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Issue of the Month

International Equivalence: What Foreign Governments and Exporters Must Get Right to Access the U.S. Market

Exporting to the U.S. requires more than product compliance — it requires system-wide alignment.

By Jonathan Morse, EAS Consulting Group Independent Consultant

Exporting meat, poultry, egg products, or catfish to the United States is not just about meeting product requirements. It requires demonstrating that an entire national inspection system operates at a level equivalent to the U.S.

That’s where many efforts run into challenges.

FSIS is not evaluating a single facility. It is evaluating how consistently a country applies inspection, enforcement, and oversight across its entire system. Gaps between written programs and actual practices, inconsistent enforcement, and limited visibility into system performance are common reasons equivalence efforts stall or fail.

In this Issue of the Month, EAS Consultant Jonathan Morse outlines how the equivalence process works, where countries and exporters typically encounter delays, and what needs to be in place before pursuing access to the U.S. market.

Most organizations only uncover these gaps during audits or market access delays.

If your organization is evaluating readiness for international equivalence or preparing for FSIS review, connect with Rob Williams to discuss your approach.

Under the Microscope

How Listeria Strain Typing Supports Faster, Smarter Investigations 

Reviewed by Aaron Pleitner, Director of Microbiology Technical Services, Certified Group

As a member of the Certified Group and Food Safety Net Services, EAS clients have access to world-renowned testing laboratories that meet your organization’s sophisticated needs. In this column, you’ll hear about their capabilities, environmental challenges and more. We hope you’ll enjoy a look “under the microscope.”

Many risks identified during equivalence reviews and inspections originate in areas only revealed through testing.

1-Minute Summary 

• Listeria strain typing helps show whether product and environmental isolates are related, supporting faster source tracking and root cause analysis. 
• In one case study, a manufacturer of deli meat used strain typing to link the product isolate to the slicer and conveyor, not a utensil positive, which helped them target the harborage site and apply purposeful mitigation efforts. 
• In another case study, a manufacturer of ice cream used strain typing to support subtyping without species identification, reducing recall-related concern. 
• In both cases, the data helped focus remediation by separating related contamination from unrelated positives, facilitating faster time to regaining hygienic control.

FDA and USDA Regulatory Updates

Key regulatory developments shaping compliance and market access:

▪ FDA to Host Public Meeting on the Scope of Dietary Supplement Ingredients

▪ FDA Withdraws Temporary COVID FSMA Guidances Related to Onsite Audits

▪ FDA Announces New Steps to Streamline Biosimilar Development

▪ FDA Finalizes Rule Standardizing National Drug Code Format

▪ FDA Issues Guidance on Responding to Form 483 Observations Following Drug CGMP Inspections

▪ FDA Announces Public Meeting on Dietary Supplement Innovation and Ingredient Scope

▪ FDA Expands Infant Formula Resources to Support Transparency and Access

Stay current with EAS events, training, and industry engagement:

Consultant Corner

EAS offers over 200 independent consultants strategically located around the globe whose expertise provide core value for clients.

Issue of the Month Author

Jonathan Morse

EAS Consulting Group, Independent Consultant

Jonathan Morse began his career with the USDA Food Safety and Inspection Service (FSIS) as a Relief Food Inspector. He later served as a Consumer Safety Officer and Enforcement Investigations and Analysis Officer (EIAO).

He also worked in industry as a Corporate HACCP Coordinator and Senior Program Auditor on the International Audit Staff. Jonathan retired from the USDA in September 2025 and now provides consulting services worldwide to foreign governments and food establishments.