EU adds mandatory antimicrobial attestation to US shellfish import certificate
US shellfish exporters and certifiers must move to the EU's new import certificate carrying a mandatory antimicrobial-use attestation
Change
On 11 June 2026 the European Commission adopted Implementing Regulation (EU) 2026/1305, amending Implementing Regulation (EU) 2020/1641 to replace the model import certificate for US bivalve molluscs, echinoderms, tunicates and marine gastropods for human consumption, inserting a mandatory antimicrobial-use attestation under Delegated Regulation (EU) 2023/905, effective 20 days after publication with a transitional period to 3 December 2026.
Why it matters
The replacement certificate (model US-LBM-HC) adds Part II.2, an attestation that the aquaculture animals received no antimicrobial medicinal products for growth promotion or yield increase and none of the antimicrobials reserved for human medicine under Implementing Regulation (EU) 2022/1255, and that the products originate from a third country or region listed in Implementing Regulation (EU) 2024/2598. Old-model certificates remain usable for entry until 3 December 2026 if issued no later than 3 September 2026, and the antimicrobial attestation applies to consignments entering the Union from 3 September 2026. The certificate also updates references, notes and structural elements. The Regulation is binding and directly applicable.
Implications
- — US exporters and certifying officers of bivalve molluscs, echinoderms, tunicates and marine gastropods to the EU must adopt the replacement model certificate (US-LBM-HC) and complete the Part II.2 antimicrobial-use attestation — for consignments entering the Union from 3 September 2026, a certificate without the attestation is not valid for entry.
- — EU importers and border-control posts clearing these US consignments must accept old-model certificates only where issued no later than 3 September 2026 and used for entry by 3 December 2026 — certificates outside those dates must be rejected in favour of the new model.
- — US producers relying on foreign-sourced or on-land aquaculture shellfish material must confirm the source third country or region is listed in Implementing Regulation (EU) 2024/2598 before certifying, as the attestation ties eligibility to that listing.
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