by the reduction in the absolute number of transits and partly because there will also be a limit in the vessel draft. Contingent on the size of the vessel, this limitation will oblige carriers to discharge containers in Balboa to be railed across the isthmus to Cristobal, from where they will be re-loaded. Although the railed containers are more likely to be dry vans than reefers, the transshipment process will inevitably delay the voyage and may also cause congestion in the container terminals at either end of the waterway.

CSMS # 58071580 - FDA publishes YouTube video “Importing FDA-Regulated Products: Human Foods”

The U.S. Food and Drug Administration (FDA) is excited to announce the release of a new YouTube video on the FDA’s Import Process for Human Foods.

Watch “Importing FDA-Regulated Products: Human Foods” now on FDA’s YouTube channel!

If you are importing a food product, there is a good chance it is regulated by FDA. The agency regulates all foods and food ingredients introduced into or offered for sale in interstate commerce, except for meat, poultry, certain processed egg products, and catfish, which are regulated by the U.S. Department of Agriculture. The regulatory requirements may depend on the specific nature of your product.

As part of the FDA’s commitment to protect public health by ensuring the safety of our nation’s food supply, we have developed this video to assist businesses, individuals, and governments in navigating the complexities of importing safe and compliant food into the United States. We encourage you to share this video across your networks, spreading awareness of this valuable resource among peers, colleagues, and interested stakeholders.

To successfully import food products into the United States, there are many things an importer should know regarding the products they are importing and their suppliers. Thisvideo will provide helpful information on the FDA import process for food including:

• Researching The Requirements

  • Food Facility Registration

  • Food Safety Standards

  • Labeling and Nutrition

  • Prior Notice

  • Additional Requirements

• Declaring the Shipment

• FDA Admissibility Decision

This video is the second in the “Importing FDA-Regulated Products” series. An introductory video on the general FDA import process in March 2022. Watch “Importing FDA-Regulated Products: the Import Process” now on FDA’s YouTube channel.

Additional Resources:

• For more information please visit:

o   FDA’s Import Program

o   Importing Human Foods

o   Prior Notice

o   Food Facility Registration

o   Labeling and Nutrition

o   Food Safety

§  Human Food Preventive Controls (PCs)

§  Current Good Manufacturing Practices (cGMPs)

§  Hazard Analysis Critical Control Point (HACCP)

§  Foreign Supplier Verification Program (FSVP)

o   How to Start a Food Business

o   Voluntary Qualified Importer Program (VQIP)

• To monitor the real-time status of a shipment, submit entry documents, submit locations for examination, and obtain Notices of FDA Action, please visithttps://itacs.fda.gov.

Contact Information:  

• For general import operation or policy questions, please contact the Division of Import Operations (DIO) at Imports@fda.hhs.gov.

• For regulatory questions or questions about specific food products, please contact the FDA’s Center for Food Safety and Applied Nutrition (CFSAN) athttps://www.fda.gov/food/resources-you-food/industry-and-consumer-assistance-cfsan

APHIS has authorized importing fresh baby kiwi fruit (Actinidia arguta) from France into the continental U.S.

PLEASE NOTE: ACIR changes will be reflected and available to print in eFile by close of business tomorrow.

This notice is to alert you to updates in the Agricultural Commodity Import Requirements (ACIR) database.

The Animal and Plant Health Inspection Service (APHIS) has authorized importing fresh baby kiwi fruit (Actinidia arguta) from France into the continental United States. Based on the findings of a pest risk analysis, APHIS has determined that applying one or more designated phytosanitary measures will be sufficient to mitigate the risks of introducing or disseminating plant pests or noxious weeds via the importation of fresh baby kiwi fruit from France. This change is effective September 26, 2023 (Docket No. APHIS-2022-0024).

The above change impacts the following CIR:

• Baby, Kiwi (Fruit) from France into Continental U.S. Ports

Maritime industry continues to prefer
route through Panama
SOURCE: American Journal of Transportation (ajot.com)                      Sep 06 2023

The Panama Canal announced that the queue of vessels waiting to transit has shown improvement. Standing at 108 at both entrances to the waterway, there are 20% less vessels waiting in total since last week (135), which is normal for this time of year.

An extended dry season and the El Niño phenomenon caused the Panama Canal to implement measures earlier this year to save water, in order to maintain high reliability levels. While these measures and the season’s high vessel demand have had an impact on waiting times for some –mostly for vessels without reservations— such demand underscores the maritime industry's continued preference for the route between the Atlantic and Pacific Oceans.

Results to Date (Fiscal Year 2023 October 1st – September 30th)

One month before the end of Fiscal Year 2023, the Panama Canal total transits are 799 above budget and 470 million tons have transited the Canal, on budget.

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The number of vessels on stand-by will depend on market demands. As we approach the peak season at the Panama Canal, and if diminished rainfall patterns remain within projections, a queue of vessels above the usual is expected, but measures taken by the Canal have proven effective. Those measures are:

1. For the Neopanamax locks, 13.4 meters (44 feet) maximum draft levels (down from an average of 15.2 meters (50 feet) last year.

2. For the Panamax locks, an average of 32 transits per day (down from 36)

The Panama Canal urges its customers to make reservations to transit, as this allows them to secure a spot. Approximately 50% of transits (most of which use the Panamax locks) do not make reservations and transit on a first-come, first-served basis. The Panama Canal makes sure to provide timely information to all its customers.

Lake Levels

The lack of rainfall has impacted Gatun Lake, now at 24.2 meters (79.7 feet), compared to 26.6 meters (87.41 feet) in September of previous years.

Generally, the lake ends a normal rainy season at 27.1 meters (89 feet) in November and ends the dry season at the end of April at 25.9 meters (85 feet). Measures taken will be maintained for the remainder of this year and throughout 2024, unless weather conditions change significantly from current forecasts.

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See full article: American Journal of Transportation

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2023 Trade Facilitation and Cargo Security (TFCS) Summit

Omni Boston Hotel at the Seaport

450 Summer Street, Boston, MA 02210

April 17-19

U.S. Customs and Border Protection (CBP) will host the 2023 TFCS Summit on April 17-19 at the Omni Boston Hotel at the Seaport and virtually via webcast. Sessions will include discussions highlighting the latest requirement updates and best practices for navigating today’s complex supply chain challenges.

REGISTRATION NOW OPEN

To register click Register Now.

(Registration will close Thursday, April 6, 2023, at 4:00 p.m. Eastern Time)

IN-PERSON REGISTRATION INFORMATION

• The registration fee is $320.00 U.S. dollars for in-person (non-government) attendees. Registration must be completed online, and payment must be made by credit card. Registrations will be confirmed and processed on a first-come, first-served basis.

  • The registration fee includes beverages and light refreshments during the breaks and lunch for all three days.

• Federal government employees will be complimentary.

  • All title 5 Executive Agency employees must follow travel and relocation policies, including those on temporary duty travel allowances. See Federal Travel Regulations, 41 C.F.R. §§ 301-11.18, 301-74.21 (41 C.F.R. §§ 301-11.18, 301-74.21). Employees eligible to receive per diem expenses must adjust their Meals & Incidental Expenses (M&IE) allowance to account for meals furnished by CBP.

• Requests for special needs should be addressed to TFCSSummit@cbp.dhs.gov.

• You will be able to request a vegetarian/vegan meal during online registration. Kosher meals will not be available.

• Members of the press interested in covering the event should contact the CBP Office of Public Affairs at cbpmediarelations@cbp.dhs.gov.

WEBCAST REGISTRATION INFORMATION

• The registration fee is $24.00 U.S. dollars for virtual (non-government) attendees. Registration must be completed online, and payment must be made by credit card. Registrations will be confirmed and processed on a first-come first-served basis.

• Federal government employees will be complimentary. Complimentary registrations for federal government employees are limited and will be granted on a first-come, first-served basis.

  • Federal government employee participation must be approved by your immediate supervisor.

• Embassy employees will be complimentary when attending virtually only, due to limited space.

• Virtual registrants will receive an access link for the webcast by Friday, April 14 to view the General Sessions, Breakout Sessions, and Keynote Luncheons for April 17-19. Exhibits and workshops will be webcasted. 
   

FOR MORE INFORMATION & TO REGISTER VISIT THIS LINK

USDA AUTHORIZATION OF IMPORATION OF OHA LEAVES FROM NIGERIA

APHIS has authorized importing fresh oha leaves (Pterocarpus mildbraedii) from Nigeria into the continental United States. Based on the findings of a pest risk analysis, APHIS has determined that applying one or more designated phytosanitary measures will be sufficient to mitigate the risks of introducing or disseminating plant pests or noxious weeds via the importation of fresh oha leaves from Nigeria. This change is effective February 15, 2023 (Docket No. APHIS-2021-0074).

The above change impacts:

• Oha (Leaf) from Nigeria into Continental U.S. Ports

USDA/APHIS AUTHORIZATION OF THE IMPORTATION OF FRESH MANGO FROM GRENADA

The Animal and Plant Health Inspection Service (APHIS) has authorized importing fresh mango (Mangifera indica L.) fruit from Grenada into the United States. Based on the findings of a pest risk analysis, APHIS has determined that applying one or more designated phytosanitary measures will be sufficient to mitigate the risks of introducing or disseminating plant pests or noxious weeds via the importation of fresh mango fruit from Grenada. This change is effective February 15, 2023 (Docket No. APHIS-2021-0016).

The above change impacts:

• Mango (Fruit) from Grenada into All Ports

USDA EXTENDS COMMENT PERIOD FOR PROPOSED IMPORTATION OF CHILEAN TABLE GRAPES UNDER A SYSTEMS APPROACH OR IRRADIATION

Washington, D.C., December 13, 2022 – The U.S. Department of Agriculture’s Animal and Plant Health Inspection Service (APHIS) will extend the comment period on a pest risk assessment and a commodity import evaluation document detailing the conditions under which table grapes from Chile may be imported into the United States. The public will have an additional 30 business days to provide comments on the documents in response to requests to extend the comment period beyond December 16, 2022. APHIS will now consider all comments received by January 17, 2023.

Currently, table grapes from Chile must be fumigated with methyl bromide to mitigate for the Chilean false red mite, Brevipalpus chilensis, and the European Grapevine Moth, Lobesia botrana. APHIS is proposing that table grapes from areas in which the moth is either absent or at very low prevalence could be imported into the United States under a systems approach or irradiation. The systems approach would provide an alternative to the current import requirement of mandatory treatment with methyl bromide fumigation.

APHIS prepared a pest risk assessment and a commodity import evaluation document. The commodity import evaluation identifies the phytosanitary measures that could be applied to table grapes from new areas of Chile without increasing the risk of introducing pests.

To view the documents and comment, go to www.regulations.gov

and enter APHIS-2021-0078 in the search field.

2022 Food Facility Biennial Registration Renewal 

October 1, 2022, 12:01AM through December 31, 2022, 11:59 PM

Section 415 of the Federal Food, Drug, and Cosmetic Act (FD&C Act) [21 U.S.C. § 350d] requires food facilities that are required to register with FDA to renew such registrations during the period beginning on October 1 and ending on December 31 of each even-numbered year.

Please be advised that “updating” your registration is a different function than “renewing” your registration. During the renewal period, you will not see the “Update” button listed on the FFRM main menu, until the registration is renewed. If a registration is not renewed by 11:59 PM on December 31, 2022, the registration is considered expired and will be removed from your account. 

In addition, all facilities must include a unique facility identifier (UFI) recognized as acceptable to FDA with the registration submission To date, FDA recognizes the Data Universal Numbering System D-U-N-S (DUNS) number as an acceptable UFI. The DUNS number is assigned and managed by Dun & Bradstreet. DUNS numbers can be obtained or verified visiting D&B’s websiteExternal Link Disclaimer.

FDA expects all registrants to provide their DUNS number with their registration or renewal submission before December 31, 2022. In the past, FDA addressed stakeholder concerns with obtaining a DUNS number in a timely manner. The FDA has released guidance, Enforcement Policy for Providing an Acceptable Unique Facility Identifier (UFI) for the 2020 Food Facility Registration Biennial Renewal Period, with information on what facilities should do if they are unable to obtain a DUNS number prior to the end of the renewal period. The guidance explained FDA allowed registrants to enter “PENDING” in the UFI field of their registration if they anticipate that they will not be able to obtain a DUNS number in time. Users will then have 90 days to obtain and submit a DUNS number and will receive reminders via email.

Remember to utilize the free FEI, FFR and DUNS portals to ensure a facility information matches exactly, reference sheet: FEI, FFR and DUNS Portals. It is imperative a facility DUNS number information and section two of the food facility registration information match exactly. FFR Section Two and DUNS Information comparison common errors are slightly different legal names and addresses in the two databases. The following are hypothetical errors or mismatched information: “ABC Manufacturing” verses “ABC Manufacturing LLC” or “123 Main Street” verses “123 Main St.”, or “British Colombia” verses “BC”. All of the above mentioned or similar, registrants or user, submitted information differences will cause mismatch information or errors. Failure to update the registration with a valid DUNS number may result in cancellation of the registration. 

If you have any further questions please contact the Food Facility Registration Data Management Support Services (FFRDMSS): by phone 1-800-216-7331 or 240-247-8804; or by email at  FURLS@fda.gov. A reference sheet concerning the DUNS number is available.



Additional Information

• Food Facility Biennial Registration Renewal Fact Sheet.

Webinar on Food Facility Registration (FFR), Biennial Renewal, and Unique Facility Identifiers (UFI)

APHIS Will No Longer Accept Unoriginal Electronic Phytosanitary Certificates and Forms After September 30, 2022

The U.S. Department of Agriculture (USDA), Animal and Plant Health Inspection Service (APHIS), responded to the unprecedented challenges from the COVID-19 pandemic on trade by allowing importers of plant commodities to upload copies of phytosanitary certificates and forms.

Starting October 1, 2022, APHIS and U.S. Customs and Border Protection will accept only original phytosanitary certificates and forms for plant commodities. PPQ and CBP will continue to accept digital exchange of electronic phytosanitary certificates through the ePhyto system—a government-to-government sharing of electronic phytosanitary certificates.

A paper certificate would not need to be presented for cargo clearance by U.S. officials if the certificate is an ePhyto with a proper declaration in the APHIS Core message set using the PG13/14 code AE1. Please review the list of participating ePhyto countries.

Note: A trading partner that is marked “Yes” may choose to not send an ePhyto message set for a shipment. This could be due to limitations with the country’s system, outages, or other reasons.

 Acceptable phytosanitary certificates include:

• Certificates created through a participating country’s ePhyto system, or signed paper forms.

• Acceptable foreign site certificates of inspection and/or treatment include signed paper forms, signed copies of the master PPQ Form 203, and digitally signed electronic PPQ Form 203s.

For more information about plant or plant product imports, email plantproducts.permits@usda.gov or call 1-877-770-5990. 

For questions about plant or plant product exports, contact your local export certification specialist or email ppqexportservices@usda.gov.

APHIS/USDA IS DRAFTING PEST RISK ASSESSMENT FOR THE IMPORTATION OF PERUVIAN ASPARAGUS

APHIS has drafted a pest risk assessment for the importation of Fresh Asparagus (Asparagus officinalis) under a systems approach, for consumption from Peru. The assessment describes potential pests associated with the commodity.

Currently, Peru has access for green asparagus with a mandatory fumigation.

APHIS shares draft pest risk assessments and pest lists to determine whether stakeholders have information that might lead us to revise the draft assessment before we identify pest mitigations and proceed with the commodity import approval process. 

The draft pest risk assessment for Fresh Asparagus will be available for review and comment until August 8, 2022. To view the assessment or submit comments, go to USDA APHIS | Stakeholder Risk Assessment Consultation 

USDA APPROVES IMPORT OF FRESH AVOCADO FROM ECUADOR INTO THE US

On May 26, 2022, APHIS authorized the importation of fresh avocado fruit from continental Ecuador into the continental United States (Docket No. APHIS-2016-0099).

Based on the findings of a pest risk analysis, which was made available to the public for review and comment, APHIS has determined the application of one or more designated phytosanitary measures will be sufficient to mitigate the risks of introducing or disseminating plant pests or noxious weeds via the importation of fresh avocado fruit from continental Ecuador. **However, the phytosanitary measures for this commodity to meet U.S. entry requirements have not yet been met, therefore, import permits will not be issued at this time.**

Change impacts:

• NEW Avocado (Fruit) from Continental Ecuador into Continental U.S. Ports commodity import requirements (CIR) document has been created for FAVIR and for ACIR

• Added Ecuador avocado to T105-a-1 to align with final rule Docket No. APHIS-2019-0099 published May 26, 2022 (Note: the phytosanitary measures for this commodity to meet U.S. entry requirements have not yet been met, therefore, import permits will not be issued at this time.)

• Please see link for requirements.  -https://epermits.aphis.usda.gov/manual/index.cfm?           action=cirReportP&PERMITTED_ID=10610910

USDA APPROVES MANGOS FROM COLOMBIA
INTO THE U.S.

This notice is to alert you to changes in the Fruits and Vegetables Import Requirements (FAVIR) Database and the Agriculture Commodity Import Requirements (ACIR) Database.

On November 22, 2021, APHIS authorized the importation of fresh mango from Colombia into the United States (Docket No. APHIS-2020-0061). 

At that time, however, phytosanitary measures needed for this commodity to enter the United States had not been met.Phytosanitary measures needed for this commodity to enter the United States have now been met and import permits can be issued effective immediately.

Change impacts:

• Mango (Fruit) from Colombia into All Ports

FDA Video On "Importing FDA-Regulated Products: The Import Process"

April 2022 - The FDA has announced a public video outlining the general FDA import process for FDA-regulated products. This video was developed to fill a recognized gap between foreign suppliers and domestic importers/brokers on the details of the FDA admissibility process starting from declaration through the final admissibility decision. Prior to the creation of this video, information about the FDA import process was only available through public websites or occasional webinars, industry trainings, and individual communications (email). The video is published on the FDA YouTube channel. 

Video: Importing FDA-Regulated Products

APHIS Will No Longer Accept Unoriginal Electronic Phytosanitary Certificates and Forms After December 31, 2021

The U.S. Department of Agriculture (USDA), Animal and Plant Health Inspection Service (APHIS), responded to the unprecedented challenges from the COVID-19 pandemic on trade by allowing importers of plant commodities to upload copies of phytosanitary certificates and forms.

Starting January 1, 2022, APHIS and U.S. Customs and Border Protection will accept only original phytosanitary certificates and forms for plant commodities. PPQ and CBP will continue to accept digital exchange of electronic phytosanitary certificates through the ePhyto system—a government-to-government sharing of electronic phytosanitary certificates.

The APHIS Core message set supports the transmission of ePhytos. A paper certificate would not need to be presented for cargo clearance by U.S. officials if the certificate is an ePhyto with a proper declaration in the APHIS Core message set using the PG13/14 code AE1. Please review the list of participating ePhyto countries.

Note: A trading partner that is marked “Yes” may choose to not send an ePhyto message set for a shipment. This could be due to limitations with the country’s system, outages, or other reasons.

 Acceptable phytosanitary certificates include:

• Certificates created through a participating country’s ePhyto system, or signed paper forms.

• Acceptable foreign site certificates of inspection and/or treatment include signed paper forms, signed copies of the master PPQ Form 203, and digitally signed electronic PPQ Form 203s.

For more information about plant or plant product imports, email plantproducts.permits@usda.gov or call 1-877-770-5990. For questions about plant or plant product exports, contact your local export certification specialist or email ppqexportservices@usda.gov.

PPQ is committed to facilitating the safe trade of agricultural products. We continue to closely monitor this evolving situation and will provide updates as needed. Be sure to regularly check the APHIS website for the latest information.

APHIS Allows Imports of Mango From Colombia

The Animal and Plant Health Inspection Service will allow importation of mangoes from Colombia into the United States, it said in a notice released Nov. 19. 

Conditions include a hot water or irradiation treatment and inspections. Shipments must be accompanied by a phytosanitary certificate from the Colombian government. APHIS said imports of mangoes from Colombia may be authorized beginning Nov. 22.

TEMPORARY ADJUSTMENT OF TMF AT THE PORT OF LOS ANGELES AND LONG BEACH

LONG BEACH, Calif., November 10, 2021—The West Coast MTO Agreement (WCMTOA) today announced that the Traffic Mitigation Fee (TMF) at the Ports of Los Angeles and Long Beach will be temporarily adjusted from December 1, 2021, through January 31, 2022, subject to regulatory clearance by the Federal Maritime Commission. During this period, there will be a financial incentive to move containers during off-peak hours by charging a TMF during peak hours. Today’s announcement makes no changes to the appointment systems operated by individual terminals.

The adjustment comes at the request of the Port Envoy to the Biden-Harris Administration Supply Chain Disruptions Task Force, as well as the Executive Directors of the Ports of Los Angeles and Long Beach, as part of a collaborative effort to incentivize increased use of marine terminal gates during off-peak hours. The action is part of an overall effort to expand the use of warehouses, distribution centers, and trucking during the second and third shifts for the final push of holiday goods in December and into January leading to Lunar New Year.

From December 1, 2021, through January 31, 2022, the TMF will be $78.23 per TEU (twenty-foot equivalent unit) or $156.46 for all other sizes of container for non-exempt international container moves through the terminals at the ports of Los Angeles and Long Beach between the hours of 7:00 a.m. and 5:59 p.m. Monday through Friday.

Containers exempt from the TMF include empty containers; import cargo or export cargo that transits the Alameda Corridor in a container and is subject to a fee imposed by the Alameda Corridor Transportation Authority; domestic and transshipment cargo; and loaded container moves through the terminals from 6:00 p.m. through 6:59 a.m. Monday through Saturday and all day (24 hours) on Saturdays, Sundays, and holidays. Empty chassis and bobtail trucks are also exempt

PierPASS is a not-for-profit company created by marine terminal operators at the Port of Los Angeles and Port of Long Beach to address multi-terminal issues such as congestion, air quality and security. The West Coast Marine Terminal Operator Agreement (WCMTOA) is filed with the Federal Maritime Commission, and comprises the 12 international MTOs serving the Los Angeles and Long Beach ports. For more information, please see www.pierpass.org.

PierPASS Customer Service Number: 877-863-3310

CHAIN REACTION FROM PORT DELAYS

As always, one of our goals is to keep our customers informed regarding challenges affecting the movement of cargo in US ports.

As we know, port congestion is a current reality across many ports of the U.S. It is estimated that of the ten busiest ports in the nation, at least seven are facing congestion regularly.

What are some of the major causes?

• The global supply chain disruption caused by the Covid-19 pandemic during the second and third quarters of 2020

• Significant labor shortages created by Covid-19 at ports and on ships

• Cargo surges from large ships

• Marine terminal productivity

• Labor disruptions

• Infrastructure unable to handle heavy volumes of cargo

• Equipment shortages 

What are the effects of port congestion on incoming cargo?

• Chronic Vessel Gridlock – ships are stranded offshore for days, even weeks waiting to anchor and unload. One major reason for the back-up is the lack of berth space. This is particularly perceptible in the ports in California, Savannah and New York.

• Delays in Arrival of Vessels – The chronic gridlock noted above automatically means expected arrival dates may no longer be valid.

• Vessel Un-loading Delays – The process of unloading vessels is very slow. Because the ports are overwhelmed with the high volume of incoming cargo and the effects of the gridlock noted above, containers are buried in extensive stacks in clogged terminal yards making unloading of cargo a slow process (just unloading an ocean vessel can take 1-3 business days because many ships have more than 10,000 containers on board).

• Trucking Issues – The delays in arrival of vessels cause issues with truckers as they are set up to pick up cargo on a particular date and schedules regularly change with frequently only a one day of notification thus, adding additional stress on trucking schedules and coordination.

• Slow Container Pickup – Trucks wait in line for hours (up to eight or nine hours in some cases) to pick up a single container. Some customers experience shipment delays lasting weeks.

• High Handling Cost of Containers (Demurrage) – Terminal operators still charge a per diem penalty for demurrage each day the container remains at the terminal beyond three days, even when the shipper is prevented from removing it. It is evident the port congestion has had a negative impact on the cost of container handling (remember that once demurrage is assessed, the shipper has no choice but to pay since the payment is due in advance on the day the cargo is picked-up).

• Challenging Communication with Ports – due to manpower shortage, it has become almost impossible to obtain a response from carriers to emails or to phone calls when requesting information regarding notices of arrival, demurrage invoices, etc. (we strongly encourage our customers to follow up with their respective carriers to obtain their notices of arrival timely to avoid demurrage charges resulting from lack of freight payment).

In summary, all the factors noted above are basic to clearing and moving cargo efficiently and quickly. Without all these parts moving in-tandem, the system is hindered. These significant issues noted will continue to result in delays in the clearance of cargo. 

DRAYAGE DEMAND CONTINUES TO RISE AT RECORD LEVELS

Background/Issue - Over the past 16 years, the country has experienced shortages of truck drivers rise and fall with economic trends. However, demand far exceeded supply during the second half of 2020 and the shortage is affecting deliveries nationwide. The truck driver shortage has been widely publicized lately as the domestic supply chain still struggles with the post-COVID fallout. As demand for freight services continues to grow, the supply side is having difficulty meeting the needs of shippers. This imbalance has left shippers feeling the pain as more volume enters the freight market than can be reasonably transported.

Basic economics dictates that this misalignment will have an upward price pressure, primarily the reason for rate increases that hit freight in 2020. The industry is working to meet the demand which is only expected to increase (as per the American Trucking Association, 72.5% of all freight in the US was transported by the trucking industry in 2019). The American Trucking Association has reported that the industry will need to hire approximately 1.1 million new drivers in the next decade to offset the strain. This equates to 110,000 drivers per year.

What are the causes for the shortage? The greatest shortage of truckers is in the sector known as truckload carriers, which move trailer-size shipments of freight long distances. Aside from the increase in freight volume, several factors have contributed to the shortage including an aging driver population, high turnover, the construction industry, federal regulation and competition from companies like FedEx, Amazon, UPS, and Walmart that can offer more regular routes.

What is the industry doing to remedy the problem? Trucking capacity is expected to remain tight during 2021. According to The American Trucking Association the industry is stressing recruitment expansion to include new talent and an increase in compensation. 

How is this affecting you? As can be anticipated, the terminals have been experiencing considerable delays from the increased volumes and chassis shortage. Containers coming off the vessel are stacked causing delays for inspection. And, when cargo is released, truckers often wait at the terminal for hours for containers to be mounted for departure which means they are only able to make 1 – 3 turns per day adding more pressure on driver availability. In addition, there are increasing delays in offloading once cargo arrives at its final destination.

As can be expected, with carriers granting only 2 free days demurrage, terminal charges resulting from these delays are at a record high; and, once carriers calculate these charges, there is an additional lag in payment application by ocean carriers. 

We recommend you advise your internal staff and sales teams to factor into the cost of the shipment the rising terminal charges as well as the potential delays in delivery to your warehouse or to your customers.

We continue to work diligently to communicate delays and facilitate timely removal of the reefers from the terminal and appreciate your consideration and awareness of these serious issues.

New 2021 tariff Published for
Greenwich Terminals

Terminal Free Time on Reefers is being reduced to 4 business days (effective March 1st 2021).

Rates are being increased effective Monday Jan 11th.

(1) DRY containers measuring up to and including 20 feet: 

$85.00 per day for each day or fraction thereof after the expiration of free time. 

(2) REFRIGERATED containers measuring up to and including 20 feet: 

$85.00 per day for each day or fraction thereof after the expiration of free time. 

(3) DRY containers measuring in excess of 20 feet: 

$100.00 per day for each day or fraction thereof after the expiration of free time.

(4) REFRIGERATED containers measuring in excess of 20 feet: 

$100.00 per day for each day or fraction thereof after the expiration of free time.

(1) US Customs X-Ray Inspection 

$195.00 per occurrence (Dry containers) (Straight time M – F only) 

$225.00 per occurrence (Refrigerated containers inclusive of unplugging and 

re-plugging) (Straight time M – F only) 

$ 287.00 per occurrence (Refrigerated containers inclusive of unplugging and re-plugging with Genset mounted) (Straight time M – F only)

(2) Two (2%) percent inspection 

$545.00 per inspection (inclusive of spotting container/breaking seal/min. inspection/all labor/resealing of container)

(5) Full Inspection (Performed at the platform) Full strip / full inspection /full restuffing. 

$1286.25 Full strip palletized / USDA full strip

(12) Cold Treatment downloads 

$75.00 per action (single file upload)

(17) Refrigerated container temperature change 

$80.00 per request

AMS Announces New 2021/2022 Rates

The Agricultural Marketing Service (AMS) is announcing the 2021/2022 rates it will charge for voluntary grading, inspection, certification, auditing, and laboratory services for a variety of agricultural commodities including meat and poultry, fruits and vegetables, eggs, dairy products, rice, and cotton and tobacco. 

The 2021/2022 regular, overtime, holiday, and laboratory services rates will be applied at the beginning of the crop year, fiscal year or as required by law depending on the commodity. Other starting dates are added to this notice based on cotton industry practices. 

This action establishes the rates for user-funded programs based on costs incurred by AMS. This year, nearly two-thirds of AMS user fee rates will remain unchanged from the previous year and a few will decrease, but increases are necessary to many fees to cover costs.

2021/2022 Rates Charged for AMS Services

For further information contact Charles Parrott, AMS, USDA at 202-260-9144 or charles.parrott@usda.gov

APHIS/USDA NEW REQUIREMENTS FOR IMPORT DOCUMENTATION

APHIS is responsible, in part, for ensuring the free flow of agricultural trade by keeping U.S. agricultural industries free from pests and diseases.  On January 25, 2021, ACE filing became mandatory for the Animal and Plant Health Inspection Service (APHIS)-Core PGA Message set. The range of commodities subject to APHIS-Core import requirements is very broad, covering plants and plant products, seeds, animal products and miscellaneous processed products.

In order to comply with the requirements of this new filing the botanical name of the product being imported is mandatory.

Effective immediately, the following additional information must be included with the documents submitted for your entry:

What is the common name? 

What is the genus and species? 

What is the variety name, if any?

This information should be included on the Commercial Invoice.  

For more information contact Advance Customs Brokers.

Advisory: USDA Authorizes Imports of
Fresh Peppers from Colombia

APHIS has authorized the importation of fresh pepper fruit from Colombia into the continental United States (Docket No. APHIS-2018-0025). APHIS has concluded that the application of one or more designated phytosanitary measures will be sufficient to mitigate the risks of introducing or disseminating plant pests or noxious weeds. The articles covered by this notification are authorized for importation after March 25, 2021.

• Pepper, Bell (Fruit) from Colombia into Continental U.S. Ports change commodity is now allowed entry into the United States with the application of one or more phytosanitary measures

• Pepper, Habanero (Fruit) from Colombia into Continental U.S. Ports change commodity is now allowed entry into the United States with the application of one or more phytosanitary measures

• Pepper, Locoto (Fruit) from Colombia into Continental U.S. Ports change commodity is now allowed entry into the United States with the application of one or more phytosanitary measures

• Pepper, Manzano (Fruit) from Colombia into Continental U.S. Ports change commodity is now allowed entry into the United States with the application of one or more phytosanitary measures

• Pepper, Tabasco (Fruit) from Colombia into Continental U.S. Ports change commodity is now allowed entry into the United States with the application of one or more phytosanitary measures

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​​ PACKER AVE MARINE TERMINAL NEW RATES
 EFFECTIVE MARCH 1, 2021

The new 2021 tariff is now being published for Greenwich Terminals. It should be live on our website soon. Some pertinent details:

Terminal Free Time on Reefers is being reduced to 4 business days (effective March 1st 2021).

Rates are being increased effective Monday Jan 11th.

(1) DRY containers measuring up to and including 20 feet: 

$85.00 per day for each day or fraction thereof after the expiration of free time. 

(2) REFRIGERATED containers measuring up to and including 20 feet: 

$85.00 per day for each day or fraction thereof after the expiration of free time. 

(3) DRY containers measuring in excess of 20 feet: 

$100.00 per day for each day or fraction thereof after the expiration of free time.

(4) REFRIGERATED containers measuring in excess of 20 feet: 

$100.00 per day for each day or fraction thereof after the expiration of free time.

(1) US Customs X-Ray Inspection 

$195.00 per occurrence (Dry containers) (Straight time M - F only) 

$225.00 per occurrence (Refrigerated containers inclusive of unplugging and  re-plugging) (Straight time M - F only)

$ 287.00 per occurrence (Refrigerated containers inclusive of unplugging and re-plugging with Genset mounted) (Straight time M - F only)

(2) Two (2%) percent inspection 

$545.00 per inspection (inclusive of spotting container/breaking seal/min. inspection/all labor/resealing of container)

(5) Full Inspection (Performed at the platform) Full strip / full inspection /full restuffing. $1286.25 Full strip palletized / USDA full strip

(12) Cold Treatment downloads 

$75.00 per action (single file upload)

(17) Refrigerated container temperature change 

$80.00 per request

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​​  FreshPlaza interviews Pat Compres
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“Knowing our customers makes the probability of problems much lower”

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Fresh produce travels the globe, and many items are imported into the US from numerous sourcing countries. Being aware of the rules and regulations from both importers and exporters perspective can be quite challenging. “With over 30 years of experience in helping clear fresh produce, we’ve been able to solve many issues,” says Pat Compres, Co-owner of Advance Customs Brokers in Miami, Florida. “We dedicate ourselves to the import side of the business only and work with all US ports,” she added. “There are so many problems that can occur in transit or before produce is being cleared in the US that we are available 24/7, 365 days/year to assist our clients. We support them in getting their produce from the country of origin to the United States in the most efficient way and shortest amount of time.”

“Our role is to advise our clients on US import requirements. In addition, we also provide them with recommendations on carriers to use, types of packaging, and we help them get through the inspection process.” All product that enters the US must be inspected and not only does Advance Customs Brokers help with the documentation process for clearing customs, the team also personally helps perform the inspections with airport arrivals.

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See Full Article

Reminder regarding timely filing of the Importer Security Filing (ISF) also known as 10+2

Eleven years ago, on January 26, 2009, U.S. Customs and Border Protection mandated the Importer Security Filing (commonly known as "10+2"). ISF is for ocean cargo imports only and must be filed electronically with U.S. Customs and Border Protection 24 HOURS PRIOR TO VESSEL LADING FROM LAST PORT OF ORIGIN.    ISF improves CBP's ability to recognize high-risk shipments in advance to ensure the safety of America's borders.

Failure to comply with the rule could ultimately result in monetary penalties, increased inspections, and delay of cargo.  CBP may issue liquidated damages of $5,000 per violation for the submission of an inaccurate, incomplete, or untimely filing. If goods for which an ISF has not been filed arrive in the U.S., CBP may withhold the release or flag cargo for an intensive at a CES, or just not release for a few days, making the cargo incur demurrage charges and loss of shelf life.

Recently we have seen CBP taking a more aggressive approach and issuing penalties for those cargos which the ISF was not filed on time.

We understand that the importer is not the entity that issues the ISF, that this must come from the shipper/exporter, but the importer is the company that receives the penalties. Therefore we want to share with you that we have been seeing delays in receiving ISF's from shippers and we want make to sure that everyone is aware of this enforcement by CBP.

Pat Compres Speaks at United Fresh Live

Global Trade Challenges in the COVID-19 Era

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Advance Customs Brokers' Pat Compres took part in a United Live panel discussing global trade affects and implications of the Coronavirus pandemic.

See Video

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USDA Seeks Change in Importation of Blueberries from Chile

USDA/APHIS  is advising the public that we have prepared a commodity import evaluation document (CIED) relative to the importation into the United States of blueberries from Chile. Currently, blueberries from Chile imported into the United States from an area in which European grapevine moth is known to exist must be fumigated with methyl bromide. Based on the findings of the CIED, we are proposing to also allow the importation of such blueberries under the provisions of a systems approach. We are making the CIED available to the public for review and comment.

DATES: We will consider all comments that we receive on or before June 1, 2020.

ADDRESSES: You may submit comments by either of the following methods:

Federal eRulemaking Portal: Go to http://www.regulations.gov/#!docketDetail;D=APHIS-2019-0049

 .

Postal Mail/Commercial Delivery: Send your comment to Docket No. APHIS-2019-0049, Regulatory Analysis and Development, PPD, APHIS, Station 3A-03.8, 4700 River Road Unit 118, Riverdale, MD 20737- 1238.

Supporting documents and any comments we receive on this docket may be viewed at http://www.regulations.gov/#!docketDetail

 D=APHIS-2019- 0049 or in our reading room, which is located in room 1141 of the USDA South Building, 14th Street and Independence Avenue SW, Washington, DC. Normal reading room hours are 8 a.m. to 4:30 p.m., Monday through Friday, except holidays. To be sure someone is there to help you, please call (202) 799-7039 before coming.

FOR FURTHER INFORMATION CONTACT: Mr. Tony Roman, Senior Regulatory Policy Specialist, RCC, IRM, PHP, PPQ, APHIS, 4700 River Road Unit 133, Riverdale, MD 20737-1236; (301) 851-2242.

https://www.govinfo.gov/content/pkg/FR-2020-03-31/html/2020-06696.htm

https://www.govinfo.gov/content/pkg/FR-2020-03-31/html/2020-06696.htm

USDA Seeks Change in Importation of Citrus from South Africa

Washington, D.C., March 31, 2020 - The U.S. Department of Agriculture's Animal and Plant Health Inspection Service (APHIS) has prepared and is accepting comments on a commodity import evaluation document (CIED) regarding fresh citrus imports from South Africa. Based on the findings of the CIED, APHIS experts determined that grapefruit, lemon, mandarin orange, sweet orange, tangelo, and Satsuma mandarin fruit from South Africa may be imported into the United States without restrictions on the ports of entry. Currently, fresh citrus from South Africa must be cold treated and imports are restricted to Newark, NJ, Philadelphia, PA, Wilmington, DE, and Houston, TX due to the presence of false codling moth in South Africa.

APHIS conducted enhanced inspections for false codling moth on citrus from South Africa at the four authorized ports over a two-year period.  During that time, more than 2,000 shipments of citrus were imported with no detections of live false codling moth. As a result we are proposing to remove the port restrictions and authorize the importation of citrus from South Africa into all ports of entry in the United States.

You may view the CIED in the Federal Register when it is published on April 1, 2020 and submit comments until June 1, 2020, 60 days after the publication date.  The docket will be available upon publication here:  http://www.regulations.gov/#!docketDetail;D=APHIS-2018-0091. 

After reviewing the comments, APHIS will announce its decision regarding the import status of fresh citrus from South Africa in a final notice

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NY-NJ Port Plans for Cargo Backlog

March 27, 2020: Insight from the Port Authority of New York and New Jersey (PANYNJ) reveals preparation for changes in cargo movement as the Covid-19 situation continues to progress. Despite Newark being under a “shelter-in-place” order, workers and truckers remain available and working since employees are able to present a ID indicating they are Essential Employees. Below is a link to an interesting Journal of Commerce article discussing more about what Port Authority of New York  and New Jersey (PANYNJ) expects. While most of the expected changes in cargo deal with dry cargo, any congestions created can slow perishables as well. 

JOC: NY-NJ Prepare for Potential Cargo Backlog

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IN THE PRODUCE NEWS!
Produce Shipments Unaffected by Covid-19, says veteran customs broker.

The Produce News spoke to Pat Compres of Advance Customs Brokers who has been on the front lines of facilitating produce trade during the disruptive situations presented by Covid-19.

​

Read article

Notice On European Tariffs Affecting
Citrus From Spain

USTR has released a list of tariffs of 25% to be imposed on billions' worth of European imports starting Oct. 18 including some produce items. Section 15 of the notice in particular lists several fresh or dried produce items including citrus from Spain.

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View the notice at: Notice of Determination and Action Pursuant to Section 301

FDA Makes Available List of Records
Required Under FSVP

The Foreign Supplier Verification Programs (FSVP) final rule, established through the FDA Food Safety Modernization Act (FSMA), requires importers to verify that the food they are importing into the United States has been produced in a manner that meets applicable U.S. food safety standards.

To do this, importers are required to develop, implement, and maintain a Foreign Supplier Verification Program which includes verification activities and records of those activities for each imported food from each foreign supplier. During an FSVP inspection, the FDA investigator will review the importer's records to determine their compliance with the FSVP regulation. To help importers determine the FSVP records they should develop and maintain, the FDA has made available a list of records required by the FSVP regulation.

CBP AQI Changes Inspection process in MIA International

Beginning July 9, 2018, CBP's agriculture inspections for Cut Flowers, Animal Products, Miscellaneous Cargo, Fruits and Vegetables (FV) must request inspection only through email.

All fruit and vegetable inspection requests should be scheduled 24 hours in advance with inspection date and location.  This advance request apply only to fruits and vegetables arriving through cargo flights.

All FV inspections will be conducted by flight at the same time if inspections are scheduled in advance.  Priority will be given to those who requested Agriculture Reimbursable Overtime (Ag ROT) and scheduled inspection in advance.

This change will affect all importers that bring cargo via air, except asparagus.   This new requirement means that a Pre Alert is a must in order for us to be able to notify CBP AQI 24 hours in advance.    If we do not receive a pre-alert on shipments it will inspected last.

Please be aware that the shipments most affected will be the short transit time shipments from the Caribbean and Central America.

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USDA to take over FDA's food safety oversight

Food safety oversight of the produce industry would be moved from the Food and Drug Administration to the U.S. Department of Agriculture under a government overhaul plan unveiled by the White House.

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Among other proposed reforms, the 132-page plan argues for a unified food safety agency within the USDA called the Federal Food Safety Agency.

"This consolidation will give USDA the clear mandate, dedicated budget, and full responsibility it needs for optimal oversight of the entire U.S. food supply," according to the document.

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For more than 40 years, the U.S. Government Accountability Office has recommended that federal government consolidate food safety functions in a single agency, but proposals to make the idea a reality have never gained traction.

The White House said a single agency would provide better food safety outcomes and improved efficiency, according to the release.

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"This consolidation will give USDA the clear mandate, dedicated budget, and full responsibility it needs for optimal oversight of the entire U.S. food supply," according to the plan. "Resources at the FDA will be freed up to focus on its core responsibilities of drugs, devices, biologics, and tobacco."

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The White House cited Government Accountability Office analysis that concluded current fragmented federal oversight of food safety "has caused inconsistent oversight, ineffective coordination, and inefficient use of resources.

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The USDA's Food Safety Inspection Service and the FDA are the two primary agencies with major responsibilities for regulating food and the substances, with the FSIS responsible for the safety of meat, poultry, processed egg products, and catfish, while FDA is responsible for all other foods, including fresh produce, seafood and shelled eggs.

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"While the FDA and FSIS currently have very different regulatory regimes, consolidating FSIS and the food safety functions of FDA would allow for a better allocation of resources based on risk, better communication during illness outbreaks, and improved policy and program planning through development of a single strategic plan," the plan said.

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In February last year, when the GAO repeated its recommendation for a unified food safety agency, Jennifer McEntire, vice president of food safety and technology for the United Fresh Produce Association, said efforts to create single oversight agency for food safety could involve a lot of time and bureaucracy but with little payoff.

"There would be a lot of difficulty getting there, and I don't think it will substantially improve public health," she said at the time. 

FAVIR Database and Fruits and Vegetables Manual 

This notice is to alert you to changes in the FAVIR Database and the Fruits and Vegetables Manual.

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The specific changes are listed below:

FAVIR Database: Blackberry, Andean (Fruit) AND Raspberry, European (Fruit) from Ecuador into Continental U.S. Ports changes the Operational Work plan for these commodities has been signed and  importers may now apply for APHIS import permits.

Fruits and Vegetables Manual: Table 3-75 Ecuador change language in footnote #3 has been changed to reflect the above-mentioned change

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FDA Releases Draft Guidance for Intentional Adulteration Rule

Today, the FDA released the first of three installments of a draft guidance document designed to support compliance with the Intentional Adulteration (IA) Rule under the FDA Food Safety Modernization Act (FSMA). The remaining two installments are expected to come out later this year.

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The FSMA final rule on intentional adulteration is designed to address hazards that may be intentionally introduced to foods, including by acts of terrorism, with the intent to cause wide-spread harm to public health. Unlike the other FSMA rules that address specific foods or hazards, the IA rule requires the food industry to implement risk-reducing strategies for processes in food facilities that are significantly vulnerable to intentional adulteration.

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Food facilities covered by the rule will be required to develop and implement a food defense plan that identifies vulnerabilities and mitigation strategies for those vulnerabilities. These facilities will then be required to ensure that the mitigation strategies are working. The first compliance date for the largest facilities arrives in July 2019.

This first part of the draft guidance includes chapters on:

• the components of the food defense plan;

• how to conduct vulnerability assessments using the key activity type method;

• how to identify and implement mitigation strategies; and

• food defense monitoring requirements.

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The second installment will focus more specifically on vulnerability assessments and training requirements, with the third including greater detail on corrective action, verification, reanalysis, and record keeping requirements.

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This draft guidance, in its entirety, is intended to be a resource that will help the food industry implement the IA provisions in a flexible and cost-effective manner. To further assist and engage stakeholders, FDA will announce plans to hold a public meeting on the draft guidance when the second installment is released later this year. All three parts will be available for public comment upon release.

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For More Information

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• Statement from FDA Commissioner Scott Gottlieb, M.D., on new guidance to help manufacturers implement protections against potential attacks on the U.S. food supply

• Mitigation Strategies to Protect Food Against Intentional Adulteration: Guidance for Industry (Draft)

• FSMA Final Rule for Mitigation Strategies to Protect Food Against Intentional Adulteration

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APHIS Proposes to Allow Imports of Fresh Avocado Fruit from Continental Ecuador

The U.S. Department of Agriculture's Animal and Plant Health Inspection Service (APHIS) is proposing to allow imports of fresh avocado fruit from continental Ecuador into the continental United States. After a thorough review, APHIS scientists determined the fruit can be safely imported under a systems approach to protect against the introduction of pests of concern.

A systems approach is a series of measures taken by growers, packers, and shippers that, in combination, minimize pest risks prior to importation into the United States.  

In this case, the systems approach includes production site requirements, packinghouse requirements, shipment of commercial shipments only, and inspection of each shipment. A phytosanitary certificate with an additional declaration stating these conditions have been met must also accompany each shipment. Avocados that are ineligible for export under the systems approach may still be imported following APHIS-approved treatment, such as irradiation.

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APHIS will carefully consider all comments received by August 14, 2018. This notice may be viewed in today's Federal Register at: https://www.federalregister.gov/d/2018-12827. Beginning tomorrow, members of the public will be able to submit comments at: http://www.regulations.gov/#!docketDetail;D=APHIS-2016-0099  

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