Questions and Answers for AMS Export Verification Program for China

The questions and answers below are categorized by subject matter and will be updated as needed.

Applying for and Receiving Service

Q: Who conducts audits for USDA?

A: The Agricultural Marketing Service; Livestock and Poultry Program’s; Quality Assessment Division conducts the audits.

Q: How are the audits conducted?

A: Clients should reference QAD 1000 Procedure, Quality Systems Verification Programs General Policies and Procedures (pdf).  It explains how QAD provides services and conducts audits and the responsibilities of companies.

Q: How do I request an audit?

A: Contact QAD at QAD.BusinessOps@ams.usda.gov or 501-312-2962. 

Q: What do I need to submit when applying for audit services?

A: There are 3 documents needed to apply for audit services.  This information is available at How to Apply for Services.

The 3 documents include:

  1. A Letter of Request. The Letter of Request should include the name and address of the company, the USDA Program that service is being requested, an overview of the company, and name and contact information for the company representative.
  2. Form LP-109, Application for Service. An electronic copy of the LP-109 may be sent to QAD by email to initiate the audit review process; however, we must receive a signed original copy of the LP-109 prior to conducting the onsite audit.  If an LP-109 is already on file for your company, you do not need to submit a new form unless you are requesting a different type of service (e.g., auditing versus grading).
  3. Quality Manual. The quality manual must include documented procedures, work instructions, and forms, etc. that address the specific Program requirements.  It is not necessary to submit records with the application; however, they must be available for review during the audit.

Q: How do I submit my application?

A:      By e-mail: QAD.BusinessOps@ams.usda.gov

By mail: USDA, AMS, LP, QAD
10809 Executive Center Drive, Suite 318
Little Rock, AR 72211

Q: How much do audit services cost?

A: Clients are charged an hourly fee of $108 for time incurred conducting the document review, travel time, on-site audit, and report preparation.  Clients are also charged for travel and per diem costs associated with the audit.

Q: Who pays for audit services?

A: The audit programs are user-fee funded.  This means that the audits are paid for by the company that requests the audit services. 

Q: If I already have a QSA or PVP in place, do I need to do anything?

A: Yes, you need to submit significant changes to your quality manual to address the specific requirements for the EV Program for China.

EV Program for China

Q: What are the specified product requirements for China?

A: Specified product requirements are the constraints or qualities that define the product.  The specified product requirements for export to China are included in the EV: Specified Product Requirements for Bovine – People’s Republic of China (QAD 1030AA)(pdf).  The requirements include:

  • Meat must derived from cattle of U.S., Canadian, or Mexican origin;
  • Cattle born in the U.S. must be traceable to their ranch/farm of origin;
  • Cattle born in Mexico or Canada must be traceable to their first residence in the U.S. unless imported for direct slaughter;
  • If imported for direct slaughter, Canadian and Mexican origin cattle must be traceable to their port of entry;
  • Meat must be derived from cattle less than 30 months of age;
  • Chilled or frozen bone-in and deboned beef products are eligible for shipment.  For a complete listing, refer to the FSIS Export Library; and
  • Carcasses, meat, and meat products must be uniquely identified and controlled up until the time of shipment. 

Q: How do I determine what products are eligible for export to China?

A: For a listing of eligible products, refer to the FSIS Export Library

Q: Are these EV Program requirements for China voluntary?

A: These EV Program requirements are only mandatory for those wishing to export beef to China.  Companies must meet the requirements outlined in the USDA Export Verification Program: Specified Product Requirements for Bovine – People’s Republic of China.

Q: Are there products that are NOT eligible to export to China?

A: Yes. Please refer to the FSIS Export Library.

Q: How do I determine what product an approved supplier can export to China?

A: Product produced from cattle slaughtered on or after the FSIS Export Library approved slaughter date is eligible.  However the company must become eligible for the AMS Program also and this will be the approval date for export to China for the company. The company's approval date is listed on the Official Listing of Eligible Suppliers to the EV Program for China (pdf) as "Date of Approval for Shipment to China."  If you are an AMS further processor and wanting to buy product approved for China and then further fabricate it for export, you must contact the supplier to determine if they produce the product you want to export.

Q: What is required for an animal to meet the traceability requirements?

A: Cattle must be traceable to the birth/ranch of origin for U.S. origin cattle.  In the case of cattle imported from Mexico or Canada, their first residence in the U.S. or if imported for direct slaughter their port of entry.  That means:

  • Animals must be identified prior to leaving the place of birth/ranch of origin (or first residence for imported cattle) with a program compliant ear tag.  A program compliant ear tag (PCT) is a 1-time use, tamper-evident tag, which contains a non-repeatable, unique number.  It may be an EID, RFID, or a visual tag.  The company must provide evidence that the tag meets these requirements;
  • PCT numbers must be accessible by AMS in order to determine compliance of source verification/origin status.

Q: Will AMS allow approved third-parties to verify the live animal requirements?

A: Yes.  There are approximately 20 third-party verification companies already approved by AMS for these activities

They have documented processes in place and established means for AMS to trace back individual animals, if needed. 

Q: What if I don’t work with a third-party verification company, how will I have to prove the cattle are eligible for China?

A: Cattle must meet the requirements outlined in the EV program for China.  If a packer wanted to develop a program (a USDA PVP or USDA QSA) on their own whereby they worked with producers/feeders to ensure these requirements are met, AMS could audit that program.

Q: Can animals be identified as a group?

A: No, all animals must be individually identified.

Q: Are imported live cattle eligible for the program?

A: Yes, from Canada or Mexico only – and with several conditions.  Cattle imported into the U.S. for direct slaughter must be accompanied by documentation (e.g., APHIS import inspection forms) and the harvest facility is responsible for ensuring those animals meet all program requirements.  Cattle imported into the U.S. not for direct slaughter (i.e., feeder calves) must be traceable to their first place of residence in the U.S. with the PCT.

Q: Can conforming and non-conforming cattle be shipped on the same truck?

A: Yes.  However, there must be controls to ensure the segregation of the non-conforming cattle to prevent their unintended use or delivery.  There must be records to show evidence of these controls.  For example: cattle are segregated on the truck in the individual compartments and the shipping documentation clearly identifies the number and location of the conforming and non-conforming cattle on that truck.

Q: Is it necessary for all establishments represented on the FSIS Export Certificate to be listed on the Official Listing of Eligible Suppliers to the EV Program for China?

A: Yes.  To export product to China, all establishments represented on the FSIS Export Certificate must be listed as eligible suppliers on the Official Listing.

Identification

Q: How do cattle need to be identified?

A: Cattle must be identified with a program compliant ear tag (PCT).  A PCT is a 1-time use, tamper-evident tag, which contains a non-repeatable, unique number.  The tag is unique and specific to the Program.  It may be an EID, RFID, or a visual tag.  The AMS-approved third party verification provider or company must provide evidence that the tag meets these requirements. 

Q: Must PCT begin with 840 in the 15 digit number?

A: No.  PCT do not need to meet the APHIS Animal Disease Traceability tag requirements.  However, the "840" tag meets all requirements of a PCT. 

Q: Where does the PCT have to be applied?

A: The PCT must be applied (1) under an approved USDA PVP or QSA Program and (2) at the birth farm or, in the case of imported cattle not intended for direct slaughter, at the first residence in the U.S.

Q: Do I have to use a PCT in a USDA Process Verified Program (PVP) or Quality System Assessment (QSA) Program?

A: No, but it is recommended.  The use of a PCT allows clients making claims that do not change from one location to another (such as age, source, and breed claims) more flexibility to market qualified animals.  Qualified animals may be marketed to unapproved locations without jeopardizing the claims associated with those animals.  Whereas, animals without a PCT must be marketed and moved from one approved location to another approved location in order to maintain the animal’s eligibility in the USDA Program. 

Q: If an animal loses a PCT, can it be retagged and retained in an approved USDA PVP or QSA Program?

A: Yes, an animal may be retagged if the PCT is lost while the animal is enrolled in a USDA PVP or QSA Program.  If the PCT is lost while the animal is not enrolled, then it is not eligible for inclusion in a USDA PVP or QSA Program.

Q: Can hot brands or freeze brands be used as a form of identification?

A: Brands may be used as a form of secondary identification at the farm or ranch, however the animal must still have a PCT as primary form of identification.  Brands alone do not allow for individual animal identification and traceability.

Publication Date: 
06/17
Programs & Offices: