Key points
- Requirements apply as at import, not as at contract date.
- Establishment approval is separate from product admissibility.
- Place responsibility for current compliance explicitly in the contract.
What changes
Contaminant limits, approved additive lists, establishment listings, certificate models, labelling requirements and origin restrictions following disease or safety events. Any of these can move while cargo is in transit.
Managing it contractually
Make the seller responsible for compliance with the destination requirements in force at import, require notification of any change affecting the shipment, and confirm establishment listing before each contract for regulated products.
What to verify
- Product, origin and establishment admissibility confirmed before contracting
- Contract placing responsibility for current compliance on the seller
- Monitoring of regulatory change for key origins and products
Risks to manage
- Cargo rejected on arrival following a rule change in transit
- Additive permitted at origin but not at destination
- Establishment delisted between contract and shipment
Common mistakes
- Assuming last shipment's requirements still apply
- Confirming admissibility only at the shipping stage
- Relying on a supplier's assurance without checking the official source
Frequently asked questions
Who is liable if rules change in transit?
Commercially it depends on the contract; regulatorily the importer is responsible for what is placed on the market. Contractual allocation should be explicit.
How is regulatory change monitored?
Through the destination authority's official publications and, for imported regulated products, through the establishment-listing databases relevant to the origin.
Related reading
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