Start with the regulatory role
Under FDA’s FSVP rule, the importer is generally the US owner or consignee of the food at the time of entry. Where none exists, the rule provides for a US agent or representative of the foreign owner or consignee, whose consent must be confirmed in a signed statement. This FSVP role is separate from the foreign facility’s registration US agent.
FSVP obligations concern verification of foreign suppliers. Dietary supplements are not automatically exempt. For many finished supplements, modified FSVP requirements focus on dietary supplement current good manufacturing practices and exclude the standard hazard-analysis requirement. Different provisions can apply to ingredients or components. Confirm the applicable requirements with the FSVP importer.
Roles that should not be conflated
| Role | Question for your shipment |
|---|---|
| Importer of record | Who is responsible for the customs entry arrangement? |
| FSVP importer | Who holds the applicable food supplier-verification responsibility? |
| Food facility US agent | Who represents the foreign facility for its registration-related role? |
| Customs broker | Who is authorised to handle the customs filing? |
| Receiving warehouse | Who accepts the physical cargo and on what terms? |
A company may take more than one role by agreement, but a warehouse address or freight booking does not establish that agreement. Document the actual parties and contacts.
Questions for foreign brands
If you are sending stock you still own to a US fulfilment warehouse, ask your adviser who will take the applicable FSVP role. If a US buyer purchases the goods, confirm how the ownership and import responsibilities are structured. Do not assume the same arrangement works for both scenarios.
A logistics quote should make its coordination scope clear. It should not imply that freight forwarding automatically includes an FSVP representative or a completed supplier-verification programme.
Information for the shipment brief
- Responsible business name and contact for the import arrangements.
- Manufacturer identity and complete product list.
- Broker contact and agreed document exchange process.
- Written confirmation of any representative arrangement where applicable.
Share contact and business details needed for the booking. Keep confidential registration credentials out of an initial freight enquiry.