- Lebanese companies should verify whether the U.S. government has prohibited doing business with a particular Lebanese company/ individual due to past export control violations or because they are subject to a U.S. sanctions program.
- Lebanese companies should consult the BIS Denied Persons List and the Treasury Department Office of Foreign Assets Control’s (OFAC) Specially Designated Nationals and Blocked Persons Lists provided in the sites below.
- The International Trade Administration’s Consolidated Screening List combines export-screening databases from the Departments of Commerce, State, and the Treasury into a single search tool. U.S. exporters may conduct electronic screens of potential international export partners using this database. - For a number of items, specific export licenses are required. These items include products whose high-tech nature implies that export may involve a national security risk. Contacting BIS will enable an exporter to determine whether a specific item requires a license. If a specific license is required, one of the considerations is the reliability of the end-user. Government agencies and companies with a solid business reputation are more likely to be granted a license.

Further to the mentioned above, all companies interested in exporting sauces to the United States of America should consider the following additional steps:
1- Register Your Facility with the U.S. Food and Drug Administration:
According to the FDA website any importer can import their food products into the United States without prior sanction of the FDA if the facility is registered and they give prior notice to the FDA of food shipments. You can register your facility on the FDA website.

2- Designate a U.S. Food Agent to handle your U.S. Communications:

All importers of food under U.S. requirements must have a U.S. food agent to act as a liaison for FDA communications regarding incoming food shipments. The FDA will communicate with your agent to schedule inspections and to verify that all food safety requirements are being upheld. This particular step is of the utmost importance. While it may seem simple to designate your importer or even your customs broker as your agent, the FDA recommends using a stateside agent and even offers a company directly through the FDA website, which can act as your agent. Usually the State Agent service includes:

• Registration Renewal: Mandatory Biennial FDA-Food Facility Registration Renewal
• Certificate of Registration: Certificates issued by Registrar Corp provide confirmation of your facility’s registration to industry
• Registration Updates: Registrations must be updated within 60 days of a change in required information
• Detention Assistance: Communication with FDA on your behalf to seek the release of a detained shipment
• Mock FDA Inspection: Onsite expert assistance.
• DUNS Assistance: Obtain a DUNS number or update an existing DUNS record
• FDA Compliance Monitoring: A unique system that continuously monitors your company’s FDA compliance status

- According to the U.S. Customs and Border Protection, food products that are imported into the United States may require additional permits, health certificates and/or other specialized certifications. These foods include but are not limited to: meat, milk, poultry, eggs, and other products that are from animal origin.
- The U.S. Customs and Border Protection assigns an Import Specialist at each port of entry that you may consult with regarding the requirements for your particular food product. They also highly recommend hiring a customs broker that can assist with your CBP entry.
- Food products must have a PN (Prior Notice) filed with the FDA to alert them of the shipment of your product for receipt at the port of entry. Once your food shipment(s) is received, it will be subjected to a thorough inspection to pass all food safety requirements. These inspections can be detailed to you by the Import Specialist so that you can ensure your imported food products will be readily received and will not be detained for not passing inspection.

N.B A Prior notice is a mandatory notification to the US Food and Drug Administration (FDA) of imported shipments of articles of food prior to their arrival in the United States. The notice holds information about the product, quantity, and packaging, and related facilities, such as the manufacturer, shipper, owner, and ultimate consignee.
Prior Notice Form:

4- Understand the FDA Requirements for Your Food Product
Each food shipment being imported into the United States, from fresh fruit to livestock, has particular requirements that must be met to pass inspection and be permitted to pass through the port of entry.
For further questions regarding the FDA regulations regarding your food product here is a list of helpful links that can direct you to the department that handles your particular item:
- Plant and Animal Items - U.S. Department of Agriculture: www.usda.gov
- Animal and Plant Health Inspection Service:
https://www.aphis.usda.gov/aphis/ourfocus/planthealth/import-information

Consumers are being more interested in their health which is directly related to their food consumption. Therefore, it’s of high importance to focus on transparency and visibility when stating the nutritional information, including calories, sugar, fat and other ingredients on the packaged food . A recent Mintel Survey has highlighted the following trends:
- 63% of consumers worldwide are increasingly trying to include plant ingredients in their diet.
- 1 out of 3 condiment consumers in the U.S. aged 16 to 24 stated that they prefer organic ingredients.
- 35% of sauce and/or marinade consumers in the U.S. are chasing healthier choices.
- 58% of U.S. consumers eating plant-based proteins more often declare that it is healthier than consuming meat.

Make Sure Your Product is Labeled Appropriately
According to the FDA, food items that are canned, packaged, baked goods or seafood must be labeled with the appropriate information. This information includes but is not limited to: country of origin, nutrition information and ingredient information. Depending on the size of your product and product packaging, the FDA has issued multiple formats that are permissible for use for labeling.
Businesses that average over $10 million in annual sales were required to make their nutrition facts labels comply with new U.S. Food and Drug Administration (FDA) labeling rules by January 1, 2020.As of January 1, 2021, all other food businesses are required to update their labels. FDA’s new rules mandate significant changes to the Nutrition Facts Chart format, serving sizes, daily values, and more. For more information and guideline on new rules of the FDA and how to label your product, visit the link below: https://www.registrarcorp.com/fda-food/labeling/?lead_source=Google%20Ad

In the US, the FDA does not regulate the use of the term “organic” on food labels. The USDA requirements for products that are labeled with the term "organic" are separate from the laws that the FDA enforces. Moreover, food products that are ordinarily under the FDA's jurisdiction and that are labeled with organic claims must comply with both the USDA NOP regulations for the organic claim and the FDA regulations for food labeling and safety.

The National Organic Program (NOP), part of USDA’s Agricultural Marketing Service (AMS), establishes international organic import and export policies to facilitate trade and to expand market opportunities for certified organic farms and businesses around the world.

Imported organic products must be certified to one of the following standards to be sold in the U.S.:

• The USDA organic regulations — USDA authorizes organizations around the world to certify farms and businesses to the USDA organic regulations.
• An authorized international standard — the U.S. has established trade partnerships with international countries.

The NOP is a federal regulatory program that develops and enforces consistent national standards for organically produced agricultural products sold in the U.S. The NOP also accredits third-party organizations to certify that farms and businesses meet the national organic standards. These certifiers and the USDA work together to enforce the standards, ensuring a level playing field for producers and protecting consumer confidence in the integrity of the USDA Organic Seal.

Certifiers are responsible for making sure that the USDA organic products meet all organic standards. There are five basic steps to organic certification:
1. The farm or business adopts organic practices, selects a USDA-accredited certifying agent, and submits an application and fees to the certifying agent.
2. The certifying agent reviews the application to verify that the practices comply with the USDA organic regulations.
3. An inspector conducts an on-site inspection of the applicant’s operation.
4. The certifying agent reviews the application and the inspector’s report to determine if the applicant complies with the USDA organic regulations.
5. The certifying agent issues an organic certificate. To maintain organic certification, your certified organic farm or business will go through an annual review and inspection process. If your operation is not located in the U.S., see our International Trade page to learn more about your options for organic certification

On August 2, 2013, FDA issued a final rule defining “gluten-free” for food labeling, which is helping consumers, especially those living with celiac disease, be confident that items labeled “gluten-free” meet a defined standard for gluten content. “Gluten-free” is a voluntary claim that can be used by food manufacturers on food labels if they meet all the requirements of the regulations.
On August 12, 2020, the FDA issued a final rule on the gluten-free labeling of fermented or hydrolyzed foods. It covers foods such as yogurt, sauerkraut, pickles, cheese, green olives, FDA-regulated beers and wines (e.g., generally those with less than 7 percent alcohol), and hydrolyzed plant proteins used to improve flavor or texture in processed foods such as soups, sauces, and seasonings. The rule does not change the definition of “gluten-free” but establishes compliance requirements for these hydrolyzed and fermented foods. It also includes a discussion of how FDA will verify compliance for distilled foods such as vinegar.
For more information and guidance, please check https://www.fda.gov/food/food-labeling-nutrition/gluten-free-labeling-foods.

Islamic dietary laws (Halal) propose specific restrictions on diets. If you want to focus on the Islamic ethnic niche markets, consider implementing Halal certification schemes.

The Vegan has not been formally defined by the FDA, USDA or any other official U.S. agency. However, the vegan community has clearly defined and explained the term, which means a product that doesn’t include any ingredients of animal origin, including milk, eggs, honey, gelatin, meat, poultry and fish . There are multiple certification programs that help you gain the consumer trust such as Vegan.org in the U.S.
https://vegan.org/certification/