FSMA Update: Importing Food under the Foreign Supplier Verification Program

Potential hazards may include any biological, chemical or physical hazards related to the food which are reasonably likely to cause illness or injury

The FSVP rule first looks to the importer. An importer is the U.S. owner or consignee of a food offered for import into the U.S. If the importer is a food manufacturer otherwise subject to the preventive controls rules, no FSVP program is necessary because the hazard is identified and managed under their preventive controls processes. If the importer is not a U.S. manufacturer subject to the preventive controls rules and does not meet one of the other enumerated exceptions, the importer must create and implement an FSVP.An FSVP requires the importer to vouch for the foreign supplier of an article of food. The foreign supplier is generally the foreign entity that manufacturers and processes the food being exported to the United States. If a foreign food passes through an intermediary packer, holder or re-labeler, the original manufacturer is still deemed to be the foreign supplier.
  
An importer’s FSVP must be a written plan which provides for three separate processes: 1) an evaluation of the potential hazards of the imported food; 2) an evaluation of the performance of the particular foreign supplier; and 3) a plan for the performance of periodic and appropriate supplier verification activities.

Potential hazards may include any biological, chemical or physical hazards related to the food which are reasonably likely to cause illness or injury. If potential hazards are identified, the foreign supplier’s performance in controlling hazards must be evaluated.

Once a foreign supplier is initially evaluated and approved, the supplier’s performance must be verified on a regular basis. If the potential hazard could cause serious adverse health consequences or death, the minimum standard is that a verification audit must be conducted at least annually.

If an importer utilizes several foreign suppliers, a separate FSVP must be developed for each. If an importer obtains more than one food product from any foreign supplier, an FSVP analysis must be performed for each food product, although there may be some overlap making the process easier. The type and method of foreign supplier verification processes is flexible and may include on-site audits, sampling and testing, and/or reviews of the suppliers’ relevant food safety records.

The three processes referred to above in an FSVP may be conducted by the importer itself or the importer may rely upon other specified types of entities so long as the importer itself reviews and assesses the verification records, including the results of supplier verification activities.  

Source: https://www.registrarcorp.com/monitor/index.jsp?gclid=CjwKEAiAkb-zBRC2upezwuyguQ4SJADZG08vjZVo-jK6WgjoFDhRCHKpnEmp44u3irGSiRBszmHAOBoCV1Tw_wcB