FDA requires the following, among other things, of importers covered by the March deadline.
Documentation of supplier compliance:
Importers are required to ensure that they import from suppliers whom they have evaluated and approved through various methods that outline the potential health risks their products pose. A covered importer must ensure that a supplier is compliant with preventive controls rules, including the implementation of a food safety plan, and allergen labeling rules. The importer must also monitor the supplier’s FDA compliance history. Should an approved supplier be found non-compliant, FDA requires importers to take corrective actions. These may involve facilitating the development of the supplier’s Food Safety Plan or ceasing business with them until they become compliant.
Hazard analysis of food products:
The FSVP rule requires importers to document a detailed hazard analysis of each category of food products they import from a given supplier. The analysis should identify any known or reasonably foreseeable hazards that could pose illness or injury, as well as the potential risks involved in the supplier’s handling of the food during manufacturing procedures, storage, and transport. The data obtained by this hazard analysis should be used to determine appropriate supplier verification activities relative to the level of risk these products pose, such as sampling or onsite audits of a food facility.