What Importers Can
Resolve To Do Now To
Be Regulation-Ready
Foreign food producers hoping to present new products to U.S. buyers have experienced setbacks as in-person trade shows came to a halt with Covid-19. What can international producers and exhibitors do now to prepare for food shows or U.S. market entry later in the year? Here are some steps that your company can take during the first and second quarters of 2021 to be regulation-ready when vaccinations expand and shows eventually resume.
Get your Foreign Supplier Verification Programs Planning Underway Now
Are you a company outside of the U.S. that has a new food item you want to introduce to the American market? As an international exhibitor, will you be ready to confidently plan your participation at U.S. food shows that may occur later this year? It’s not too soon to begin the FSVP process with a U.S.-based FSVP Importer, and to start any new FDA registrations for foreign facilities. According to Bobbi Greenwell, PCQI, FSVP Compliance Director at The Radius Group, Inc., “The U.S. requires that importers develop, maintain and follow an FSVP for each food brought into the country. If importers secure a food from different suppliers, an FSVP is needed for each supplier. Here at TRGI, we operate as an FSVP Importer and advise companies to anticipate a process that takes some months to complete as we help foreign suppliers meet U.S. food importing regulations. If you’re hoping to secure a new client order at a trade show later this year, have your food safety plan reviewed now and your FSVP ready prior to the show for smoother market entry.” If you’re developing products or line extensions for the U.S. market, have restructured your supply chain, or need label review, start the year with this essential FSVP planning.
Reevaluate your FSVP Plan if It’s Been 3 Years Since the Last One
Has it been three years since your FSVP plan was completed? Importers are required to reevaluate FSVP plans every three years and these assessments on performance and risks, food safety procedures and practices, must be conducted by a Qualified Individual.
Make Sure your Nutrition Facts Label is FDA-Compliant on Packaged Food and Drinks
In the U.S, the requirements of Nutrition Facts labeling were updated in 2016, with a compliance period coming to an end this year for certain manufacturers. Manufacturers with less than $10 million in annual food sales were required to update their labels by January 1, 2021. Manufacturers of most single-ingredient sugars, such as honey and maple syrup, and certain cranberry products have until July 1, 2021 to make the changes. The new labeling reflects updated information on the link between diet and chronic diseases to support consumer awareness.
Ensure your Records are Ready in the Event of an FSVP Inspection
If you’ve completed the FSVP process, are you subject to routine surveillance by FDA? Does your company have an inspection history that includes any violations? Prepare for any inspections by making sure all your records are translated into English. Be sure that you can retrieve records quickly if they are not stored at your facility. With the coronavirus pandemic, you may need to send records electronically or through another means that delivers records promptly. Taking time now to ensure your records are in the proper condition in the event of a records request by an FDA inspector will make this process less painful.
Continuously Confirm your Suppliers’ Compliance with FDA rules
Importers should regularly confirm their suppliers’ compliance with relevant regulations. FDA rules require that importers continuously check that their foreign suppliers are not receiving a warning letter, import alert, or are the subject of recalls or any other action asserting non-compliance with food safety. In 2020, FDA issued more than 40 warning letters for FSVP violations (a large increase from 2019 when 5 such letters were issued).