A couple points for you:
- Your importers should be compliant with the Foreign Supplier Verification Program rules. Part of the FSVP is documenting a hazard analysis, which includes allergens. You may want to clarify with your suppliers about their assessments for the presence of a hazard, not just whether or not they are controlling it.
- If you are not bringing allergens into your plant, nor including them as a part of your formulation, then your allergen control program is going to be preventative. I.e. focusing on supplier documentation of presence of a hazard or risk analysis for unintentional introduction of a hazard, supplier approval programs requirements including suppliers have an allergen plan in pace (even if they don't handle allergens, just like you), and procedures for what you as an organization will do in the event that your process or formula's changes and allergens were to be on-site (i.e. label, quarantine, sanitize and verify sanitation).
- Allergen cross-contact and allergen mislabelling are some of the leading causes of recall for FDA regulated CPG. Their intention with the rules is to ensure food processors have thought through the hazard and would know how to minimize the risks associated with it. So have a good plan for how they would be handled, ensure any new suppliers or products get reviewed for allergen risk, & include label review processes and you will be compliant with FSMAs allergen preventive controls. You will not necessarily always identify an allergen hazard during a hazard analysis, but it is still a good idea to have a preventive allergen control plan in place that includes basic processes for allergen labelling, quarantine, sanitization, verification sanitation, and employee training of the Big 8.