What Must Importers Verify Under the New FSVP Requirements?
FDA is still developing the specific details of its new FSVP authorities. However, the part of the FSMA that authorizes and describes the new FSVP requirement focuses on specific food safety outcomes. U.S. Food Importers must be able demonstrate, through their FSVP, that their foreign manufacturers supply foods that:
- Are made, processed, packed and stored using processes that “provide the same level of public health protection” as HARPC and the Standards of Produce Safety Requirements,
- Comply with the Major Food Allergen Labeling requirements, and
- Are not adulterated
These statutory provisions represent food and beverage safety outcomes which FDA expects firms to work toward in creating an FSVP plan. The specific food safety protocols in any given FSVP plan will depend upon a variety of factors, including inherent risks associated with the food or the processing steps, the region or country of origin of the food, the ingredients used, the number of manufacturing parties involved in making the food, etc. Although FSVP requires foreign suppliers to implement either HARPC or Standards of Produce Safety, as applicable, those programs will also vary widely, company-to-company and food-to-food.
How May Importers Verify The Compliance Of Their Foreign Suppliers?
The FSVP provision identifies some activities U.S. Food and Beverage Importers may perform as appropriate to verify that the food they import is safe — that it meets the statutory food safety outcomes outlined in the FSMA. These include:
- Monitoring shipment records that might reveal the food is safe,
- Conducting annual on-site inspections of the foreign supplier
- Obtaining a copy of and evaluating the Foreign Supplier’s HARPC Plan or records proving food complies with applicable Standards of Produce Safety
- Lot-by-lot food certification of compliance
- Periodic sampling and testing shipments challenging manufacturer Certificates of Analyses
FSVP.com was designed specifically to provide access to our FDA consultants and attorneys with decades of experience in proving compliance with FDA’s food safety requirements. Additionally, we keep you updated on how and why FDA is moving as it develops and implements FSVP, HARPC, and Standards of Produce Safety.
Don’t lose time and money due to refused food shipments! Contact us today to ensure that your company complies with all FSVP requirements.