Just looking for a little guidance as to what we need to do in relation to FSMA for foreign suppliers. We are a UK based BRC certified manufacturer of a branded product. The brand holder (our customer) wants to expand their market into the USA within the next 12 months or so. Reading on line it is about as clear as mud as to what we as the manufacturer need to have in place in order to ship the product out to the USA on their behalf - FSVP does not appear to be applicable to us as we will not be technically classed as the importer. But what I suppose I am asking is what we need above and beyond the BRC systems we currently have in place in order for us to be approvable - we of course operate HACCP, along with additional vulnerability and site security threat risk assessments as required for BRC. I have read the BRC voluntary module for FSMA which states is only applicable to US operators and most of the points made in this document appear to be wording amends to our system. Do we need to register with the FDA or be subject to additional audit?
Any help / guidance along the correct path will be greatly appreciated