Supply Chain

Have you thought about your suppliers FDA registrations?

Ned Blinick

August 18, 2016

It's hard to believe that we are now into August. I've always been a glass-half-empty kind of guy, and August represents the waning of summer. I feel as though I can already hear the approaching footsteps of autumn; cooler nights, and then cooler days.Food Importers should be taking note of the date. Since 2016 is an 'even' year, FDA registrations are required to be renewed. Specifically, the renewal window for FDA registrations starts on October 1 and ends on December 31, and all food facilities are required to renew their registrations. If a facility fails to renew its registration, it will be revoked and a new registration will need to be obtained.Why is this important to Food Importers? Simply stated, any shipment that arrives at a US port (where the facility that produces, processes, packs, or holds any food product - including wine and spirits) without a valid FDA registration will be held by CBP until the situation is rectified. It is especially problematic for companies that have hundreds of suppliers and/or producers - where the management is very time consuming and difficult to track.While most companies that export to the US will understand that their FDA registration is imperative, there is always the chance that they will forget. Facilities that have a small proportion of its exports going to the US might inadvertently overlook this requirement. Regardless, it is the Importer's responsibility to ensure that the appropriate registrations have been filed and are kept on file so as to minimize the chance of a shipment being held by CBP and FDA.Companies take different stances on how best to ensure that their suppliers have their FDA registrations up-to-date, based on their risk profile or attention to risk. The best companies proactively solicit a response from their suppliers to ensure that their registration has been renewed and confirm the registration number. This can be a lot of work, especially if it is done manually. Both the solicitation, management, and follow up are all time consuming and tedious to manage without the proper tools.As CBP and FDA and other government agencies all have access to ACE information the importer is coming under greater scrutiny. Complying with simple registration requirements is important in ensuring that your profile with the affected agencies is "clean".Have you given any thought to your FDA registrations and how you are going to manage them this go-round? Do you need help with the process of soliciting responses from your suppliers and vendors? If so, you really should give 3rdwave a shout. We have a great deal of experience managing this process, and tools that will make the solicitation process a snap...and the cost is much more reasonable than you might think.