If a firm sells their product intrastate to another processor, such as a warehouse, which distributes interstate, is the original firm covered?
Yes, firms that sell their product intrastate to another processor with knowledge that the product will then be introduced into interstate commerce, or with good reason to believe that the product will be introduced into interstate commerce, are subject to the requirements of the seafood HACCP regulation. However, a processor that distributes only to intrastate retailers or distributors with full expectation that the product will be ultimately distributed within that state, is not subject to the regulation. Situations such as these require careful consideration on a case-by-case basis.
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