The Food and Drug Administration (FDA) recently issued its final rule addressing Foreign Supplier Verification Programs (FSVPs) under the FDA Food Safety Modernization Act (FSMA).  The regulation parallels the supplier verification provisions of the preventive controls regulations, requiring “importers” to develop and implement supplier verification programs for food imported to the United States. The rule takes effect for most importers in 18 months (May 2017). FSVP represents a paradigm shift, as it is the first time that FDA has regulated food importers. The requirements under the new regulation are very detailed and record-intensive, likely necessitating careful attention by all food importers—including retailers, brokers, and food companies importing finished goods. The regulation will have less impact on facilities that are subject to preventive controls, as they are deemed in compliance with FSVP because the supply-chain oversight requirements in both rules are essentially the same. Below we provide an overview of the key provisions of the FSVP final rule.


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