An Equal Opportunity Provider and Employer

Agricultural

Marketing

Service 

Federal Grain Inspection 

Service

Field Management 

Division 

1400 Independence Ave. 

SW, Stop 3630

Washington, D.C. 20250

Voice (202) 720-0228

Fax (202) 690-3951

Hotline 1-800-998-3447

Reference #263 September 25, 2015

TO: FGIS POLICY BULLETIN BOARD

FROM: Anthony Goodeman, Acting Director 

 Field Management Division 

SUBJECT: Country of Destination on 921-2 for Cargo Transloading in 

 Canada

ORIGINATING OFFICE: Policies, Procedures, and Market Analysis Branch

1. PURPOSE

This memorandum clarifies the policy for information entered in Box 

7 of FGIS Form 921-2, pertaining to carriers shipped from the United 

States and transloaded in Canada to carriers bound for foreign 

nations. 

2. BACKGROUND

A situation regarding an elevator company loading a graded 

commodity into railcars bound for Canada prompts this bulletin. 

Upon arrival in Canada, the graded commodity was transloaded into 

containers which the elevator company said were bound for Indonesia. 

The Official Agency (OA) entered Canada in Box 7 (Country of 

Destination), of FGIS Form 921-2, whereas the elevator company 

wanted Indonesia entered in Box 7. The instructions for Box 7 state 

that information from the load order is to be entered. APHIS-PPQ was 

consulted as to what is the proper Country of Destination to enter. This 

policy bulletin confirms the correct information to enter into Box 7, in 

Question and Answer style.

3. POLICY

Question: Can Box 7 be left blank, and let the shipper inform the local 

APHIS officer of the foreign destination when the 921-2 is exchanged 

for the Phytosanitary certificate?

Answer: No.
Page 2

Question: Is it permissible to enter a foreign nation in Box 7 of a 

921-2 issued on a railcar, wherein the commodity is transloaded to a 

different carrier (motor vessel, ocean going barge, or container) bound 

for the listed foreign nation?

Answer: It depends on whether the commodity is transiting through 

Canada, or enters commerce in Canada. Two scenarios explain the 

difference:

Scenario 1: Transiting Canada, meaning the commodity does 

not enter Canadian commerce. This is determined by whether the 

commodity requires clearance through Canadian Customs. If the 

commodity does not require Canadian Customs clearance, it is 

considered to be transiting Canada and therefore acceptable to 

show the requested foreign nation as the Country of Destination.

Scenario 2: Not transiting Canada, meaning the commodity 

does enter Canadian commerce. This is defined as the 

commodity requiring clearance through Canadian Customs. If 

the commodity does require Canadian Customs clearance, it is 

considered to enter Canadian commerce, therefore Canada must 

be entered as the Country of Destination.

It is the responsibility of the applicant for service (e.g. shipper) to 

inform the Official Service Provider whether the commodity requires 

Canadian Customs clearance. Official personnel are not required to 

make this determination.

The reverse side of Form 921-2 has space for Additional Remarks 

wherein the Official Service Provider may enter a remark such as 

“Applicant states the commodity is destined for (ultimate Country of 

Destination).”

4. FILING INSTRUCTIONS

File a copy of this notice with FGIS Directive 9180.35 Phytosanitary 

Inspection. Field office managers must ensure that a copy of this 

notice is provided to official agencies operating within their circuit.

5. QUESTIONS 

Direct questions regarding this policy to 

AMS - FGIS Policies Procedures Market Analysis Branch.