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Dairy Facts 2016

Foreign Supplier Verification Programs to Take Effect May 30

May 18, 2017

Starting May 30, the Foreign Supplier Verification Programs rule of the Food Safety Modernization Act will require all food companies, even those exempt from the rule, to provide information to the Food and Drug Administration to ensure imported products are allowed across the U.S. border. The rule requires companies importing foods regulated by the FDA to provide specific identification for their imported foods, while other companies are expected to submit documentation indicating that the food products are exempt or that the compliance date has not yet occurred for those products.

Under the rule, dairy companies that import foods will have to verify that their non-U.S. suppliers are producing food in a manner that meets U.S. safety standards and that they are achieving the same level of food safety as domestic farms and food facilities. The rule specifically requires importers to conduct verification activities, such as audits of a supplier’s facility, sampling and testing of food, or a review of the supplier’s relevant food safety records, that are based on risks linked to the imported food and the performance of the supplier.

The compliance dates can vary depending on the size and type of supplier and whether it meets current Good Manufacturing Practices and risk-based preventive controls. For specific details, visit the FDA website for more information on all compliance dates.

May 30 Compliance Date

Importers covered by the May 30 compliance date must provide the FSVP importer’s name, e-mail address and a Unique Facility Identifier recognized by FDA. According to new FDA guidance, a unique nine-digit identifier provided by Dun & Bradstreet is acceptable to use. For companies without a Dun & Bradstreet number, FDA will temporarily allow importers to enter “UNK” for “unknown.”

Hogan Lovells, IDFA’s outside counsel, has prepared a memo outlining the changes in procedures and the new information required by FDA. Members may login in here to read more.

In February, IDFA and 16 other members of the Food and Beverage Industry Alliance called on FDA to issue comprehensive guidance that would help companies understand the agency’s expectations and develop compliant supplier verification programs. IDFA is still analyzing the extent to which this new information from FDA answers the questions member companies have had and will provide additional details at a further date, if necessary.

Members with questions may contact John Allan, IDFA vice president of regulatory and international affairs, at

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