U.S. Romaine Importers: Prepare Now for Fall

In June, the CFIA announced that it would again be implementing temporary import conditions for U.S. romaine lettuce this fall requiring that importers of U.S. romaine products grown in the Salinas Valley submit attestation forms and Certificates of Analysis to confirm that there are no detectable levels of E. coli O157:H7, with a Proof of Origin required products from other U.S. areas.

After receiving some backlash from growers upset by the lack of specific information on the rule – which caused issues last year when inspectors seemed to also need more clarity, particularly in the area of unannounced audits – CFIA published further information on specific requirements in late July. 

In addition to all existing import requirements, importers must:

• For romaine lettuce and romaine-containing salad mixes from the California counties of Santa Clara, Santa Cruz, San Benito, and Monterey
  • Provide an importer attestation for each shipment that: they have an official Certificate of Analysis for each romaine-lettuce product in the shipment; sampling and testing was conducted according to the temporary SFC licence conditions and E. coli O157:H7 was not detectedProvide written evidence of the licence holder’s preventive control plan which includes a written procedure describing how the sampling and testing requirement outlined below is implemented (See sections 3d, e, f, and 4d.)
    • Note that a presumptive positive result from a screening method is treated as a positive for E. coli O157:H7 unless a confirmation test performed on the original enrichment broth within 24 hours of the first test produces a negative result.
  • Include the Certificates of Analysis issued for the romaine products in each shipment.
• For romaine lettuce and romaine-containing salad mixes from outside the above counties
  • Provide a Proof of Origin with the state and county where the romaine lettuce was harvested.
  • If a Proof of Origin is not available, the requirements for romaine grown in the listed counties will apply.
• Additionally, romaine lettuce grown in California is to have been handled by a certified member of the California Leafy Greens Marketing Agreement (LGMA) and romaine grown in Arizona handled by a shipper that is a certified member of the Arizona LGMA.

The above licence conditions apply to all U.S. import shipments of all varieties of fresh, mature, and baby romaine lettuce and/or salad mixes containing these, whether sold in bags, in bulk, or combined with other food items.

Intended to mitigate the higher risk of E. coli O157 contamination of romaine lettuce grown in the Salinas Valley during the fall months, the conditions are effective September 28 through December 20, 2023. Although similar measures have been implemented each fall since 2020, TAG has seen that Canadian importers and U.S. exporters have often been caught unprepared, causing delayed and refused shipments. Thus, it is important that all those impacted – on both sides of the border – review and understand the temporary licence conditions.

In other news …

After having announced in early June that the Official Meat Inspection Certificate (OMIC) for exporting poultry meat products from Mexico to Canada would be suspended effective June 29, 2023, CFIA reinstated the recognition of the Mexican inspection system for processing imported poultry and reactivated the use of the OMIC for meat products produced from imported poultry meat products on June 21. After reviewing information provided by Mexico, the CFIA stated that it was satisfied that the circumstances that led to the suspension have been corrected.