Is a firm that manufactures tuna sandwiches from canned tuna and distributes (sells) the product to sandwich vendors covered by the Seafood HACCP Regulation?
Yes. The vendors themselves sell the product retail, and are, therefore, exempt. However, the manufacturer sells the product wholesale and is, therefore, covered. The manufacturer must also be engaged in interstate commerce in order to be covered by the regulation, but, with canned tuna, that is highly likely.
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