The FDA’s Import Alert system is an important tool in the agency’s food safety toolbox.

While there are many Import Alerts in effect, covering a range of pharmaceuticals, devices, cosmetics and foods (both human and animal), today’s focus is on Import Alert 99-35: Detention Without Physical Examination Of Fresh Produce That Appears To Have Been Prepared, Packed Or Held Under Insanitary Conditions.

Some context

The FDA gives the following conditions under which a company’s produce may be added to this Import Alert:

Produce is vulnerable to contamination with pathogenic microorganisms if exposed to insanitary conditions during growing, harvesting, packing, holding, manufacturing, processing, or transportation. Multiple foodborne illness outbreaks have been linked to produce that was likely contaminated as a result of insanitary conditions during growing, harvesting, packing, holding, manufacturing, processing, or transportation. Produce is of special concern because in many instances it is consumed without further treatment to adequately destroy or remove pathogenic microorganisms.

FDA may document insanitary conditions that may have resulted in the contamination of produce with human pathogens during an inspection of an establishment that grows, harvests, packs, holds, manufactures, processes, or transports produce. FDA may also use analytical evidence or epidemiological and traceback evidence to establish that produce was grown, harvested, packed, held, manufactured, processed, or transported under insanitary conditions that may have resulted in contamination of the produce with human pathogens.

In order for a company’s produce to be removed from the detention list (known as the Red List), it “…should submit documentation to FDA demonstrating that the firm has resolved the conditions that gave rise to the appearance of adulteration so that the Agency will have confidence that future entries will be in compliance with the Act.”

A recent example

On July 6, 2026, the CDC posted a notice linking a multistate outbreak of 12 cases of E. coli O145 illnesses to GreenWise Organic Frozen Blueberries imported from Chile. The blueberries had been sold in Publix stores in multiple states.

Three days before the CDC went public with the outbreak notice, Frutas y Hortalizas del Sur S.A. (San Carlos, Chile) recalled the implicated batch of blueberries. On July 29, 2026, Publix expanded the company’s initial recall to include all lots of the GreenWise frozen blueberries.

The connection between the product and the outbreak cases was made based on epidemiological and traceback information only. Neither the CDC nor the FDA reported having found the outbreak strain in a sample of the blueberries.

On July 27th and 28th, the FDA added multiple frozen berry products from four Chilean suppliers to Import Alert 99-35. The entities named in the alert were: COMFRUT SA (Santiago, Chile), Comercial Fruticola S.A.(COMFRUT) (Santiago, Chile), Comfrut Curico (Maule, Chile) and Frutas y Hortalizas del Sur S.A. (Nuble, Chile).

Where is the Taylor Farms Import Alert?

Import Alert 99-35 specifies the following criteria, either of which can merit adding a company’s produce to the Red List. It is not necessary for both criteria to be met in order for a company to qualify for inclusion on the list.

1. Inspectional evidence demonstrating that produce has been grown, harvested, packed, held, manufactured, processed, or transported under insanitary conditions whereby it may have become contaminated with pathogens.
2. Epidemiological evidence, traceback evidence, and expert opinion.

There are thirteen countries (fourteen, if one includes US-based importers) represented on the Red List. One of the thirteen is Mexico.

There are 26 individual Mexican companies on the Red List, cited for pathogens ranging (alphabetically) from Cyclospora to Shigella.

The produce items listed for detention include papayas, peppers, herbs and spices, berries, and green onions.

Taylor Farms de Mexico is NOT one of those 26 companies. Iceberg lettuce (or any other variety of lettuce) is NOT one of the produce items.

Why is Taylor Farms de Mexico not on the Red List?

It can’t be because the outbreak is too small to be worthy of notice. Even using the CDC’s most recent outbreak notice (released on July 24, 2026), there are at least 1,947 confirmed Cyclospora outbreak cases in nine states, with 98 people hospitalized. In comparison, the outbreak linked to frozen blueberries comprises only 12 cases in two states.

It can’t be because the linkage is “only” based on epidemiological and traceback data. The E. coli O145 outbreak was linked to frozen blueberries based on the same level of data.

It can’t be because there hasn’t been enough time to add Taylor Farms de Mexico to the Red List. The two outbreaks have overlapping timelines.

In 2013, this company’s lettuce was linked to an outbreak of Cyclospora. It is evident that the investigation into the root cause of that 2013 outbreak was unsuccessful or incomplete. Otherwise, the same problem would not have reoccurred.

Taylor Farms de Mexico qualifies to be added to the Red List through epidemioloigical and traceback evidence linking its produce to a foodborne disease outbreak. It is also a repeat offender. A two-time loser.

The bottom line

The Import Alert system is designed to place the onus on foreign suppliers with a history of food-safety problems to prove their produce is safe BEFORE it is allowed into distribution in the United States.

Taylor Farms de Mexico has a troubled food-safety history and deserves to be added to the Red List for Import Alert 99-35 pronto.

Interested in learning more about food safety and the history of foodborne disease outbreaks and investigations?

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