Foreign Supplier Verification Program (FSVP)

The FSVP importer, generally the US owner or consignee at entry, must analyze hazards for each food, evaluate and approve each foreign supplier, perform verification such as audits, sampling or record review, take corrective action, and keep records for two years. The importer must be identified by name, email and DUNS number in the CBP entry filing. Compliance dates began in May 2017. Very small importers and some foods have modified requirements. Violations can lead to refused entry and import alerts.

FSVP decides who is legally responsible when imported food comes into the US, and e-commerce brands are often surprised to learn it is them. A brand that imports supplements, snacks or coffee and sells them online is usually the FSVP importer even if a 3PL receives the goods. For example, a direct-to-consumer brand importing matcha from Japan must have a written FSVP for that supplier and appear as FSVP importer in the customs entry, or FDA can hold the shipment at the port.

• Importer of RecordIORParty legally responsible for an import
• Customs BrokerLicensed filer of US customs entries

• Food Safety Modernization Act (FSMA)2011 · 2011 law shifting FDA food safety to prevention
• Bioterrorism Act of 20022002 · Law creating FDA food registration and prior notice
• Federal Food, Drug, and Cosmetic Act (FD&C Act)1938 · Core US law on food, drugs, devices and cosmetics

1. FDA: FSMA Final Rule on Foreign Supplier Verification Programs fda.gov
2. eCFR: 21 CFR Part 1, Subpart L ecfr.gov