NCC recently filed comments to USDA’s Food Safety and Inspection Service (FSIS) outlining the industry’s concerns regarding the new standard. Given the labeling and trade concerns, NCC requested further information and engagement with the industry before the new guidance is implemented.


On January 9, 2001, FSIS published its final rule on retained water, setting limits for the amount of water retained in a single-ingredient raw meat and poultry product after it is washed and chilled. In 2015, these regulations were amended to include fish, but the math and basis for the calculations were not changed. For the past 23 years, the calculations for determining the maximum percentage of retained water in a raw product have remained consistent and correct. It has helped consumers know how much water is in a packaged product and provided that same information to our trading partners.

NCC’s Comments

“Given the significant concerns and potential implications, the industry is unable to fully comment on the Revised Guideline and related formula change without additional information from the Agency regarding the basis for the Revised Guideline and an explanation for the development of the new formula,” NCC’s comments said. “Industry respectfully asks FSIS to provide this information and further engage with industry to assess the claimed new science behind the Revised Guideline prior to implementing any changes.”

“We respectfully ask that FSIS continue to engage with industry to resolve the numerous issues and concerns discussed above and provide clarification on the need for such change. The financial burden on industry [will be] significant,” NCC’s comments conclude. “Further, these changes may not only negatively impact NCC member companies, but also FSIS, and could spur distrust from consumers, customers, and potentially our trading partners. ”

NCC’s comments outlined numerous concerns, which can be found here.