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#1 CookieMonster

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Posted 01 April 2020 - 06:51 PM

So here is my little dilemma which has me second guessing myself on whether or not I am misunderstanding. Let me explain the situation.

 

We are purchasing through a Broker who is importing a confectionery item from another country. They have told me that they are the "importer", so the US owner or Consignee. However they have a 3rd party warehouse store the product that is being imported. 

 

Now here are my questions in regards to this situation:

  1.  Isn't the Broker/Importer required to have their own FDA registration number? 
  2. Wouldn't the Broker/Importer be required to also have their own Food Safety Plan/HACCP Plan since they are importing a food items.

 

Now the Broker has provided me with the standard documents from the actual foreign manufacturer, and even provided proof that the 3rd party warehouse is registered with the FDA. 

 

How do you guys handle this sort of situation. Do a different set of regulations apply that I am missing?

 



#2 SQFconsultant

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Posted 02 April 2020 - 03:24 PM

So here is my little dilemma which has me second guessing myself on whether or not I am misunderstanding. Let me explain the situation.

 

We are purchasing through a Broker who is importing a confectionery item from another country. They have told me that they are the "importer", so the US owner or Consignee. However they have a 3rd party warehouse store the product that is being imported. 

 

Now here are my questions in regards to this situation:

  1.  Isn't the Broker/Importer required to have their own FDA registration number? 
  2. Wouldn't the Broker/Importer be required to also have their own Food Safety Plan/HACCP Plan since they are importing a food items.

 

Now the Broker has provided me with the standard documents from the actual foreign manufacturer, and even provided proof that the 3rd party warehouse is registered with the FDA. 

 

How do you guys handle this sort of situation. Do a different set of regulations apply that I am missing?

Answers: 

1 - No they are not required to have this.

2 - No they are not required to have this -- from the balance of your message it appears they act as a brokerage only and have product shipped from US entry point direct to 3rd party warehouse and that warehouse would be registered and your message indicates they are.

 

With one of our clients they have about 50 or so import brokers like this and what is required is that the broker has evidence (documentation) that their foreign suppliers are FSVP'd and as far as an approved supplier program goes we require either the warehouse to provide a copy of their most recent 3rd party food safety audit and/or GFSI certificate.

 

Many of the 3rd party warehouses used for storage of imports and distribution are GFSI certified and they know exactly what they are required to provide.

 

Hope that helps.


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 | International Cross-Border C-CUR Acceptance

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

http://www.GlennOsterConsulting.com  -- 

 

Internal Auditor Training - $50 per person

https://glennosterco...uditor-training

 

 

 

 

 

 

 

 

 
 
 
 
 
 
 
 
 

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