FWS Announces Universal Labeling Requirements for Sturgeon and Paddlefish Caviar

FWS explains that CITES member nations agreed that as of January 2004 they would only accept caviar shipments marked according to the universal labeling system.

Universal Labeling Requirements for Imports, Exports, & Re-Exports Effective Immediately

As a result, FWS states that effective immediately, all imports, exports, and re-exports of sturgeon and paddlefish caviar must be marked with a non-reusable label (see below). In addition, CITES permitting requirements and all other wildlife import/export requirements must still be met. Specific labeling requirements are:

1 Primary Containers of Caviar

FWS states that any primary container of caviar (tin, jar, or box into which caviar is directly packed) must bear a non-reusable label or mark. FWS states that a non-reusable label or mark means that the label or mark cannot be removed without damage or transferred to another container. For the U.S., the design of the non-reusable label or mark will be determined by the labeler.

(A) In the case of exports and re-exports when repackaging has not occurred, the label or mark must include a formula that provides the following information:

i Standard three-letter species code. Hybrids should be identified using the codes for the male and female parents, separated by the letter 'x' (for example GUE x BAE). The species codes are as follows:

ii One-letter source code of the specimen;

iii Two-letter International Organization for Standardization (ISO) code of the country of origin;

iv Four-digit year of harvest;

v Processing plant code (represents the plant that produces the caviar or the exporter). This code can be letters or numbers, or a combination, as determined by the labeler;

vi Lot identification number (corresponds with the caviar tracking system used by the processing or repackaging plant). It does not have to be four digits.

(B) FWS states that the following is an example of a label or mark: HUS/W/RU/2003/xxxx/yyyy, where xxxx = processing plant code and yyyy = lot identification number.

(C) FWS further states that if no repackaging occurs in an intermediary country, the non-reusable label from the country of origin is considered acceptable labeling.

(D) For exports or re-exports when repackaging occurs, the label or mark on the primary container must be non-reusable and include the following information:

i Three-letter standardized species code;

ii One-letter source code of the specimen;

iii Two-letter ISO code of the country of origin;

iv Four-digit year of repackaging;

v Repackaging plant code that includes the two-letter ISO code for the repackaging country if different from the country of origin; and

vi Lot identification or CITES document number.

(E) An example of the repackaging label or mark is: PER/W/IR/2003/DE-wwww/zzzz (DE-wwww represents the repackaging plant code, zzzz = indicates the lot identification or CITES document number)

(F) FWS states that primary containers of mixed or pressed caviar must identify all of the species in each container and the quantity of each species. The U.S. does not recognize the use of the three-letter 'MIX' species code.

2 Secondary Containers

In addition, FWS states that labels on secondary containers (receptacle into which primary containers are packed) must indicate the exact quantity of caviar and provide a description of the contents.

3 CITES Document/Annex

The FWS adds that the CITES document or an annex attached to the document must contain all the information presented on the labels.

4 Exports or Re-exports from U.S.

For exports or re-exports from the U.S., applicants must provide labeling information when applying for a U.S. CITES export or re-export document.

(See ITT's Online Archives or 08/02/02 news, 02080220, for BP summary of FWS' proposed rule to add Beluga Sturgeon (Huso huso) to the endangered species list and halt commercial trade in of this species, its parts and products. )

FWS Contact - Office of Law Enforcement (703) 358-1949

FWS Notice (dated 03/12/04) available at http://www.le.fws.gov/PBCitesLabelingSturgeonCaviar.htm