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.