NEW FSVP COMPLIANCE DEADLINE IS MARCH 19: WHAT FOOD IMPORTERS SHOULD KNOW AS REGULATIONS INTENSIFY

Food importers should be aware of a March 19 deadline requiring most small businesses to comply with the Food Safety Verification Program (FSVP) regulations. With the FSVP shifting the burden of ensuring the safety of imported foods from the FDA to importers themselves, WB Skinner is urging its clients to put their plans into place, with special emphasis on “good-to-excellent” record keeping and tracking.

Hazard Identification

According to Julie Hartenfels, VP of Compliance for WB Skinner, the next deadline means that affected importers recognize that there are different codes related to hazard identification, as specified by the FSVP program:

• FSV – for products where the supplier controls the hazards
• FSX – other products that may be FDA regulated but importer controls the hazards
• RNE – products for research and evaluation – samples not for commercial use.

Hazard identification must consider known or reasonably foreseeable biological, chemical, and physical hazards. These hazards could be present because they occur naturally, are unintentionally introduced, or are intentionally introduced for economic gain (if they affect the safety of the food). According to the FDA rules, if the hazard analysis reveals one or more hazards that require a preventive control, the facility must have and implement written preventive controls for the identified hazards. See the FDA’s Draft Guidance on Hazard Analysis HERE. *

WB Skinner is already putting these hazard identification codes into entries for clients, but urges importers to be aware of the requirements and seek guidance if needed.

What is FSVP?

FSVP is part of the FDA’s Food Safety Modernization Act (FSMA) and is a long-in-development plan to require that U.S. importers bring in goods only from FSVP-approved suppliers.  Importers are required to verify that their foreign suppliers are producing and labeling food at the same level of public health protection as U.S. standards require.  The FDA has been rolling out FSVP compliance dates since May 2017, with factors such as size of the importer’s sales, staff, and foreign resources determining the relevant compliance date. The March 19 2018 date affects mostly small importers of human and animal food.

What Importers Should Do

WB Skinner urges its clients to be familiar with the requirements and deadlines of FSVP and be aware of the implications for their businesses. Compliance with the program will minimize entry times and FDA hold-ups for their shipments.

View the Final FDA rule and its requirements HERE.**

If you have questions about the FSVP rule, please contact Julie Hartenfels or give us a call at 201-644-7214.