Jump to content

  • Quick Navigation
Photo
- - - - -

FSVP for Distributors & Customers


  • You cannot start a new topic
  • Please log in to reply
3 replies to this topic

#1 svnh.bell

svnh.bell

    Grade - AIFSQN

  • IFSQN Associate
  • 44 posts
  • 2 thanks
0
Neutral

  • Earth
    Earth

Posted 29 August 2019 - 05:55 PM

Looking for some clarification: 

 

We do not directly import any materials from overseas. We do however purchase foreign raw materials from US distributors. Does the overall responsibility of FSVP fall on the distributor (the importer) or us? 

 

We are still doing our due diligence with a supplier approval program and qualifying each material manufacturer, analyzing each lot for identity via validated NIR methods and testing for microbial contamination in regards to the FDA's hazard tables. 

 

Are we required to have a formal FSVP plan, then? We are a small (10 full time) facility manufacturing ingredients for cosmetics, supplements, beverages, and some foods. 

 

Thanks! 



#2 SQFconsultant

SQFconsultant

    SQFconsultant

  • IFSQN Fellow
  • 3,084 posts
  • 787 thanks
652
Excellent

  • United States
    United States
  • Gender:Male
  • Interests:Truth is like a delicious slice of watermelon... you just want more and more!

Posted 30 August 2019 - 03:21 AM

We do not directly import any materials from overseas. We do however purchase foreign raw materials from US distributors. Does the overall responsibility of FSVP fall on the distributor (the importer) or us? 

 

It is the US Distributor that has the responsibility- however with that said they in turn must copy you on each one.


Kind regards,

 

Glenn Oster
 
GOC GROUP / +1.800.793.7042 / Food - Food Packaging - Food Storage/DC

SQF, BRC & IFS System Development, Implementation & Certification Consultants

Serving Small-to-Mid-Size Businesses | We are International - Accepting all major C-Currencies

Internal Auditor Training | eConsultant | SQF, BRC & IFS Pre-Development or Pre-Audit GAP

http://www.GlennOsterConsulting.com  -- 

 

 

60% Savings to Ownership/Senior Partners when using C-Currency "XRP" Expires: 04-NOV-20

https://glennosterco...-development-pr
 

 

 

 

 

 

 

 

 
 
 
 
 
 
 
 
 

#3 tde19

tde19

    Grade - Active

  • IFSQN Active
  • 10 posts
  • 2 thanks
0
Neutral

  • United States
    United States

Posted 08 November 2019 - 04:25 PM

We do not directly import any materials from overseas. We do however purchase foreign raw materials from US distributors. Does the overall responsibility of FSVP fall on the distributor (the importer) or us? 

 

It is the US Distributor that has the responsibility- however with that said they in turn must copy you on each one.

 Is there specific documentation that is needed, say a statement, that shows we do not directly important so FSVP does not apply? 



#4 pHruit

pHruit

    Grade - FIFSQN

  • IFSQN Fellow
  • 1,388 posts
  • 590 thanks
298
Excellent

  • United Kingdom
    United Kingdom
  • Gender:Male
  • Interests:Composing/listening to classical music, electronics, mountain biking, science, sarcasm

Posted 08 November 2019 - 05:02 PM

 Is there specific documentation that is needed, say a statement, that shows we do not directly important so FSVP does not apply? 

 

The FDA overview on FSVP is pretty clear on only applying to importers: https://www.fda.gov/...ans-and-animals

Similarly the Key Requirements document (attached) defines in the scope: For the purposes of FSVP, an importer is the U.S. owner or consignee of a food offered for import into the United States. If there is no U.S. owner or consignee, the importer is the U.S. agency or representative of the foreign owner of consignee at the time of entry, as confirmed in a signed statement of consent.

 

See also the attached "Am I subject to FSVP" decision tree.

Attached Files






0 user(s) are reading this topic

0 members, 0 guests, 0 anonymous users

EV SSL Certificate