📅 Prepared March 12, 2026 | 🔄 Revised September 24, 2026 ✍️ Dirk Adams with the assistance of AI ⌛ 12 min read 33 sources

SEAFOOD RESEARCH SERIES | PAPER NO. 2

How USDA Polices Siluriformes Processing

The FSIS rules, directives and enforcement tools behind catfish inspection, from the grant of inspection to import reinspection and recalls.

Prepared for publication by Farm Animal Transparency | September 2026

Siluriformes plants are not policed by a single end-product check. The rules start before the plant opens and continue at the border and in commerce.

Photo: Tender (fish buying boat) at fish processing plant by sf-dvs, CC BY 2.0, via Flickr.

At a glance

Entry requirements. Before a plant receives inspection it must have written Sanitation SOPs, written recall procedures and a HACCP plan. A conditional grant lasts no more than 90 days while the plan is validated.

Meat-style enforcement. The fish rules adopt the meat-inspection rules of practice (9 CFR part 500): regulatory control actions, withholding of the mark, suspension and withdrawal, plus detention, seizure and criminal provisions.

Inside the plant. Slaughter plants are covered once per production shift. Inspectors check whole fish for species at least once per quarter where plants receive whole fish, and FSIS samples for species and drug residues.

At the border. Every imported lot is reinspected. Only China, Thailand and Vietnam have eligible Siluriformes establishments. Recalls in 2025 and 2026 involved product that skipped reinspection or came from ineligible countries.

Abstract

This paper describes how the USDA Food Safety and Inspection Service (FSIS) enforces its inspection program for fish of the order Siluriformes, as of September 2026. It covers the conditions for a grant of inspection, plant facility rules, product disposition rules, sampling and label checks under current FSIS directives, import reinspection, and the escalation tools available to FSIS. It closes with recent recalls. Paper No. 1 explains why Siluriformes are inspected by FSIS rather than FDA.

1. The enforcement ladder

The fish rules are at 9 CFR parts 530–561. Many sections adopt the corresponding meat-inspection rules by cross-reference. The table groups the controls by stage.

Stage	What FSIS checks	Main consequence
Entry into inspection	Written Sanitation SOPs, written recall procedures, HACCP plan and validation	Conditional grant, refusal or withdrawal
Plant operation	Separation from unofficial operations, inspector facilities, locked official devices, inspection coverage	Regulatory control action
Product controls	Disease and parasite findings, spoilage, physical contamination, drug and pesticide residues, inedible material	Retention, condemnation or controlled disposal
Sampling and labeling	Species verification, residue testing, quarterly species checks, inspection legend, common or usual name	Withheld mark or misbranding
Imports	Country eligibility, foreign certificate, application for inspection, reinspection of every lot	Refused entry or recall
Escalation	Detention, seizure, withholding, suspension, criminal provisions	Product stopped or grant of inspection at risk

2. How the system works

Enforcement starts before the first fish is processed

Under 9 CFR 532.2, fish establishments must meet the conditions in 9 CFR 304.3. A plant must have written Sanitation SOPs and written recall procedures, and must have conducted a hazard analysis and developed a HACCP plan. A conditional grant of inspection may be issued “for a period not to exceed 90 days, during which period the establishment must validate its HACCP plan.” Official numbers, inauguration of inspection and withdrawal follow the meat rules in 9 CFR part 305.

The rules also reach upstream. Part 534 says fish farmers should monitor their water for contaminants such as heavy metals, pesticides and industrial chemicals, allows only lawful use of FDA-approved drugs, and requires transport vehicles to supply “sufficient water and sufficient oxygen.” FSIS may collect samples of feed, fish and water from producers (9 CFR 534.2). It may also periodically inspect the records of businesses that hatch, feed, grow or transport fish (9 CFR 532.1(b)(5)).

Plant-level controls borrow from meat inspection

Part 533 requires an official establishment to be “separate and distinct from any unofficial establishment.” It must provide office space and facilities for inspectors, receptacles marked “U.S. Condemned,” denaturing materials, and locked storage for official brands and certificates whose keys stay with FSIS employees. Overtime and holiday inspection follow the meat rules. Since September 1, 2017, FSIS has covered establishments that slaughter Siluriformes once per production shift rather than during all hours of operation (82 FR 41501).

Product-control rules are specific

Fish establishments must comply with 9 CFR parts 416 (sanitation), 417 (HACCP) and 418 (recalls and notification). The hazard analysis must cover hazards “that can occur before, during, and after harvest” (9 CFR 537.2). If adulterated or misbranded product has entered commerce, the establishment must notify the local FSIS District Office within 24 hours.

Part 539 lists mandatory dispositions. Fish with specified parasites, lesions, columnaris or enteric septicemia (ESC) must be disposed of so they are not used as food. Spoiled or decomposed fish are subject to condemnation. Physically contaminated product is subject to retention and condemnation. Drug residues must be within FDA tolerances in 21 CFR part 556, and pesticide residues within EPA tolerances in 40 CFR part 180.

Under part 540, fish that died other than by slaughter may not be brought into an official establishment without advance permission and must be kept out of any room where edible product is prepared. Condemned and inedible material must be separated from edible fish and either denatured or held in marked containers, and may be shipped under seal to rendering. FSIS may take samples of “products, water, dyes, chemicals, preservatives, spices, or other articles” in an establishment at no cost to the program (9 CFR 548.3).

Directives add a second layer

FSIS Directive 14,010.1, Revision 2 (January 17, 2025), governs Siluriformes sampling in domestic establishments. It covers species verification and residue sampling and instructs inspectors to “withhold the mark of inspection on raw, wild-caught fish pending acceptable FSIS residue results.” Ready-to-eat fish products are sampled for Salmonella and Listeria monocytogenes under FSIS’s ready-to-eat program.

FSIS Directive 14,000.1, Revision 1 (October 3, 2022), sets inspector duties at fish establishments. Inspectors perform verification tasks during each operational shift and must “visually examine whole fish, at least once per quarter,” in establishments that receive whole fish, to verify species. They order speciation testing when a visual check cannot confirm the species.

FSIS suspended its Salmonella sampling program for raw Siluriformes on July 13, 2022 (87 FR 35720). It cited “consumer cooking practices, lack of recent outbreaks attributed to Siluriformes fish, and low percent positives detected.” Residue and species sampling continue.

Product release depends on names, marks and records

The official inspection legend “must be shown on all labels for inspected and passed fish and fish products” and must be applied by mechanical means, not a hand stamp (9 CFR 541.2). Labels must carry the common or usual name, and only fish of the family Ictaluridae may be called “catfish” (9 CFR 541.7). The operator of each official establishment is responsible for complying with the Act and the regulations (9 CFR 548.1). Records follow the meat rules in part 320 (9 CFR part 550). Most must be kept for “2 years after December 31 of the year in which the transaction” occurred (9 CFR 320.3).

Imports face a separate layer

A country may export Siluriformes only if FSIS finds its inspection system equivalent (9 CFR 557.2). As of September 2026, FSIS lists eligible Siluriformes establishments only in China and Thailand (raw product) and Vietnam (raw and processed product). Each consignment must carry a foreign inspection certificate (9 CFR 557.4), and the importer must file an application for inspection in advance (9 CFR 557.5).

All imported fish must be reinspected before entry. Under 9 CFR 557.6, “every lot of product shall routinely be given visual inspection by a Program import inspector for appearance and condition, and checked for certification and label compliance.” FSIS’s electronic system assigns further “reinspection levels and procedures based on established sampling plans and established product and plant history.” FSIS Directive 14,950.1, Revision 1 (March 16, 2023), tells import inspectors to “refuse entry on the lot” when defects are found and to stamp it “United States Refused Entry.” Residue and species sampling at import is covered by FSIS Directive 14,100.1. FSIS lists the analytes as veterinary drug residues, malachite green, gentian violet, metals, pesticides and species.

Escalation can stop product or end inspection

Part 561 applies the meat-inspection rules of practice in 9 CFR part 500 to fish. A regulatory control action is “the retention of product, rejection of equipment or facilities, slowing or stopping of lines, or refusal to allow the processing of specifically identified product.” A withholding action is “the refusal to allow the marks of inspection to be applied to products.” FSIS may suspend inspection without prior notice when a plant has shipped adulterated or misbranded product, lacks a HACCP plan or Sanitation SOPs, has sanitary conditions that would adulterate product, violates a regulatory control action, or interferes with an FSIS employee (9 CFR 500.3(a)).

Part 559 applies the meat rules on administrative detention and judicial seizure and condemnation to fish, and applies the Act’s criminal provisions. The official detention mark is “U.S. Detained” (9 CFR 541.5).

3. Recent enforcement examples

Date	Company	What happened
Aug. 2026	Asian America Trading, Inc. (Hayward, CA)	About 996 lb of ready-to-eat fish skin crackers made from Pangasius in China, which is not eligible to export ready-to-eat Siluriformes products. Found during routine FSIS surveillance of imports in commerce (details as reported by trade press).
Aug. 7, 2026	Shan Distribution Network, Inc. (Carol Stream, IL)	About 5,084 lb of frozen breaded swai fillets and sticks produced in the United Arab Emirates, a country not eligible to export Siluriformes.
Feb. 19, 2026	Sobico USA LLC (West Hartford, CT)	About 13,464 lb of frozen, raw intact Siluriformes from Vietnam imported without import reinspection.
June 12, 2025	Starway International Group LLC (Maspeth, NY)	About 9,513 lb of frozen fish ball products from a Vietnamese establishment not eligible to export Siluriformes. The recall was later expanded.
Nov. 8, 2019	You Chang Trading, Inc. (Brooklyn, NY)	Frozen, raw Siluriformes fillets labeled as tilapia that were not presented for FSIS import reinspection.

The pattern is consistent. Each of these recalls turns on border control: product that was never reinspected, or product from a country or plant that is not eligible. The You Chang case also involved a species label that did not match the fish.

4. Conclusion

The FSIS Siluriformes program is more than a mark on the package. It sets conditions before a plant opens, controls official devices inside the plant, sets fish-specific disposition rules, samples for species and residues, reinspects every imported lot, and gives FSIS tools to stop product or suspend inspection. For Farm Animal Transparency (FAT), the practical result is that a Siluriformes package carries a USDA establishment number that can be traced to a plant and to its FSIS record.

Related FAT maps

The FAT catfish supply chain map shows FSIS-inspected Siluriformes plants alongside EPA ECHO permit compliance records.

Sources

Working paper. First prepared March 12, 2026; revised September 24, 2026 with data as of that date. Corrections welcome: dirkadams@farmanimaltransparency.com.