IFN 05-18 – IFIS Importer declaration and IFIS Community Protection profile question for ready-to-eat processed finfish

Issued: 10 July 2018

Purpose

The purpose of this notice is to advise brokers and importers that from 8 August 2018, a voluntary importer declaration will be introduced for ready-to-eat processed finfish (RTE finfish), such as smoked salmon. This declaration enables the importer to declare that the finfish does not support the growth of Listeria monocytogenes. RTE finfish submitted with this declaration will be analysed against the Listeria monocytogenes standard of no more than 100 colony forming units of Listeria monocytogenes per gram.

FSH 07-2018 specifies the kinds of finfish in which the growth of Listeria monocytogenes will not occur.

These changes do not apply to:

What is changing?

Community Protection (CP) question

From 8 August 2018, the department will replace the existing CP questions for RTE finfish with the following question:

‘IFIS: Are the goods cooked, cured or smoked finfish that require refrigeration (frozen or chilled) and do not require further cooking before consumption? If yes, you have the option to lodge an ‘Imported Food Inspection Scheme–importer declaration for processed ready-to-eat finfish that does not support the growth of Listeria monocytogenes’. Search ‘IFIS Importer declarations’ at agriculture.gov.au for more information.’

The department will monitor the answers to the CP questions. Consistent with the department’s minimum document requirements policy, the department expects that importers and brokers will maintain records of the information used to substantiate answers to CP questions. The department may require brokers and importers to present this information upon request for compliance or verification activities. Giving false or misleading information is a serious offence.

Imported Food Inspection Scheme (IFIS) Importer declaration

From 8 August 2018, the department will introduce an importer declaration for RTE finfish, such as smoked salmon.

The‘Imported Food Inspection Scheme–importer declaration for ready-to-eat processed finfish that does not support the growth of Listeria monocytogenes’is a voluntary declaration that enables importers to provide information on why the RTE finfish does not support the growth of Listeria monocytogenes.

RTE finfish lodged with this declaration will be analysed against the standard of no more than 100 colony forming units of Listeria monocytogenes per gram.

FSH 07-2018 specifies the kinds of finfish in which the growth of Listeria monocytogenes will not occur.

The IFIS Importer declaration is valid for a year from the date it is signed by the importer. Giving false or misleading information in an importer declaration is a serious offence.

Clearance

The table below provides the tests applied and permitted results for RTE finfish based on the combination of the answer provided to the CP question and whether the goods are accompanied by an ‘Imported Food Inspection Scheme – importer declaration for ready-to-eat processed finfish that does not support the growth of Listeria monocytogenes’.

CP question

IFIS Importer declaration

Test applied

Permitted result

IFIS: Are the goods cooked, cured or smoked finfish that require refrigeration (frozen or chilled) and do not require further cooking before consumption?

Are the goods accompanied by an ‘Imported Food Inspection Scheme–importer declaration for ready-to-eat processed finfish that does not support the growth of Listeria monocytogenes’?

Yes

Yes

Listeria monocytogenes

n = 5, c = 0, m = 100 cfu/g

Yes

No

Listeria monocytogenes

n = 5, c = 0, m = not detected* in 25g

No

N/A

The food will be referred as a ‘surveillance food’ and surveillance tests apply, unless the broker has answered ‘Yes’ to another imported food CP question.

n = the minimum number of sample units which must be examined from a lot of food.
c = the maximum allowable number of defective sample units.
m = the acceptable microbiological level in a sample unit.

* the department allows appointed analysts to composite the five RTE finfish samples when the ‘not detected’ standard applies. This may result in reduced testing costs for importers.

Importers may request a review of a decision within the legislated timeframe for such reviews. If such a review requires re-sampling and re-analysis of samples (for example, for assessment against the other of the two standards) then this will occur at the importer’s expense. A non-compliant result, on its own, is not justification for a review or re-analysis.

How are the changes being implemented?

The changes do not apply until 8 August 2018. From 8 August 2018, the new CP question applies and importers and brokers can lodge the ‘Imported Food Inspection Scheme–importer declaration for ready-to-eat processed finfish that does not support the growth of Listeria monocytogenes’.

The ‘Imported Food Inspection Scheme–importer declaration for ready-to-eat processed finfish that does not support the growth of Listeria monocytogenes’ is available from the ‘Lodging declarations and documentation for imported food’ webpage.

The department has updated the risk food web page for ready-to-eat processed finfish. This web page provides details of the requirements for RTE finfish.

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