Exports of Animal-Based Foods to the United States: The USDA Process Beyond the FDA
There is an important fact for producers planning to export animal-based food products to the United States: whether it’s dry food, wet food, premium treats made from organs and offal, or processed meat products, the process for animal-based products works very differently from that for regular food. Completing FDA registration is not enough; for the product to clear U.S. customs , a second agency is involved: the USDA.
For producers who set out without understanding this distinction, the outcome is unfortunately the same: the container waits at the port, daily demurrage charges accrue, and in some cases, the product is returned. Yet the rules are clear; when set up correctly from the start, the process proceeds smoothly. In this article, we outline the process for importing animal-based food products into the U.S. within a framework that covers all product groups.
The U.S. Animal-Based Food Market: Why Is Demand So Strong?
The U.S. is the market with the highest spending on animal-based foods worldwide. Three categories in particular present a real window of opportunity for Turkish producers:
Pet Food and Premium Treats
The U.S. pet products market has surpassed $270 billion as of 2025 and is expected to approach $400 billion by 2030. The fastest-growing segments are premium and functional treats: freeze-dried meat treats, single-protein and grain-free foods, and organ-based high-value-added products. For our in-depth guide specifically on pet food, please see our article titled “Exporting Pet Food to the U.S.: A Guide to APHIS, FDA, and Amazon.”
Milk and Dairy Products
U.S. cheese imports exceed $2 billion annually; sheep’s milk cheese, tulum, and aged cheeses hold a strong position on gourmet shelves. Turkish dairy products are finding a genuine market, particularly within the Mediterranean cuisine segment and in the ethnic grocery market network.
Processed Meat and Charcuterie
Traditional products such as sucuk, pastırma, and kavurma are reaching both the diaspora and the mainstream consumer base that is capitalizing on the “international foods” trend. However, this category is subject to the most intensive USDA oversight, making process design particularly critical here.
The demand side is ready. The key factor is whether the regulatory framework was set up correctly from the start.
Why the USDA? What Doesn't the FDA Cover?
Let’s clear up a misconception right from the start: The FDA is responsible for food “in general,” but not for all food. In the U.S., food regulation is divided between two agencies:
- FDA (Food and Drug Administration): The vast majority of conventional foods, processed foods, beverages, dietary supplements, cosmetics, and drugs.
- USDA (United States Department of Agriculture): Meat , poultry, and egg products, as well as many other products containing animal-derived ingredients. The USDA’s food safety division is the FSIS (Food Safety and Inspection Service), and its animal health division is the APHIS (Animal and Plant Health Inspection Service).
The main reason the USDA is involved can be summed up in one word: biosecurity. The U.S. enforces extremely strict border controls to prevent foreign animal diseases—such as foot-and-mouth disease (FMD), African swine fever (ASF), and avian influenza—from entering the country via imported animal products. So the issue isn’t just “Is your product safe?” but rather “Is this product acceptable based on the animal health status of the country of origin?”
This approach also explains the most common mistake made by Turkish manufacturers: a product may be completely compliant with FDA standards, but if the country of origin does not meet the required animal disease status, the product cannot enter the U.S. Inspections are conducted not on a product-by-product basis, but based on the combination of country, product, and manufacturer.
What Is Required for Animal Products?
Although it varies by product group, the U.S. import dossier for products containing animal-derived ingredients typically includes the following components:
1. Health Certificate from the Country of Origin
An official certificate issued by the competent authority in Turkey (the Ministry of Agriculture and Forestry) certifying that the product is eligible for export from an animal health perspective. It must be issued in a format accepted by the USDA, in English, and include the correct references. It is generally issued separately for each shipment.
2. USDA FSIS Documents
Production facilities for meat and poultry products subject to the FSIS process support shipments with relevant documents, primarily FSIS 9540-I. The general rule is as follows: The USDA expects imported products subject to FSIS inspection to originate from countries with an inspection system equivalent to U.S. standards. Turkey’s equivalence status is evaluated on a product-by-product basis; for processed meat products, this must be clarified from the outset.
3. APHIS Permit and VS Permit
An APHIS Veterinary Services (VS) permit is required for by-product-based products, dried organ treats, certain dairy products, and feed/pet food products. Queries are made through APHIS’s VS Permitting Assistant system based on the product-origin combination; each product is subject to its own set of rules. For a detailed guide covering the application steps, the current APHIS eFile process, and common mistakes made by Turkish producers, please refer to our guide titled “How to Obtain a USDA/VS Permit?”
4. The FDA and Prior Notice
The USDA tier does not eliminate the FDA. For many products containing animal-derived ingredients—including pet food—the requirements for FDA facility registration, designation of a U.S. Agent, and Prior Notice for each shipment remain in effect. In other words, the process is structured not as “FDA or USDA,” but as “FDA + USDA.” For details, please refer to our guide on FDA Registration and Documentation.
5. Customs and Importer Layer
On the shipment side, the customs clearance process for animal products cannot proceed smoothly without an importer’s registration, a customs bond, and the correct HTS classification. On the labeling side, the product name, net quantity, ingredients, allergens, manufacturer information, and country of origin (Product of Türkiye) must be stated in the U.S. format and in English. Our FDA Labeling and Customs Consulting Guide will serve as a helpful resource for label reviews.
What Is the Cost of Incorrect Ordering?
The practical consequences of not properly configuring the documents before the product is shipped are as follows in practice:
- Demurrage and storage fees: The daily charge for a container held at customs ; this can amount to thousands of dollars within a few weeks.
- Sample and testing costs: Any additional samples or tests required by the FDA or USDA will be charged to the importer.
- Re-export or destruction: Returning or destroying products that are not accepted for import results in both financial loss and damage to reputation.
- Import Alert (DWPE) risk: In the event of recurring issues, inclusion on the FDA’s “Detention Without Physical Examination” list; all subsequent shipments are automatically detained.
- Customer relationship: A problem with the first shipment to a U.S. distributor or retailer is often the point of no return for the relationship.
What Does Correct Sorting Look Like in Practice?
The process we follow in the animal product projects we consult on works roughly as follows:
- 1. Product-of-origin eligibility check: The import requirements for each product based on its Turkish origin are determined through the APHIS VS Permitting Assistant. This is the make-or-break point for the project.
- 2. Basic registrations: FDA facility registration + U.S. Agent; DUNS number, if required.
- 3. USDA tier: FSIS equivalence assessment and APHIS VS Permit application based on the product line.
- 4. Health certificate infrastructure: Establishing the certificate workflow on the Turkish side ; a process that will be repeated with each shipment.
- 5. Label and packaging compliance: Review and revisions of labels on a SKU-by-SKU basis to ensure compliance with U.S. standards.
- 6. Shipping operations: Prior Notice, importer registration, customs bond, correct HTS classification, freight planning.
Roadmap, At a Glance
| Stage | What's Happening | Why It Matters |
| Category Analysis | Product-Specific Admissibility (APHIS VS) | The project's make-or-break point |
| FDA Basics | Facility Registration + U.S. Agent + Prior Notice | FDA requirements also apply to animal-derived products |
| USDA FSIS | Equivalency Assessment + Documentation Package | The Main Gateway for Meat and Poultry Products |
| APHIS authorization | VS Permit Application and Follow-Up | Detectable in offal, organs, and certain dairy products |
| Tag | Label in U.S. format by SKU | Most of the revisions are made here |
| Shipping | Health certificate + bond + HTS | A recurring operation in every shipment |
Frequently Asked Questions (FAQ)
Isn't FDA registration sufficient for animal products?
That’s not enough. Depending on the product category, USDA FSIS and/or APHIS approvals also apply; a health certificate is required for every shipment. The FDA and USDA requirements are established together.
Is a health certificate required for every shipment?
Yes. A health certificate is issued by the authority of the country of origin for each shipment; it must be in a format accepted by the USDA.
How long does an APHIS permit last?
It varies depending on the combination of product and country of origin; early application and proper documentation significantly shorten the process. Beyond the timeframe, the key issue is whether the product is eligible for import from the relevant country of origin.
How does Turkey’s foot-and-mouth disease status affect exports?
The USDA evaluates imported animal products based on the animal disease status of the country of origin. For this reason, the advance verification of the product-origin combination in the APHIS system is the first step in the process.
Can my label be in Turkish?
No. The entire label must be in English and include the required elements in the U.S. format.
Setting Up the Documents Correctly Before the Product Is Shipped
The key issue in animal-based food exports is ensuring that the documentation is properly prepared before the product is shipped. Projects where FDA and USDA requirements are not planned in tandem often end up learning the hard way through delays and costs incurred during the first shipment; however, for producers who proceed in the correct order, the process becomes predictable.
We manage the entire process—from start to finish—for FDA and USDA regulatory compliance related to the export of animal products from Turkey to the United States. In addition, we coordinate shipping and U.S. customs clearance, as well as U.S. tax and accounting matters and trademark registration, all under one roof.
Related guides: How to Obtain a USDA/VS Permit? · Exporting Pet Products from Turkey to the U.S. · FDA Registration and Certification · Trademark Registration in the U. S.
Other guides in this series
This guide is part of a series explaining FDA processes for exporting to the U.S. Other related guides:
- Steps Involving APHIS, FDA, and AAFCO for Pet Food Exports to the U.S.
- Exports of natural dog chew products to the U.S.
- FDA Registration, GMP, and Customs for Vegetable Oil Exports
- For support with registration and certification, please see our FDA registration and certification services.
