Bait And Seafood Not Fit For Human Consumption
Bait and seafood not fit for human consumption has been a bit of a gray area when it comes to reporting requirements. Information recently published by the FDA provides a bit of clarity in relation to these products.
It has been determined that seafood and baits not fit for human consumption, even if they are covered by HACCP, require Foreign Supplier Verification Program (FSVP) reporting.
If you ship Seafood or Bait that is not fit for human consumption please make sure that you are adding the FSVP party responsible for verifying the foreign manufacturer of the goods are processing the goods according to US FDA safety regulations.
What Is The Foreign Supplier Verification Program (FSVP)?
FSVP is a program set in place by the Food and Drug Administration (FDA). This requires US buyers to make sure they are importing from foreign producers that are manufacturing under the same standards as domestically made foods. It consists of various specific information retained by the US importer such as hazard analysis of the producers, controls, monitoring programs, and specific record keeping requirements.
What New Information Must I Include On My Invoices?
You will need to report the FSVP Importer, their DUNS number, contact email address, and IRS number. If this information is not provided your Customs Broker will not be able to clear your goods, and the shipment will be put on hold until that information is provided.
Who Is The FSVP Importer?
The FSVP Importer must be a US Company. When items have been sold this is usually the US buyer of the goods. If there is no US buyer, then it is the receiver of the goods in the US. If there is no final receiver, such as items going to a fulfillment facility, you can use a US FSVP Agent who agrees to take on the responsibilities of the FSVP Importer.
How Does This Affect Foreign Suppliers?
Although the FSVP Importer is technically the US Company, there is a large amount of information that the FSVP Importer is required to verify and keep on file regarding your manufacturing facility. These can range from lab results, your food safety plans, and other information. You are required to provide this information to the FSVP party as a condition of import.
In addition, as the foreign supplier, if you are the Importer of Record, you will need to make sure you speak with your buyers to confirm with them that they are aware of the FSVP rule, their responsibilities as the named FSVP party, and that they have provided you with their DUNS number and email address.
Where Can I Find More Information Regarding The Foreign Supplier Verification Program Requirements?
A link to the FSVP rules can be accessed here
Alternatively, you can call our US Trade Compliance Department to find out more information on importing food products into the US.