FSVP Compliance Checklist for U.S. Food Importers
FSVP Compliance Checklist for U.S. Food Importers
38 verification points across 5 sections Β· Click each item to mark it complete
How to use this checklist: Each item maps to a specific FSVP requirement under 21 CFR Part 1, Subpart L. Items marked CRITICAL are non-negotiable β a single gap here can trigger an import alert or Warning Letter. Use this as a self-assessment before an FDA inspection or when onboarding a new foreign supplier.
1 β Qualified Individual & Agent Designation0/6
β
A qualified individual has been formally designated as the FSVP Agent (must meet the Β«qualified individualΒ» definition per 21 CFR 1.500)
Criticalβ
The FSVP Agent has completed FSPCA FSVP training recognized by FDA, or has equivalent documented food safety knowledge and experience
Criticalβ
Written documentation confirms the agent’s name, qualifications, and role within the FSVP program
Β§1.509β
The FSVP Agent is reachable by FDA during business hours and can respond to agency inquiries in English
β
Your FDA Importer Account (via FDA Unified Registration and Listing System or CBP) accurately reflects your FSVP Agent’s contact information
CBPβ
There is a documented process for updating the agent designation when personnel changes occur
2 β Foreign Supplier Evaluation0/9
β
A written hazard analysis has been completed for each food commodity imported, identifying known or reasonably foreseeable biological, chemical, and physical hazards
Criticalβ
Each hazard identified as requiring a control measure is documented with the rationale for that determination
Criticalβ
A foreign supplier evaluation has been conducted for each supplier, assessing their food safety practices and performance history
Criticalβ
Supplier evaluation considers: FDA inspection history, compliance with applicable U.S. food safety regulations, and corrective action track record
Β§1.505β
If the supplier holds a recognized certification (e.g., PrimusGFS, SQF, GlobalG.A.P.), this is documented and the certification scope is verified against the imported product
β
The evaluation assesses the severity and probability of hazards if controls are not applied
β
Supplier evaluation records are maintained and dated, with the name of the qualified individual who performed the evaluation
Recordsβ
There is a process to re-evaluate suppliers when new information emerges about food safety risks or supplier performance
β
You have obtained and reviewed supplier documentation: certificates of analysis, food safety plans, audit reports, or equivalent evidence
3 β Verification Activities0/9
β
Verification activities have been determined and documented for each supplier, appropriate to the hazards and supplier risk level
Criticalβ
For suppliers with hazards that require control, verification includes at least one of: onsite audit, sampling & testing, review of food safety records, or other appropriate activity
Criticalβ
If relying on a third-party audit as verification, the auditor is qualified and the audit scope covers the relevant hazards
Β§1.506β
If using product testing as verification, sampling plans, testing methods, and frequency are documented and scientifically appropriate
β
If relying on a supplier’s food safety records review, the records reviewed are specified and the review frequency is documented
β
Verification activities are conducted at an appropriate frequency based on risk β and not just at onboarding
β
All verification activity results are documented with dates and outcomes, and records are retained for at least 2 years
Recordsβ
There is a documented process to respond to unsatisfactory verification results β including supplier corrective action requests and stop-ship decisions
β
If a supplier has been approved under an exemption or modified requirement (e.g., very small supplier), the basis for that exemption is documented
Β§1.5074 β FSVP Program Documentation & Annual Review0/8
β
You have a complete written FSVP program covering all required elements under 21 CFR Part 1, Subpart L
Criticalβ
The FSVP program has been reviewed and reanalyzed within the past 12 months by a qualified individual
Criticalβ
The program was updated whenever you became aware of new information about food safety risks for any imported product
Β§1.510β
The program was updated when you added new products or new foreign suppliers
β
All FSVP records are maintained in English (or translated into English) and can be provided to FDA within 24 hours of a request during inspection
Recordsβ
Records are retained for at least 2 years (certain records require longer retention β confirm by record type)
Recordsβ
There is a corrective action procedure when the FSVP program is found to be inadequate or when a supplier fails to meet requirements
β
You know what to do if you receive a Form 483 or Warning Letter related to your FSVP β and you have a designated point of contact to respond
5 β Exemptions, Waivers & Special Situations0/6
β
You have confirmed whether each imported food is subject to FSVP or exempt (e.g., juice under 21 CFR Part 120, seafood under Part 123, dietary supplements under Part 111)
Β§1.502β
If importing from a country with an FDA equivalence recognition agreement, you have documented the basis for relying on that recognition
β
If any supplier qualifies as a very small foreign supplier (annual sales β€$1M), you have documented the modified verification approach applied
Β§1.512β
You have assessed whether any imported product is a RAC (raw agricultural commodity) and applied the correct FSVP requirements accordingly
β
If a broker or customs agent is involved in your imports, their role relative to FSVP obligations is clearly defined and does not create compliance gaps
β
You have a process to monitor FDA import alerts affecting your suppliers or products, and to act on them before shipments are presented at the border
β
Full FSVP Compliance β Well Done
You’ve checked all 38 requirements. Maintain your program active throughout the year and schedule your annual reanalysis before it’s due.
Talk to an FSVP Expert at Agrocers β