Prior to the 2011 Food Safety Modernization Act (FMSA), U.S. and foreign facilities that manufactured, processed, packed, or held food products for shipment to U.S. destinations were required to register with the U.S. Food & Drug Administration (FDA). Under FMSA, they must also renew those registrations in every even-numbered year.
2014, as you might have guessed, is one of the years in which registration renewals are required. And while both domestic and foreign FDA-registered food facilities are required to renew, importers face a special risk if their suppliers fail to renew their facility registrations. Beginning on January 1, 2015, facilities that have not renewed their registrations may have their registrations revoked. Shipments from such facilities may accordingly be subject to detention by U.S. Customs & Border Protection (CBP).
If you import food products, now is the time to confirm that your foreign suppliers have completed their renewals, or risk delays and possible rejection of shipments in the new year. And while domestic manufacturers don’t have to worry about border delays, they also need to make sure that their registrations are renewed, lest they too face invalidation of their registrations.
One tip – updating a registration is not the same as renewal, so even if you’ve recently updated an existing registration, that doesn’t mean you’re in the clear. For both domestic and foreign facilities (and their customers), there’s no time like the present. Take some time today to confirm that your facility registrations have been properly renewed and, if they haven’t been, get those renewals submitted.