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Importers of Record Come in All Shapes and Sizes

Ten years ago, the FDA divided the large and comprehensive Food Safety Modernization Act into several rules. One of those is the Foreign Supplier Verification Program or FSVP. FSVP largely affects the “importers of record” – those businesses legally responsible for importing food into the United States.

In short, FSVP requires that “importers perform certain risk-based activities to verify that food imported into the United States has been produced in a manner that meets applicable U.S. safety standards.”

But who are importers of record, and what specifically are they expected to do?

Importers of record come in all shapes and sizes and can be found virtually everywhere in the United States. Some importers of record represent larger shipper entities with thousands and even tens of thousands of suppliers, both domestic and foreign. They may employ hundreds or thousands of people, and command hundreds of millions of dollars in annual revenues. They may also import many different food commodities.

However, most importers are smaller. Usually, these importers focus on a limited number of commodities. Most mid-sized import companies employ dozens of employees. Some are located in border communities and ports of call, but others may reside in inland cities and towns anywhere in America’s 50 states or US territories.

Azzule’s Core Support team has worked with clients of all sizes, but we really take pride in our clients with small-scale import operations. These smaller importers are often mom and pop firms run by two or three people, some even out of their own homes that may use only a single foreign supplier to import a single commodity.

Importers of record may have large packing operations that blend numerous commodities into fresh or processed foods. However, other importers never touch the food they have taken ownership of, and simply transfer the sale of food to another third party customer.

All importers of record have a few things in common. First, they are all a part of a supply chain, and as such, they all have strict liability for the food that they have brought into the United States. More to the point, as importers of record, all are legally required to implement FSVP. So, what are the requirements of FSVP?

Importers are responsible for actions that include:

  • Determining known or reasonably foreseeable hazards with each food
  • Evaluating the risk posed by a food, based on the hazard analysis, and the foreign supplier’s performance
  • Using that evaluation of the risk posed by an imported food and the supplier’s performance to approve suppliers and determine appropriate supplier verification activities
  • Conducting supplier verification activities
  • Conducting corrective actions

All importers must establish and follow written procedures to develop, maintain, and follow a Foreign Supplier Verification Plan for each food brought into the US. They must require their foreign suppliers to meet their pre-established approval processes. “The evaluation of the risk posed by the imported food and the supplier’s performance must be reevaluated at least every three years, or when new information comes to light about a potential hazard or the foreign supplier’s performance.”

Lastly, importers of record might have modified FSVP requirements when the importer’s customer is processing the food in accordance with applicable food safety requirements by applying preventive controls.

What size import business would you label your company? Leave us a comment; we would love to know!

Also, if this article has helped you realize that your business may need to comply with the Foreign Supplier Verification Program, and you have questions on how to get started, please contact our sales team at or call us at (805) 623-8416!

Our team will be able to shoot you a response within a 24 hours, and we will have FSVP experts on hand, ready to give you guidance on your next steps to compliance.