Specialty Food Magazine

Spring 2018

Specialty Food Magazine is the leading publication for retailers, manufacturers and foodservice professionals in the specialty food trade. It provides news, trends and business-building insights that help readers keep their businesses competitive.

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Who Is the Importer? The FSVP importer is the owner or consignee of food that is being imported into the U.S. The importer must be physically located in the U.S., and have a U.S. business address. A mailbox and an answering service are not enough; they must have a location that can be visited by the FDA. The importer's name, email address, and facility identifier must be provided for each line entry of product coming into the U.S. When multiple entities meet the definition of FSVP importer, those organizations must decide who is the FSVP importer and record that in a contract. There are many situations where more than one entity could be the importer; for instance, when a company is bringing a product in for a specific retailer. Either entity could be the FSVP importer but one needs to accept that responsibility. The guidance also addresses the definition of a "foreign sup- plier." The foreign supplier is the company that manufactures or processes the food. (It can also be the establishment that raises the animal or grows the food, although that is of less concern to the specialty food industry.) It is the final organization that does manufacturing or processing, not the final entity to be in posses- sion of the food. A distributor, repacker, or labeling company cannot be the foreign supplier. Regarding ingredients for further processing, the importer of the ingredient is the responsible FSVP entity. In specialty, that is usually a different organization than the manufacturer. The importer of the ingredient must verify the safety of the ingredient when it comes into the U.S., unless hazards will be controlled along the supply chain. Importers are required to put together an FSVP for each food that they import from each foreign supplier. The FSVP is singular to the food as well as the supplier. So, for instance, if an importer is bringing in cheese and yogurt from the same supplier, a separate FSVP would need to be conducted for those products in that they have significantly different hazards. For foreign suppli- ers with products in multiple product lines, there could be many FSVPs. It all is based on the potential hazard and how it can be controlled. However, importers do not need to establish separate FSVPs for different versions of the same food from a supplier. For example, if you are importing a jam that comes in different f lavors, such as strawberry and blueberry, and in different sizes, such as single serve, consumer size, and foodservice, one FSVP would be sufficient, as long as the hazards present and preventive controls needed for each f lavor and size are similar. When the hazards are different, separate FSVPs must be conducted by the importer or the variance must be addressed within a single yet more comprehensive FSVP. Taking the jam example, if the strawberry jam had walnuts as an ingredient, a separate FSVP would be needed because the walnuts introduce an allergen to the food. And importers are responsible for making sure that the presence of an allergen is addressed. The FSVP must be specific to each foreign supplier. For instance, if you are importing olive oil from 20 companies in Spain, Italy, and Greece, you must verify that each of the suppliers is making the oil in a safe manner. The FSVPs for each supplier might be very similar but you do need to have one for each of the companies. How Can an Importer Prepare? Since the FSVP regulation went into effect in May 2017, most importers should currently be complying with the law. The FDA does understand that this is a dramatic change and is working with the import community to educate before they regulate. The FSVP must be conducted by a "qualified individual" just as the Food Safety Plan under the Preventive Controls for Human Food regulation must be written by a "qualified individual." FDA defines a "qualified individual" as "a person who has the education, training, or experience (or a combination of these) necessary to per- form an activity required under the FSVP regulation, and can read and understand the records that the person must review in perform- ing this activity." The Food Safety Preventive Controls Alliance has developed a training curriculum and certificate for "qualified indi- viduals" and has also developed an FSVP training program. Both are recognized by the FDA. The qualified individual can be an employee of the importer, a government official, a consultant, or third-party auditor. U.S. or foreign government personnel can conduct FSVP activities, as long as they understand FDA food safety regulations. Importers can also Importers need to have the paperwork, at their place of business in the U.S., ready for inspection by the FDA. Importers are required to put together an FSVP for each food that they import from each foreign supplier. SPRING 2018 75

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