March 12, 2019 CFSI Staff

Certificate Superseding Guidance

Effective April 1, 2019, certificates may be superseded for previously certified product that has left the US to rectify certificates that have been for example, lost, damaged, contain errors, or where the original information is no longer correct. These supersede certificates must be clearly marked to indicate that they are replacing the original certificate. A supersede certificate shall reference the number of the original certificate that it supersedes and the date the original was signed. 

Management requirements:

  • Regional supervisory staff is expected to do random verification of issued supersede certificates to ensure policy effectiveness and implementation. Supersede certificates issued through the Seafood Inspection Services Portal (SISP) provide a “supersede values” page which documents any changes. 
  • If a replacement certificate is issued in deviation from written policy, supervisory approval is required. A log shall be kept documenting reasons for deviation and corrective action taken.

Scenarios where a supersede may be appropriate:

  • For split load under following conditions: Product species must remain the same; weight must remain the same or lower. There is a limit of one time supersede per consignment for this issue, any requests beyond must be routed through HQ.
  • For change of country. Note: If, this is from outside EU to an EU country, then customer assumes the risk of possible rejection.
  • For change of consignee.
  • For change of processor if within the parent company only (EX. One vessel to another within same company ownership). NOTE: Change of Processor NOT allowed for EU certificates.
  • To correct minor typographical errors. In particular, EU will accept minor changes to container/seal number but not an entire container/seal number change. 
  • For changes in logistics (EX. port, vessel name)

Scenarios where a supersede is not appropriate include: 

  • If product has been accepted at a foreign border inspection post, then USDC will not supersede. It is up to customer to work with the ‘landed’ country (NEW COMPETENT AUTHORITY) for continued export.
  • For change of seal number.
  • To covert multiple certificates into less (EX. 2 into 1)
  • To add additional product or weight.
  • To change country of origin of product.
  • For product change under following conditions: Species ; expanded common name; type code; intermediate code; end product code
  • For product that has not departed the US. In this case, the original certificate should be voided and a new certificate should be issued.

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