The importer of record (as defined by CBP) may be the same as the importer under FSVP, but is not necessarily.
The FSVP Importer performs certain risk-based activities to verify that food imported into the United States has been produced in a manner that meets applicable U.S. safety standards. In contrast, the CBP importer of record of a food might be an express consignment operator with little to no knowledge of the safety regulations applicable to the products for which they obtain clearance from CBP.