Meal kits do not require assembly subject to FSIS inspection if packaged separately and labeled appropriately.
July 15, 2019
The U.S. Department of Agriculture has released guidance on meal kits that contain a meat or poultry component requiring inspection by the agency’s Food Safety & Inspection Service (FSIS).
The guidance indicates that meal kits do not require assembly subject to FSIS inspection if: (1) the “meat or poultry component is prepared and separately packaged under FSIS inspection and labeled with all required features,” (2) the “outer kit label identifies all of the individual components in the kit” and (3) the “outer kit label clearly identifies the product as a single unit or ‘kit,’ such as ‘Chicken BBQ Dinner Kit’ and ‘Beef Lasagna Meal.'”
There are many varieties of kit products, including, but not limited to: wraps, pizzas, stews, salads, fajitas, stroganoff or stir-fry skillet meals that include a meat or poultry component. Some of these items may also require cooking. Often, the meat or poultry component is separately wrapped and fully labeled and then assembled together with various other food components in the same packaging.
Kit products with a meat or poultry component are still under FSIS jurisdiction. These products must meet all applicable FSIS requirements to ensure that they are not adulterated or misbranded. After FSIS assesses comments on the guideline and gains additional information on establishments producing kit products, instructions will be issued to the Office of Field Operations to clarify what products constitute kits that should no longer be under inspection.
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