The U.S. Meat Export Federation (USMEF) recently submitted comments to the California Department of Food and Agriculture with industry concerns about the proposed regulatory text for Proposition 12.
Travis Arp, USMEF senior director of export services, said the USMEF?s comments are focused on the impact Prop 12 will have on international trade, including possible logistical challenges for pork exporters using California?s port infrastructure and cold storage facilities.
?The comments the USMEF submitted were very export-and-trade focused,? Arp said. ?One of the main issues in the proposed regulatory text is that product transiting through the state of California, whether or not it?s destined to be sold in California, has to be identified on commercial documents- like shipping manifests and bills of lading- on whether this product is Prop 12 compliant or if it is non-compliant. That?s not terribly difficult for a pork exporter to do. However, it really limits their commercial flexibility on that product. Say you have product that is sold to an export destination. It?s identified as not being Proposition 12 compliant, but then something ultimately falls through with that sale and you have to sell that product on the domestic market. Now you have to take that product out of California in order to merchandise it. It really creates a lot of complications from a logistic standpoint. The other aspect is that the California Department of Agriculture can inspect product as it crosses the border into California really at any given time. There?s a lot of product that is source-loaded in the Midwest- that product is already in a container, it?s sealed, that information might be recorded on official export certification documents- and, if the California Department of Agriculture decides to inspect that product at the border, they could remove seals. So, again, it can create issues on what your export documentation says and how you have to handle that product once it transits across the border and, ultimately, to the port where it?s going to go out for export.”
For more information and for the USMEF’s full comments, visit usmef.org.
