FSIS Technical Animal Fat Export Certification — Federal Inspection and Certification for Rendered Fat Exports
Legal Authority
- 21 U.S.C. § 469 — Agricultural Adjustment Act (as amended): authorizes USDA to inspect and certify agricultural commodities for export; the authority under which FSIS provides voluntary export inspection and certification services for rendered animal fats
- 9 CFR Part 351 — FSIS regulations governing technical animal fat export certification: establishes the voluntary service under which FSIS inspectors certify that rendered animal fats (tallow, lard, grease) meet specified quality standards for export to foreign markets that require USDA certification
Key Mechanics
The FSIS technical animal fat export certification program is a voluntary service — exporters of rendered animal fats (tallow, lard, yellow grease, and similar products) may request FSIS inspection and certification to satisfy importing countries' requirements. Many foreign markets, particularly in Asia and Europe, require USDA certification that animal fat products meet specific quality, composition, and freedom-from-adulteration standards before allowing import. FSIS inspectors collect samples from the fat lot, conduct laboratory testing for fat content, moisture, free fatty acid levels, and impurities, and issue export certificates attesting compliance with the applicable standards. Fees for the voluntary inspection service are charged to the applicant on a cost-recovery basis. The certification documents state the product origin, tested characteristics, and the USDA inspector's attestation — the credentials that foreign customs and food safety agencies require for import clearance.
Current Rule (2026)
| Parameter | Value |
|---|---|
| Citation | 9 CFR Part 351 |
| Issuing agency | USDA Food Safety and Inspection Service (FSIS) |
| Statutory authority | 21 U.S.C. § 469 (Agricultural Adjustment Act, as amended) |
| Last major amendment | No recent Federal Register amendments |
What This Rule Does
"Technical animal fats" — rendered tallow, grease, lard, and related products from animal processing — are major agricultural commodities exported from the United States to markets in Europe, Asia, and Latin America for use in animal feed, oleochemical manufacturing, biodiesel, and industrial processes. Foreign buyers often require that these products carry official U.S. government certification of identity, composition, and processing standards before import is permitted.
Nine CFR Part 351 establishes the voluntary FSIS certification program for technical animal fat exports. Rendering plants and processors can apply to become "certified plants" — official inspection facilities where FSIS inspectors verify that animal fat products meet the specifications stated on their export certificates. The certification is not mandatory for all exports, but it is functionally required by many importing countries' customs and agricultural import authorities.
The program distinguishes between technical animal fats (processed and rendered products intended for industrial or feed use) and edible animal fats (inspected and certified under the regular FSIS meat inspection programs). Part 351 covers only technical (non-edible) grades.
Key Provisions
- § 351.2 — Definitions: "technical animal fat" means rendered animal fat that does not meet the standards for edible grade; "certified plant" means a rendering or processing plant that has been approved by FSIS to produce certified technical animal fats; "inspector" means an authorized FSIS inspector assigned to a certified plant; the definition of "department" refers to USDA as a whole
- § 351.3 — Certification form: the official USDA export certification for technical animal fats takes a specific form; only certified plants can export product bearing the "Certified U.S.A." identification; unauthorized use of this certification mark is a violation
- § 351.10 — Facility requirements: certified plants must maintain facilities adequate for preparing, identifying, and storing technical animal fats intended for export; the physical layout must allow FSIS inspectors to observe all relevant processes and separate certified product from non-certified material
- § 351.11 — Identification and separation: certified plants must maintain strict separation between technical animal fats that have been certified and uncertified materials; tanks, containers, and equipment used for certified product must be properly identified; wrappers and equipment must be cleaned between uses to prevent commingling
- § 351.12 — Inspector access and notification: certified plant operators must inform the FSIS circuit supervisor when the plant is operating on any given day; FSIS inspectors must have unimpeded access to certified plants at all times, including unannounced visits during operations
- § 351.13 — Supervision of processes: FSIS inspectors supervise all processes used in preparing certified technical animal fats; inspectors may examine and test product at any stage of production; the extent of examination is at the inspector's professional judgment
- § 351.14 — Certification process: inspectors examine lots proposed for certification; they verify that the product meets applicable specifications for composition, color, free fatty acid content, moisture, and other parameters relevant to the export certificate's representations
- § 351.15 — Violation reports: inspectors must report to the circuit supervisor any apparent violations of the regulations or the specifications stated on export certificates; the circuit supervisor decides whether to suspend certification for the lot or the plant
- § 351.16 — Certificate required for export: no certified plant may export any certified technical animal fat without a valid certificate issued under this Part; the certificate must accompany each shipment and be available to customs and import authorities at the destination
- § 351.17 — Identification of certified product: certified technical animal fats being exported must bear proper identification (tank markings, container labels, shipping documents) that trace them to the specific certified lot and the certifying inspector's records
- § 351.18 — Official identification marks: the "Certified U.S.A." identification mark may only be applied by FSIS inspectors at certified plants; unauthorized use — by any person not authorized by FSIS — is a violation of the regulations and may constitute fraud in export transactions
- § 351.19 — Refusal of certification: if an inspector has reason to believe that a lot of technical animal fat does not meet the standards for certification (based on visual examination, test results, or other evidence), the inspector may refuse to issue a certificate for that lot; the plant may request review of the refusal
How It Affects You
If you operate a rendering plant or animal fat processor and export to countries that require official USDA certification, Part 351 is the pathway to obtaining that certification. Becoming a "certified plant" requires FSIS approval of your facilities and processes, commitment to daily inspector access, and adherence to lot separation and identification requirements.
The certification is functionally mandatory for access to many markets. European Union import requirements for animal by-products, Japanese feed ingredient import permits, and South Korean and Chinese technical fat import protocols often require official USDA certification. Without a Part 351 certificate, your product may be turned back at the destination port — at your cost.
FSIS inspectors are embedded in your operation during any production run that generates product for export certification. This is not a sampling audit — it is continuous process supervision. Plan your operations and facility layout to accommodate FSIS inspector presence as a normal part of export production.
The $25,000 ceiling on administrative settlements (for FTCA purposes) means enforcement actions for misuse of official certification marks or fraudulent certification are pursued directly through USDA and DOJ, not settled administratively.
Separation between certified and non-certified product is strictly enforced. A single lot of non-certified product commingled with certified product — whether through equipment contamination, improper tank labeling, or documentation failure — can result in loss of certification for the entire production run and potential suspension of the plant's certified status.
Statutory Authority
This rule implements:
- 21 U.S.C. § 469 — Authorizes USDA to provide inspection and certification services for animal products intended for export at the request of exporters; the authority underpins voluntary export certification programs including Part 351
- 7 U.S.C. § 1622 — Agricultural Marketing Act; provides additional authority for USDA to provide grading, inspection, and certification services for agricultural commodities, including animal products
Recent Rulemakings
No major Federal Register amendments reported. The certification framework has been stable; specific product standards and testing protocols may be updated through administrative guidance.