FSVP, a regulation under FSMA putting food safety responsibilities primarily on importers for the first time, requires food importers covered by the rule must verify that their foreign suppliers are producing food in a manner that provides the same level of public health protection as the preventive controls or produce safety regulations, as appropriate, and to ensure that the supplier’s food is not adulterated and is not misbranded with respect to allergen labeling.

A food importer means the U.S. owner or consignee of an article of food that is being offered for import into the United States.  If there is no U.S. owner or consignee of an article of food at the time of U.S. entry, the importer is the U.S. agent or representative of the foreign owner or consignee at the time of entry, as confirmed in a signed statement of consent.  The importer for FSVP is not necessarily the same as the importer of record for the U.S. Customs.

 

Under FSVP, importers are required to:

  • Determine known or reasonably foreseeable hazards with each food from each foreign supplier

  • Evaluate and re-evaluate the hazard risks and the foreign supplier’s performance

  • Determine appropriate supplier verification activities

  • Conduct supplier verification activities through an onsite audit, sampling and testing, and review of relevant food safety records.

  • Conduct corrective actions

 

FSVP allows US importers to rely on a third party who has qualified individuals (QI) and qualified auditors (QA) to conduct a hazard analysis, evaluation of food risks and foreign supplier performance, and suppliers verification as long as the evaluation of risks and foreign supplier performance and supplier verification is not performed by the foreign supplier and importers must review and assess the relevant documentation.

CPC offers a one-stop cloud-based solution to importers, brokers, distributors, forwarders, and manufacturers who are subject to FSVP, our  qualified individuals (QI) and qualified auditors (QA) will help you develop, maintain, and follow FSVPs, providing customized services that include:

  • Conduct hazard analysis.

  • Evaluate foreign supplier’s performance and risks posed by the food.

  • Reevaluate foreign supplier’s performance when food safety concerns occur or at the end of the 3-year period.

  • Perform supplier verification activities including onsite audit.

  • Investigate and take corrective actions once a food safety issue occurs.

  • Develop and maintain FSVP processes, procedures, and timely update the system to prevent foreseeable food safety incidents.

  • Customize an FSVP system to meet requirements applied to a client’s specific operation.

  • Timely monitor foreign suppliers’ compliance status and immediately notify you when a foreign supplier receives a recall, warning letter, 483s from the FDA inspections, import alerts, and import refusals.

  • Document and retain required FSVP records and provide quick access to audit-ready cloud-based documentation system.

  • Provide onsite assistance during FDA FSVP inspection upon request.

 

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