3 replies to this topic

[aparajhithafsc]

Hello,

 

I have a clarification to ask -

One of my clients exports food products from Canada to USA - both white label and private label. 

They ship it to a 3PL who then further distributes to relevant customers. The 3PL has declined to act as the FSVP IOR.

They currently do not have a customs broker who can act as the FSVP IOR. 

My client has a registered office in Chicago through workbox as well as a mailbox. There is no one physically present there nor does any payroll happen there. All their QA & Regulatory teams as well as the FSVP QI are based out of Canada. 

 

My questions - 

1. Can the client act the IOR themselves?

2. IS the registered office address without any payroll sufficient to satisfy the U.S consignee entity requirement? 

3. Do they still need a signed agreement between this US Office and Canada Office for ownership of product by the U.S office?

 

Its a bit confusing based on the FSVP guideline definition on where the line is drawn on who is a U.S Consignee.

 

Thanks in advance!

 

Edited by aparajhithafsc, 17 August 2026 - 03:25 PM.

[TimG]

I won't answer your question, but I want to make sure you've seen these 2 documents:

 

Am I subject to FSVP?

Guidance for Industry: Foreign Supplier Verification Programs for Importers of Food for Humans and Animals

[aparajhithafsc]

Hello TimG,

 

Yes, I have, thank you! 

I hear conflicting information though. 

By the definition, it looks like they can comply and I know a few other companies that are doing this.

But with no "activity" in this office, does it really qualify for the definition of U.S consignee for FSVP purposes? I've had other consultants say no to this, hence the confusion.

 

Thanks! 

I won't answer your question, but I want to make sure you've seen these 2 documents:

 

Am I subject to FSVP?

Guidance for Industry: Foreign Supplier Verification Programs for Importers of Food for Humans and Animals

[tahoeskier]

1.  All must be in writing and who is acting as the FSVP importer?

2. US office must be a physical address but does not need to be manned. If needed, someone must be able to get there within a reasonable amount of time (no defined limit). The FSVP importer who develops the FSVP plan must be in the US.

3.YES