No. FDA does not require a food facility to use a third party to make registration submissions.
A food facility owner, operator, or agent in charge of the facility is responsible for meeting the
registration requirements (see section 415(a) of the FD&C Act; and 21 CFR part 1, subpart H).
The owner, operator, or agent in charge may authorize an individual to make registration
submissions on behalf of the facility (see, e.g., 21 CFR 1.230(a)). The authorized individual
may be, but is not required to be, the U.S. agent for a foreign facility. Although third parties
such as U.S. agents may charge a fee for their registration-related services, there is no fee
assessed by FDA for registrations.
