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FDA registration as a packaging producer


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Skyhaze

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Posted 07 May 2020 - 09:42 AM

i work for a company that produces cardboard packaging in the UK, we have been asked by a customer for our FDA registration number which they will need to export some tea advent calendars to the US later in the year. I've seen a similar topic on here but the responses were from people that are based in the US and the consensus was that packaging producers do not need to register. Is the rule the same for exporting into the US? I don't want to register if we don't need to.



SQFconsultant

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Posted 07 May 2020 - 12:26 PM


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pHruit

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Posted 07 May 2020 - 01:31 PM

i work for a company that produces cardboard packaging in the UK, we have been asked by a customer for our FDA registration number which they will need to export some tea advent calendars to the US later in the year. I've seen a similar topic on here but the responses were from people that are based in the US and the consensus was that packaging producers do not need to register. Is the rule the same for exporting into the US? I don't want to register if we don't need to.

 

IIRC it's only the final processor/packer that requires FDA registration - they are the party responsible for ensuring compliance with US/FDA requirements.

The food facilities registration requirement comes under 21USC350 ("Registration of food facilities" - see https://www.law.corn...de/text/21/350d). Note the definition in section ©(1): The term "facility" includes any factory, warehouse or established of an importer) that manufactures, processes, packs, or holds food.

 

Since as a packaging manufacturer you are none of these, you do not (and indeed almost certainly cannot) register. Your customer will only need to provide their FDA details for their export.



Skyhaze

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Posted 07 May 2020 - 01:56 PM

That's excellent, thank you very much for your help.






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