Import Alert Guide
Import Alert 99-15 — Countrywide Processed Foods, Pesticides
A plain-language guide to FDA Import Alert 99-15, the countrywide alert allowing detention without physical examination of specified processed foods for illegal pesticide residues. What it covers, the charge, the Green List exemption model, and what testing evidence typically involves.
The Short Version
What Is Import Alert 99-15?
Import Alert 99-15 is a countrywide alert permitting FDA to detain, without physical examination, specified processed foods for illegal pesticide chemical residues. Unlike the firm-specific Import Alert 99-08, this one applies by origin: covered processed foods from a specified country are subject to detention unless the firm is on the alert's Green List. A residue is "illegal" when it lacks an established tolerance for that food, or exceeds the tolerance that exists, rendering the product adulterated.
- Alert Number
- 99-15
- Scope
- Countrywide — specified processed foods for pesticides, by country of origin
- Charge
- Adulteration — bears or contains a pesticide chemical residue (Section 402(a)(2)(B); refused under 801(a)(3))
- Mechanism
- Detention Without Physical Examination (DWPE), countrywide with Green List exemption
- Firm-Specific Counterpart
- Import Alert 99-08 (processed foods, specific firms)
- Official Text
- FDA Import Alert 99-15
The Background
Why This Alert Is Countrywide
Pesticides on food are regulated through tolerances — the maximum residue levels set for a given pesticide on a given food, codified in 40 CFR Part 180. When a processed food bears a residue without an established tolerance, or over the established tolerance, it is adulterated under U.S. law.
99-15 exists for situations where a pesticide-residue problem in a processed food is broad enough that FDA applies detention across a country's supply rather than to individual firms — for example, specified products such as preserved and salted duck eggs from Hong Kong or raisins from Turkey. Covered processed foods from the specified origin are presumed violative on arrival, and a firm demonstrates ongoing compliance by earning a place on the alert's Green List, which exempts its covered products from countrywide detention under this alert.
An important interaction: a firm may be exempt (Green-listed) under 99-15 for the countrywide pesticide, yet still be subject to firm-specific detention under Import Alert 99-08 for a different pesticide. When that happens, the 99-08 procedures apply for that residue. Reading both alerts against a firm's listings is essential.
The Evidence
What Per-Shipment Testing Typically Involves
To secure release of an individual detained shipment, the responsible party generally provides evidence that the specific product does not bear or contain unsafe pesticide chemical residues — commonly private laboratory analysis of a representative sample under documented custody.
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Representative Sampling
Samples are collected from the detained lot under a documented plan and chain of custody, sized to the residue screen and the laboratory's requirements for the processed product.
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Residue Analysis Against Tolerances
An independent laboratory screens for the pesticide residues at issue and evaluates results against the applicable tolerances. FDA weighs combined residues — including isomers, metabolites, and degradates listed in 40 CFR Part 180 — so the analysis must address the full residue picture, and any pesticides for which the firm is also subject to 99-08.
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Your Team Submits
Results and custody records are organized into a case file; you and your authorized parties submit to the FDA compliance office named on the notice. FDA may collect audit samples before deciding, and makes the final admissibility decision.
Check both alerts. Because a firm can be Green-listed under 99-15 yet still Red-listed under 99-08 for a different pesticide, the residue panel has to reflect every pesticide the firm is subject to across both alerts. The charges and listings define the scope. See our laboratory testing coordination guide.
Be Realistic
Green List & What This Alert Means in Practice
Honest limitations
- Countrywide means origin alone triggers detention. A firm can have a clean record and still see covered shipments detained until it reaches the Green List — that's the nature of a countrywide alert.
- Green List exemption is not release. Winning release of individual shipments does not put a firm on the Green List — future covered shipments are still detained until the exemption is granted.
- Two alerts can apply at once. Green List status under 99-15 does not clear a separate firm-specific listing under 99-08 for another pesticide.
- Green List is documentation-heavy. Exemption requires information to FDA's Division of Import Operations adequately demonstrating the conditions causing the violation were resolved, typically including documented preventive actions — testing evidence supports it but does not by itself accomplish it.
Related
Related Alerts & Guides
Processed Foods — Pesticides
The firm-specific counterpart to 99-15 — processed foods detained by firm rather than by origin.
Read the guide IA 99-05Raw Agricultural Products — Pesticides
The raw-commodity pesticide alert — same concern for unprocessed produce and grains.
Read the guide IndustryProcessed & Packaged Food Testing
Category overview: common detention reasons for processed foods and the testing they require.
View industriesProcessed Food Detained Under 99-15?
Bring Us the Notice — We'll Check Both Alerts
Send your FDA Notice of Action, the pesticide charge, and product and origin details. You'll get an honest, case-specific read on the residue panel — including any overlap with 99-08 — and what coordination can do, before any commitment.
Urgent detention matters receive priority intake review.
FDA Detention Sampling is an independent private company. We are not affiliated with, endorsed by, or part of the U.S. Food and Drug Administration. This guide is a plain-language summary of Import Alert 99-15; the official alert text published by FDA is authoritative and controls. Sampling, laboratory testing, documentation, and coordination services do not guarantee FDA release, admissibility, acceptance of laboratory results, removal from or exemption under any import alert, or any specific regulatory outcome. FDA makes the final admissibility decision.