Foreign Supplier Verification Program (FSVP)

Foreign Supplier Verification Program (FSVP)
FSMA Foreign Supplier Verification Program

Foreign Supplier Verification Program (FSVP)

The Foreign Supplier Verification Program (FSVP) is a risk-based, written compliance program established under the FDA Food Safety Modernization Act (FSMA) for importers who meet the FSVP definition in 21 CFR Part 1, Subpart L. The FSVP importer generally is the U.S. owner or consignee of the food at the time of entry; when there is no U.S. owner or consignee, a U.S. agent or representative of the foreign owner or consignee may serve as the FSVP importer with signed consent. A compliant FSVP addresses hazard analysis, foreign supplier evaluation, supplier verification, corrective actions, importer identification, and inspection-ready records for the foods and suppliers covered by the program. Non-compliance can lead to FDA enforcement, shipment refusal, or Detention Without Physical Examination (DWPE).

Foreign Supplier Verification Program (FSVP) Quick Facts
Who Needs It FSVP importer: U.S. owner/consignee, or qualifying U.S. agent/representative
Governing Regulation 21 CFR Part 1, Subpart L (FSMA §301)
Core Requirement Written hazard analysis + supplier verification, per supplier & per product
Plan Scope FSVP documentation must address each imported food and foreign supplier
Records Availability Required records must be available promptly; English translations provided within a reasonable time if FDA requests them
Verification Confirmation DUNS number + FSVP importer identity on every line entry via ACE
Review Cycle Reanalysis at least every 3 years (or sooner upon material change)
Penalty for Non-Compliance Shipment refusal at port, Import Alert, DWPE, FDA Form 483, and civil enforcement under Section 301 of the FD&C Act

Businesses that meet FDA’s definition of an FSVP importer must comply with the Foreign Supplier Verification Program rule unless an exemption or modified requirement applies. FDA Registration Assistance develops and manages custom FSVP programs to keep your records inspection-ready.

Custom Pricing Tailored to Your Products, Suppliers, Verification Needs & Support Scope
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Clients Worldwide
135+
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Years Experience
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FSMA-Compliant FSVP Plans
Plans Ready in 7–10 Business Days
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Ongoing FSVP Maintenance

Your Required Foreign Supplier Verification Program (FSVP) Plan for Importing Food into the U.S.

The Foreign Supplier Verification Program (FSVP) was established under the Food Safety Modernization Act (FSMA), with initial compliance dates beginning in May 2017. Businesses that meet FDA’s definition of an FSVP importer must maintain a compliant program for the imported foods and foreign suppliers they are responsible for, unless an exemption or modified requirement applies.

Foreign Supplier Verification Program (FSVP) requirements are codified at 21 CFR Part 1, Subpart L. Importers must perform risk-based supplier verification activities, maintain written hazard analyses, and be prepared for FDA inspection at any time. Failure to maintain a compliant FSVP plan can result in import alerts, shipment refusals, and FDA enforcement action. FDA Registration Assistance delivers a fully compliant FSVP plan in 7–10 business days.

  • Required for covered FSVP importers of food and beverages under FSMA
  • Separate FSVP plan required per supplier and per product
  • Must include hazard analysis, supplier evaluation, and verification activities
  • FSVP records must be available for FDA inspection at any time

Foreign Supplier Verification Program (FSVP) Requirements & Obligations

U.S. importers must perform risk-based supplier verification activities. Here's what FSVP compliance requires in practice.

Requirement 01

Who Must Have an FSVP

The U.S. owner or consignee of food at the time of entry — or, if there is none, the U.S. agent or representative of the foreign owner or consignee that has agreed in writing to serve as the FSVP importer.

  • U.S. importers of human food & beverages
  • Importers of dietary supplements & ingredients
  • Importers of animal food & pet food
  • U.S. agents acting for foreign owners at entry
Requirement 02

FSVP Plan Obligations

Each FSVP must be written, documented, and available for FDA inspection. Plans must be maintained per supplier and per product.

  • Conduct hazard analysis for each imported food
  • Evaluate foreign supplier performance and risk
  • Select risk-appropriate verification activities; document alternatives where annual onsite auditing would otherwise apply
  • Review and update FSVP at least every 3 years

Foreign Supplier Verification Program (FSVP) Compliance By the Numbers

Helping U.S. importers stay compliant with inspection-ready FSVP plans and expert ongoing support.

135+
Countries
Foreign supplier countries covered
7–10
Days
FSVP plans delivered in 7–10 business days
15+
Years Experience
FDA compliance expertise
1,000+
Clients Served
Importers compliant with FDA Registration Assistance

Get Your Foreign Supplier Verification Program (FSVP) Plan in 4 Simple Steps

Our streamlined process makes FSVP plan creation fast, thorough, and FDA inspection-ready.

1

Submit Your Importer Information

Complete our intake form with your company details, product categories, and foreign supplier information.

2

We Build Your FSVP Plan

Our FSVP experts conduct a hazard analysis, evaluate your supplier risk, and prepare a fully documented FSVP plan that meets FDA standards.

3

Plan Delivered & Reviewed

Your completed FSVP plan is delivered within 7–10 business days for your review. We walk you through every component and answer any questions.

4

Ongoing FSVP Maintenance

We monitor supplier changes, conduct required 3-year reviews, and update your FSVP plan as needed — stay inspection-ready every year with FDA Registration Assistance.

Core Responsibilities of a Compliant Foreign Supplier Verification Program (FSVP) Importer

21 CFR Part 1, Subpart L imposes defined duties on the Foreign Supplier Verification Program (FSVP) importer. Certain activities may be performed by qualified third parties, but the FSVP importer must review and assess the relevant documentation and remains responsible for compliance with the rule.

01

Develop a Written FSVP for Every Supplier–Product Pair

Maintain a unique, written FSVP for each foreign supplier and each food product (21 CFR 1.502). The plan must be in English and signed by a qualified individual.

02

Conduct a Hazard Analysis for Each Imported Food

Identify known or reasonably foreseeable biological, chemical (including radiological), and physical hazards under 21 CFR 1.504, and determine which require a control.

03

Evaluate & Approve Foreign Suppliers

Assess the supplier's food safety performance, applicable FDA warning letters, audit history, and ability to control identified hazards before approval (21 CFR 1.505).

04

Perform Risk-Appropriate Verification Activities

Select and conduct risk-appropriate verification activities under 21 CFR 1.506, such as onsite audits, sampling and testing, or review of supplier food-safety records. For SAHCODHA hazards controlled by the foreign supplier, initial and annual onsite auditing is generally required unless a documented written determination supports other activities and/or less frequent auditing.

05

Identify the FSVP Importer on Every Entry

Ensure the FSVP importer's name, email, and DUNS number are transmitted on every line entry to CBP's ACE system at the time of importation (21 CFR 1.509).

06

Maintain Inspection-Ready Records

Maintain FSVP records for the retention periods required by 21 CFR 1.510 and make them available promptly to FDA upon request. If records are maintained in another language, an English translation must be provided within a reasonable time when FDA requests it. Electronic records are permitted when the rule’s requirements are met.

07

Take Corrective Action When Problems Arise

Investigate, document, and act on any adulteration, misbranding, or supplier non-conformance discovered through verification or complaints (21 CFR 1.508).

08

Reanalyze the FSVP Every 3 Years (or Sooner)

Reanalyze the entire FSVP every three years, or immediately upon new hazard information, supplier change, or evidence the existing controls are inadequate (21 CFR 1.505(c)).

Foreign Supplier Verification Program (FSVP) Importer vs. U.S. Agent — They Are Not the Same Role

Many food businesses use these terms interchangeably. The Foreign Supplier Verification Program (FSVP) Importer and the U.S. Agent are two completely different FDA designations with different legal duties, different governing rules, and different consequences for non-compliance.

AttributeFSVP ImporterU.S. Agent (Food Facility)
Who Designates ItDesignated at the time of U.S. entry by the owner/consignee, or by agreementDesignated by a foreign food facility during FDA registration
Who It RepresentsRepresents the imported food shipment at the borderRepresents the foreign facility itself to the FDA
Required ByU.S. importers of food, beverages, supplements & animal foodForeign food facilities required to register with the FDA
Governing Regulation21 CFR Part 1, Subpart L (FSVP rule)21 CFR Part 1, Subpart H (Food Facility Registration)
Primary FunctionVerify foreign suppliers, conduct hazard analysis, maintain FSVP recordsServe as 24/7 communication link between the foreign facility and the FDA
Required ForFood offered for U.S. entry when the FSVP rule appliesEvery registered foreign food facility (renewed every two years)

The Foreign Supplier Verification Program (FSVP) Importer is the U.S. party legally accountable for verifying that a foreign supplier's food is safe and properly labeled before it enters the country. The U.S. Agent is the U.S.-based point of contact that a foreign food facility lists with the FDA when it registers under FSMA — its role is to receive FDA communications and be available 24/7. These are separate designations governed by different parts of 21 CFR Part 1. A foreign manufacturer needs a U.S. Agent to keep its FDA registration active. A U.S. importer of that manufacturer's food needs an FSVP to legally bring the food into the country. In practice, most businesses involved in U.S. food importation need both — one for the foreign supplier's facility registration and one for the U.S. importer's FSVP obligation. FDA Registration Assistance can serve in both capacities.

DIY Foreign Supplier Verification Program (FSVP) vs. Professional FSVP Service

The Foreign Supplier Verification Program (FSVP) can be self-managed in theory, but the regulation is dense and the cost of getting it wrong is high. Here is how the two approaches compare in practice.

Most importers choose a professional Foreign Supplier Verification Program (FSVP) service because the regulatory cost of a single mistake — one missed verification activity, one outdated hazard analysis, one unanswered FDA letter — can mean shipments held at the port, Import Alerts, and lost retailer or Amazon listings. A dedicated FSVP partner like FDA Registration Assistance turns FSVP from an internal compliance burden into a managed, inspection-ready system that scales with your supplier base.

Using a Friend as Your Foreign Supplier Verification Program (FSVP) Importer vs. FDA Registration Assistance

There is no government filing fee for the Foreign Supplier Verification Program (FSVP). So why not just ask a U.S.-based friend, customs broker contact, or family member to list as the FSVP importer? Here is the honest comparison.

The "free friend" route can create serious risk if the person serving as the FSVP importer does not understand the legal responsibilities they are accepting. Required FSVP records must be made available promptly to FDA upon request, and English translations of records maintained in another language must be provided within a reasonable time when FDA requests them. A professional Foreign Supplier Verification Program (FSVP) service replaces guesswork with a documented, inspection-ready compliance file.

Foreign Supplier Verification Program (FSVP) Glossary: Terms Every Importer Should Know

The Foreign Supplier Verification Program (FSVP), FSMA, and 21 CFR Part 1 use specialized terms that have precise legal meanings. Here are the most important ones you'll see on FDA forms and inspection reports.

FSVP (Foreign Supplier Verification Program) The written program required under 21 CFR Part 1, Subpart L for U.S. importers of food, beverages, and supplements.
FSMA Food Safety Modernization Act (Public Law 111-353, signed January 4, 2011). The federal law that created FSVP and shifted import food safety responsibility to U.S. importers.
FSVP Importer The U.S. owner or consignee of the food at entry; if there is none, the U.S. agent or representative of the foreign owner. Defined at 21 CFR 1.500.
Qualified Individual (QI) A person with the education, training, or experience to develop and perform FSVP activities. The QI must sign and date the FSVP plan and verification records.
Hazard Analysis A written evaluation of biological, chemical (including radiological), and physical hazards reasonably foreseeable in a food, and whether each requires a control (21 CFR 1.504).
SAHCODHA "Serious Adverse Health Consequences or Death to Humans or Animals." When such a hazard is controlled by the foreign supplier, initial and annual onsite auditing is generally required unless the importer documents an adequate alternative verification determination.
DUNS Number A 9-digit Unique Facility Identifier issued by Dun & Bradstreet. The FDA recognizes the DUNS as the acceptable UFI for identifying the FSVP importer on each line entry.
ACE Automated Commercial Environment. The CBP electronic system through which the FSVP importer's identity and DUNS number are transmitted to the FDA at the time of import.
Supplier Verification Activity Verification activities under 21 CFR 1.506 may include onsite auditing, sampling and testing, review of relevant supplier food-safety records, or other appropriate procedures based on the food and supplier risk.
Import Alert An FDA enforcement tool that flags specific products, manufacturers, or countries for Detention Without Physical Examination (DWPE) at the port until the importer proves compliance.
Form FDA 483 A written list of observations issued by an FDA inspector at the conclusion of an FSVP or other facility inspection, identifying conditions that may violate the FD&C Act.
Reanalysis A full re-evaluation of the FSVP, required at least every three years or whenever new hazard information, a supplier change, or evidence of inadequate control becomes available (21 CFR 1.505(c)).

Common Foreign Supplier Verification Program (FSVP) Failures That Trigger FDA Action

These are the most frequent Foreign Supplier Verification Program (FSVP) failure modes cited on FDA Form 483 observations and seen behind shipment refusals and Import Alerts. Every one of them is avoidable with a properly maintained FSVP.

No Written FSVP at the Time of Entry

FDA reviews the importer’s FSVP and finds missing required hazard analysis, supplier evaluation, or verification documentation — a serious compliance deficiency that can result in FDA observations and further enforcement.

Missing or Incorrect DUNS Number on Entry

The FSVP importer field on the ACE entry is blank, set to "UNK," or pointing to an unverifiable DUNS — leading to FDA hold messages and shipment delays at the port.

Missing Required SAHCODHA Verification Documentation

When a hazard controlled by the foreign supplier presents a reasonable probability of serious adverse health consequences or death, FDA generally requires an onsite audit before initial importation and at least annually thereafter unless the importer documents why other verification activities and/or less frequent auditing provide adequate assurance.

Records Not Available Promptly or Translation Delayed

Required FSVP records must be made available promptly to FDA upon request. If records are maintained in another language, FDA can request an English translation, which must be provided within a reasonable time. Missing records or delayed translations can lead to inspection findings.

Missed 3-Year Reanalysis

Importers forget to reanalyze the FSVP after three years, after switching suppliers, or after a new hazard emerges. Outdated FSVPs are treated by the FDA as no FSVP at all.

One FSVP Covering Multiple Products or Suppliers

A single generic FSVP is used across unrelated products or several different suppliers. FSVP requires a written program for each supplier–product combination.

No Corrective Action When Issues Arise

Out-of-spec testing, supplier warning letters, or recall notices are received and ignored. FDA expects documented corrective action under 21 CFR 1.508 — silence is a violation.

FSVP Plan Never Signed by a Qualified Individual

The FSVP exists on paper but no Qualified Individual (QI) is identified or has signed off on the hazard analysis. Unsigned plans are routinely cited as non-compliant.

Complete FDA Compliance Solutions

We offer a full range of FDA registration and compliance services to help importers and food facilities succeed in the U.S. market.

Foreign Food Facility Registration

Register your foreign food facility with the FDA — required for all facilities exporting food to the U.S.

Domestic Food Facility Registration

Register your U.S.-based food facility with the FDA under the Food Safety Modernization Act (FSMA).

FSVP Compliance

Ensure your U.S. importer meets FDA's Foreign Supplier Verification Program requirements.

Annual Registration Renewal

FDA food facility registrations must be renewed every two years. We handle the renewal process for you.

Shipment Compliance Consulting

Expert guidance on FDA import requirements, shipment monitoring, and avoiding costly import alerts.

HACCP Plan Development

Develop and review your HACCP food safety plan to meet FDA requirements and protect your facility's compliance status.

Label & Ingredient Review

Ensure your product labels and ingredient declarations meet all FDA labeling requirements before entering the U.S. market.

Import Alert Assistance

Get expert help resolving FDA import alerts and detentions to restore your products' ability to enter the U.S.

DUNS Request Assistance

We help you obtain your DUNS number, required for FDA food facility registration and federal business activities.

Prior Notice Filing

Submit FDA Prior Notice for food shipments entering the U.S. — required at least 2 hours before arrival at port.

FSVP for Amazon Sellers

Specialized FSVP compliance for Amazon sellers importing food products — meet FDA requirements and keep your listings active.

Food Canning Establishment (FCE-SID)

Register your acidified or thermally processed low-acid food facility with the FDA as required for canned and shelf-stable products.

Frequently Asked Questions

Everything you need to know about the FDA Foreign Supplier Verification Program (FSVP) compliance.

A Foreign Supplier Verification Program (FSVP) plan is a written document required by the FDA that demonstrates how a U.S. importer verifies that their foreign suppliers produce food that meets U.S. safety and labeling standards. It must include a hazard analysis, supplier risk evaluation, and documented verification activities.

An FSVP importer generally is the U.S. owner or consignee of food offered for import into the United States. If there is no U.S. owner or consignee at the time of entry, the FSVP importer is the U.S. agent or representative of the foreign owner or consignee, as confirmed in a signed statement of consent. FSVP applies unless an exemption or modified requirement applies.

FSVP requirements must be addressed for each imported food and each applicable foreign supplier. Documentation can be organized within a managed FSVP system, but the hazard analysis, supplier evaluation, and verification decisions must cover the specific food and supplier relationship. FDA Registration Assistance can manage plans for multiple products and suppliers.

FDA Registration Assistance can typically prepare a compliant FSVP plan within 7–10 business days, depending on product complexity and supplier documentation. We will confirm your timeline during the intake process.

Failure to maintain a compliant Foreign Supplier Verification Program (FSVP) plan can result in FDA Form 483 observations, import alerts, shipment detention or refusal (DWPE), and civil or regulatory enforcement action. Having a properly documented FSVP ensures your products can enter the U.S. without disruption.

FSVP compliance pricing is custom based on your specific needs — including the number of products, suppliers, and level of ongoing support required. We also offer U.S. Agent services as part of our FSVP program. Contact FDA Registration Assistance for a custom quote tailored to your business.

Yes. “FSVP Agent” is commonly used as a service description, but FDA legally defines the responsible role as the FSVP importer. FDA Registration Assistance can manage FSVP documentation and verification support and can discuss serving as the U.S. agent or representative FSVP importer where the regulation permits. The applicable legal structure depends on who owns or has purchased the food at the time of entry.

FDA Registration Assistance will guide you through all required information during our intake process. Typically this includes your company details, product descriptions, foreign supplier names and locations, and any existing food safety documentation.

FSVP plans must be reviewed and updated at least every three years, or sooner when there are changes in suppliers, processes, or hazard information. FDA Registration Assistance manages your FSVP maintenance every year so you are always compliant and never caught off guard during an inspection.

FSVP is established under Section 301 of the Food Safety Modernization Act (FSMA) and codified at 21 CFR Part 1, Subpart L. The rule went into effect on January 26, 2016, with compliance dates beginning in May 2017.

Yes. Certain categories are exempt or have modified requirements, including juice and fish products subject to HACCP regulations, food for research or personal consumption, alcoholic beverages, and food from countries with an equivalent food safety system. Contact FDA Registration Assistance for a compliance review if you believe an exemption may apply.

FSVP importers must provide a Unique Facility Identifier (UFI) — specifically a DUNS number — for each line entry of food offered for importation. The FDA recognizes the DUNS number (issued by Dun & Bradstreet) as the acceptable UFI. FDA Registration Assistance can assist with DUNS number requests as part of our FSVP services.

Verification activities may include onsite audits, sampling and testing, review of the supplier’s relevant food safety records, or other appropriate activities. When a hazard controlled by the foreign supplier is a SAHCODHA hazard, an onsite audit before initial importation and at least annually thereafter is generally required unless the importer makes and documents an adequate written determination that other activities and/or less frequent auditing provide adequate assurance. FDA Registration Assistance helps determine the appropriate activities for your specific supplier and product risk profile.

Yes, with some variations. Importers of dietary supplement ingredients who verify compliance with CGMP specifications may be exempt from most standard FSVP requirements. Importers of finished dietary supplement products must comply with most FSVP requirements, with verification activities focused on CGMP compliance.

A hazard analysis identifies and evaluates known or reasonably foreseeable biological, chemical, and physical hazards associated with the imported food. It assesses the probability and severity of harm if controls are not in place. FDA Registration Assistance conducts a thorough hazard analysis as part of every FSVP plan we develop.

Yes. FDA Registration Assistance can provide managed FSVP support from initial plan development and hazard analysis through supplier verification documentation, corrective-action support, ongoing maintenance, and required reanalysis. Where the regulatory conditions are met, we can also discuss U.S. agent or representative FSVP importer support. Contact us for a scope tailored to your import structure.

FDA Registration Assistance provides Foreign Supplier Verification Program (FSVP) services at custom pricing because each importer’s circumstances are different. Pricing can depend on the number and type of imported foods, foreign suppliers, hazard profile, verification activities, shipment scope, records already available, and the level of ongoing support required. Your proposal will clearly identify what is included. Many importers also need Foreign Food Facility Registration for their foreign supplier. Contact us for a tailored quote based on your actual import structure.

A qualifying U.S. person or entity can serve as the FSVP importer when the conditions in 21 CFR 1.500 are met. If there is no U.S. owner or consignee, a U.S. agent or representative of the foreign owner or consignee can serve as the FSVP importer when confirmed in a signed statement of consent. The role carries substantive compliance duties, so using a friend or unrelated party who is not prepared to manage hazard analysis, supplier evaluation, verification activities, records, and FDA inquiries can create significant risk. Professional managed FSVP support helps keep the required documentation organized and inspection-ready.

If the party serving as the FSVP importer does not respond to FDA or cannot provide the required FSVP records, FDA may determine that the importer is not in compliance with the rule. That can lead to enforcement action, including refusal of admission and potential Detention Without Physical Examination (DWPE). Required FSVP records must be made available promptly to FDA upon request, and requested English translations must be provided within a reasonable time. The FSVP importer remains responsible for compliance. FDA Registration Assistance provides responsive managed support during U.S. business hours and helps organize FDA records responses.

To change your Foreign Supplier Verification Program (FSVP) Agent on an existing registration, you must update the FSVP importer information in your written FSVP records and ensure the new agent's name, address, email, and DUNS number are transmitted on every subsequent line entry through CBP's ACE system at the time of import. There is no separate FDA filing form for FSVP — the change takes effect at the next entry filing. FDA Registration Assistance handles the entire transition: we coordinate with your customs broker, update all required entry data, sign the FSVP as the new Qualified Individual, and ensure there is no gap in coverage that could trigger an FDA hold message.

FSVP has exemptions for food imported for research or evaluation and for food imported for personal consumption, but each exemption depends on meeting the conditions in 21 CFR 1.501. A trade-show or sample shipment is not automatically exempt simply because it is small or not sold. The intended use, quantity, labeling, distribution, and entry documentation should be reviewed before relying on an exemption.

Yes, if you meet FDA’s definition of the FSVP importer for the imported food and no exemption applies. Selling through Amazon FBA, Shopify, eBay, Walmart Marketplace, or another e-commerce platform does not remove FSVP obligations. Our FSVP for Amazon Sellers service is designed for businesses importing food for e-commerce sale.

No for cosmetics — the Foreign Supplier Verification Program (FSVP) applies only to food. However, dietary supplements are regulated as food under FSMA and do require FSVP coverage with modified verification activities focused on CGMP compliance under 21 CFR Part 111. Cosmetics fall under MoCRA (Modernization of Cosmetics Regulation Act), a separate framework. Animal feed, pet food, and infant formula are food and therefore covered by FSVP.

FSVP documentation must address each imported food and the applicable foreign supplier. Multiple products from the same supplier can be organized within one managed FSVP system, but the required hazard analysis, supplier evaluation, and verification decisions must adequately cover each food and supplier relationship. FDA Registration Assistance organizes multi-product, multi-supplier programs so the required documentation remains clear and inspection-ready.

The Foreign Supplier Verification Program (FSVP) is a U.S. importer responsibility — it verifies that the foreign supplier produces safe food. Foreign Food Facility Registration is a foreign manufacturer responsibility under 21 CFR Part 1, Subpart H — it lists the facility with the FDA and is renewed every two years. Importers usually need FSVP; their foreign suppliers usually need Foreign Food Facility Registration. Many businesses need both registrations active at the same time to legally ship food into the United States.

No. The Foreign Supplier Verification Program (FSVP) importer must be the U.S. owner or consignee of the food at the time of entry or, when there is no U.S. owner or consignee, the U.S. agent or representative of the foreign owner or consignee as confirmed in a signed statement of consent under 21 CFR 1.500. A foreign entity by itself cannot be the FSVP importer. FDA Registration Assistance can discuss U.S. agent or representative options when this structure applies.

The FDA verifies Foreign Supplier Verification Program (FSVP) compliance in three ways: (1) scheduled and unannounced FSVP inspections at the importer's U.S. business address, where inspectors review hazard analyses, supplier records, and verification activities in person; (2) electronic records requests under Section 414 of the FD&C Act, requiring the FSVP importer to make required records available promptly and, when requested, provide English translations within a reasonable time; and (3) review of the FSVP importer's DUNS number and contact information transmitted on each line entry through CBP's ACE system. Missing or invalid data on any of these channels can trigger an FDA hold.

If a U.S. brand owner is the U.S. owner or consignee of the food at the time of entry, it generally is the FSVP importer and must ensure the applicable FSVP requirements are met for the foreign manufacturer and imported food. A private-label or co-manufacturing agreement does not by itself eliminate FSVP obligations. The hazard analysis and verification activities should reflect the actual imported food and the foreign supplier involved.

The Foreign Supplier Verification Program (FSVP) importer must have a physical U.S. address — not a P.O. box — plus a U.S. phone number and email address that the FDA can use to schedule an inspection or request records. A virtual office or commercial mail receiving address is acceptable only if a responsible person can be reached at that address during U.S. business hours and required FSVP records can be produced promptly in response to an FDA request.

Repeated FSVP violations can lead to FDA Form 483 observations, Warning Letters, refusal of admission, or placement on an Import Alert such as IA 99-41. When an importer and food are subject to DWPE, affected entries may be detained without physical examination until the applicable FDA requirements are satisfied. FDA Registration Assistance can assist with FSVP remediation and, where appropriate, our Import Alert Assistance service.

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