In our December FSMA Club webinar, Trust, but Verify: Tips and Tools for Your Foreign Supplier Verification Program, Marc Sanchez, FDA Attorney, went into detail regarding FSMA's FSVP rule and broke down some of the confusion with a few examples you can find in our previous post.
“Does FSMA’s Foreign Supplier Verification Program apply to me?” This is probably one of the first questions to ask yourself regarding the Foreign Supplier Verification Program (FSVP). There can be a lot of different parties that might have hands on a shipment as it comes into the U.S., so how do you define who the importer is for the purpose of this rule?
The FDA’s Food Safety Modernization Act (FSMA) rule on Foreign Supplier Verification Programs (FSVP) for Importers of Food for Humans and Animals is now final, and compliance dates for some businesses begin in 18 months.
The FDA’s Foreign Supplier Verification Program (FSVP) provides greater oversight into the products coming into the U.S. to ensure that “importers would be required to perform certain risk-based activities to verify that food imported into the United States has been produced in a manner that provides the same level of public health protection as that required of domestic food producers.”
Generally, the FDA is asking who has financial stake to ensure the food coming in will be up to standards that the FDA expects. If you are the US owner or cosigning at the time of entry, you are the importer for purposes of this rule. If there is no owner or cosigner at the time of entry, then the FDA will look at the US agent or representative for the foreign owner of cosigner.
What are the 7 Components or Activities that Must Happen for a Successful Foreign Supplier Verification Program?