The Foreign Supplier Verification Program (FSVP) is part of the Food Safety Modernization Act (FSMA). The FSMA was passed to prevent foodborne illnesses in the United States. The FSVP puts the responsibility on importers to make sure that imported foods meet the same safety standards as domestic food.
Although complying with the FSVP can be complicated, it helps importers develop rigorous safety standards and avoid expensive penalties and recalls. Importers who are FSVP compliant will also build trust with consumers and maintain their market reputation.
FSVP Certification: Steps for Importers
The FSVP is mandatory for certain food importers in the United States to guarantee food isn’t adulterated or mislabeled. You need to follow it and perform verification procedures for every supplier you use to import covered food.
1. Responsibilities under FSVP
Unfortunately, the FSVP is a complex law. Your first step is to understand if it applies to you. If you import certain types of foods, are a receiving facility, or are a very small importer, you may not be subject to the FSVP or may be subject to modified FSVP requirements. You can participate in training programs offered by third parties or the FDA or consult with experts to determine how to comply with the FSVP.
Once you determine your responsibilities under the FSVP, you need to designate specific people or teams to manage FSVP compliance. This qualified individual (QI) needs to understand what FDA regulations apply to imported food. Provide comprehensive training so they’ll understand compliance procedures and record keeping. Make sure your compliance teams have the resources they need to carry out their duties effectively.
2. Hazard Analysis
Under the FSVP, you need to conduct a hazard analysis to identify any physical, biological, or chemical hazards associated with imported foods. You can do this by systematically evaluating all possible risks that could affect the foods you import.
After you’ve identified the potential hazards, you need to assess the likelihood and severity of the risks. Based on the results of the analysis, you’ll need to take control measures to mitigate the risks and protect public health.
3. Supplier Verification Activities
Create your own written FSVP plan that outlines steps you’ve taken to guarantee your foreign suppliers are producing food that meets U.S. safety standards. Your supplier verification procedures might include conducting onsite audits, reviewing food safety records, and regularly testing imported foods.
Your FSVP plan should include your hazard analysis, verification activities, and corrective measures. You’ll also need to provide documentation to prove you’ve followed your plan.
4. Record-Keeping and Documentation
The FSVP requires you to provide a detailed audit trail for review. Keep records of all your activities, including hazard analysis, audits, and test results. You also need documentation of the corrective measures you’ve taken in response to identified threats. Thorough documentation will help you prove compliance and make it easier to trace any instances of foodborne illness from imported food.
5. Compliance Monitoring and Continuous Improvement
FSVP compliance isn’t a one-and-done deal. You need to regularly monitor supplier performance and compliance through ongoing verification activities. Make your FSVP plan so that it can adapt and change in response to any change in suppliers, foods, or regulations. Regularly reviewing your plan will help you stay current with the latest risks and safety practices.
Compliance Considerations and Challenges for Importers
Importers face many challenges in implementing FSVP requirements. When you’re working with foreign suppliers, you may face language and cultural barriers that can interfere with communication regarding safety standards and practices. You may need to invest in training and translation services to overcome language gaps and improve communication with your suppliers.
Smaller suppliers also face significant compliance challenges due to a lack of financial and personnel resources. You may not have the expertise to conduct effective hazard analyses and supplier verification. In these cases, third-party consultants are a valuable resource. They can provide independent expertise and support in implementing FSVP requirements and meeting regulatory standards.
Resources for FSVP Certification
Fortunately, you have a lot of resources available to help you achieve FSVP certification. The FDA provides guidance documents and training materials to help you understand how to comply with the FSVP. You can access webinars, workshops, and meetings on different aspects of food and dietary supplements. You can also get a list of all import alerts from the FDA website. However, even with the extensive resources the FDA provides, understanding the certification requirements isn’t easy.
Some independent, third-party companies offer courses on the FSVP certification process. If you belong to a professional organization related to your imported product, such as the National Coffee Association, they can be a good resource for specific information about FSVP compliance.
Conclusion
FSVP certification is a mandatory hurdle with which importers must comply. It helps protect public health by guaranteeing that imported food meets the same stringent safety standards as food produced domestically.
If you want to achieve FSVP certification, you’ll need someone who understands the requirements, can conduct a hazard analysis for all imported food, and can verify each supplier. You’ll also need to keep meticulous documentation and regularly update your FSVP plan in response to any changes. As you take these steps yourself, your customs broker can provide guidance. Your customs broker will need to report the FSV party on all food shipments that are subject to the requirement.
Taking advantage of resources available from the FDA and working with a customs broker well-versed in trade compliance issues can make the process easier for you.
