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Exporting pet food from the US

For pet food containing animal-derived material, USDA's APHIS endorses export health certificates and runs a fee-based inspection and certification service when an importing country asks for official certificates. Pet food is also food under the FD&C Act, so the 801(e) export rule applies. Most shipments need EEI.

Updated · Each section links to the official source it comes from

Certifying agency
USDA Animal and Plant Health Inspection Service (APHIS)
Certificate
Export health certificate, endorsed by APHIS
Plant service
Voluntary inspection and certification, 9 CFR Part 156
Fees
User fees under 9 CFR Part 130
Under the FD&C Act
Food, including food for animals
Export declaration
EEI in the AES, above $2,500 per Schedule B line

Before the goods leave

The questions to answer, in the order they usually come up.

  1. 1Does the destination ask for an export health certificate or other official certificate? Read more
  2. 2Does the certificate call for supervised processing at the plant? Read more
  3. 3Is the product made to the buyer's specification and not sold in the US? Read more
  4. 4Does the shipment need EEI, and who files it? Read more

The rules, by area

What each area covers, the texts that set it, and what the official pages say.

APHIS export health certificates

The official document an importing country may require for animal products leaving the US.

  • An export health certificate is an official document that, as required by the importing country, is endorsed by an APHIS representative and states that the animals or animal products to be exported were found healthy and free from evidence of communicable diseases and pests (9 CFR 130.1).
  • User fees for export health certificates are paid before the endorsed certificates are received, unless APHIS accepts a credit history and bills the user (9 CFR 130.6).
  • The FDA's food export library points exporters to APHIS for requirements on exporting animals and animal products.

How we help: Compliant Always keeps each endorsed certificate with the consignment and lot it covers, dated, and reads it against what the destination asks for. Ask about this

Voluntary inspection and certification of animal products

An APHIS service at the plant, for certificates on the class, quality, quantity or condition of animal products.

  • Where foreign countries' requirements or contract terms call for official certificates, APHIS inspects the processing, handling and storage of animal products at the plant and certifies those that conform (9 CFR 156.3).
  • An animal product means anything made of, derived from or containing any material of animal origin (9 CFR 156.2).
  • The plant operator fully informs the inspector of the processing; the inspector records temperatures, times and pressures to justify the certificates.
  • The applicant states the forms of certificate it wants on the application, and pays the user fees under 9 CFR Part 130.
  • Service is refused where the plant and its processing, handling and storage are not adequate to warrant the certificates (9 CFR 156.5 and 156.8).

How we help: Compliant Always keeps the plant's process records and the certificates drawn from them with each lot, and shows what is missing before a shipment. Ask about this

Pet food made only for export

Food under the FD&C Act includes articles used for food or drink for animals (21 U.S.C. 321(f)), so section 801(e)(1) applies.

  • Food intended for export is not deemed adulterated or misbranded if it meets the foreign purchaser's specifications, does not conflict with the importing country's laws, is labelled on the outside of the shipping package as intended for export, and is not sold in domestic commerce.
  • The exporter keeps records showing each condition for 3 years after exportation, and shows them to the FDA on request (21 CFR 1.101(b)).

How we help: Compliant Always keeps the buyer's specification and the export marking with each lot, dated, ready if the FDA asks. Ask about this

Export declaration: EEI in the AES

Electronic Export Information filed in the Automated Export System, the export component of ACE, before the goods leave.

  • The EEI is filed through the AES by the US principal party in interest (USPPI), its authorised agent, or the authorised US agent of the foreign principal party in interest, for exports of physical goods, including orders received over the internet (15 CFR 30.2).
  • No EEI is needed where the value under one Schedule B or HTSUSA number, from one USPPI to one consignee on one conveyance, is $2,500 or less, unless a licence is required (15 CFR 30.37(a)).
  • Shipments to Canada are exempt, except goods stored in Canada for a third country or moving through Canada to one (15 CFR 30.36).
  • Filed before departure: 24 hours before loading for vessel cargo, 2 hours before departure for air cargo, 1 hour before a truck reaches the border (15 CFR 30.4).
  • Each line carries a 10-digit Schedule B or HTSUSA number and, where it applies, the ECCN or EAR99 (15 CFR 30.6).
  • Parties to the export keep its documents for five years from the date of export (15 CFR 30.10).

How we help: Compliant Always keeps the invoices, classifications and certificates behind each declaration with the shipment and lot, dated, and answers importers' questions from that record. Ask about this

Who answers for what

WhoWhat they answer forHow we help
ExporterMeeting the importing country's laws, requesting certificates and, as USPPI, the EEI.Certificates and declarations kept with each shipment, with gaps shown before it leaves.
ManufacturerApplying for or endorsing the plant service, and informing the inspector of its processing.Process records kept with each lot behind the certificate.
Freight forwarder or customs brokerFiling EEI as the authorised agent.The commercial documents behind the filing, in one record.
Certifying authorityAPHIS, which endorses export health certificates and inspects at the plant.Each certificate read against what the destination asks for.

Where are the goods going?

Most of what pet food have to meet is set where they are sold. Each guide sets out the rules on arrival, with the official source for each.

Questions businesses ask

Who issues export certificates for US pet food?
USDA's Animal and Plant Health Inspection Service (APHIS). An export health certificate is endorsed by an APHIS representative where the importing country requires one.
What does an APHIS export health certificate state?
That the animals or animal products to be exported were found healthy and free from evidence of communicable diseases and pests, as required by the importing country (9 CFR 130.1).
Is there a fee for an APHIS export health certificate?
Yes. User fees under 9 CFR Part 130 are paid before the endorsed certificates are received, unless APHIS accepts a credit history and bills later.
What is the APHIS voluntary inspection and certification service?
A service under 9 CFR Part 156 in which APHIS supervises processing, handling and storage of animal products at a plant and certifies their class, quality, quantity or condition against foreign requirements or contract terms.
Does pet food count as an animal product for APHIS?
Under 9 CFR 156.2, an animal product is anything made of, derived from or containing any material of animal origin, which covers pet food with animal-derived ingredients.
Can APHIS refuse to certify pet food?
Yes. Service is refused if the plant and its methods of processing, handling and storage are not adequate to warrant the certificates sought (9 CFR 156.5 and 156.8).
Is pet food food under US law?
Yes. The FD&C Act defines food as articles used for food or drink for man or other animals, so its export rules for food apply to pet food.
Can I export pet food that does not meet US rules?
Under FD&C Act section 801(e)(1), if it meets the buyer's specifications, does not conflict with the destination's laws, is marked for export on the shipping package and is not sold in the US. Records are kept for 3 years.
Where do I find a destination's requirements for pet food?
The FDA's food export library points exporters to APHIS for the requirements on exporting animal products. The exporter is responsible for meeting the importing country's laws.
Do I need to file EEI to export pet food?
Yes, through the AES, unless an exemption applies, such as $2,500 or less under one Schedule B number to one consignee, or most shipments to Canada.
How does Compliant Always help with exporting from the US?
Our team reads the rules for the routes you ship. Compliant Always shows which export documents apply to your product, keeps them with the shipment beside what the destination asks for, and watches the sources for changes. It shows what the requirements say and what your documents show; you decide.

Sources

Compliant Always is a product of Lettuce Labs LLC. It shows what requirements say and what your documents show. It is not legal advice, and you decide.

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