Importing Food Safely
With recent incidents of food contamination making headline news, tracking the food supply chain has never been more important. Here are some tips on ensuring food import safety and accountability from Michael Lahar, food and drug administration team leader for A.N. Deringer Inc., a St. Alban's, Vt.-based third-party logistics provider.
1. Verify your trading partners are registered with the FDA. Every party that touches food products and dietary supplements intended for consumption in the U.S. marketplace, with the exception of carriers that have possession of the goods merely to facilitate transportation, must register with the Food & Drug Administration (FDA). Registering manufacturers/shippers, wholesalers, middlemen, third-party warehouses, and cold storage facilities allows the FDA to trace the product in the event of a recall.
2. Know your manufacturer/shipper. Make sure the names and addresses provided for FDA clearance match the names and addresses on file with the Food Facility Registration numbers. For products not originating in North America, this can be one of the biggest obstacles to obtaining timely release of your goods by the FDA.
3. Provide a product description. Use laymen's terms to describe your product on the clearance document, particularly when citing brand or trade names.
4. Properly mark canned goods. When importing Low Acid Canned Foods and Acidified Foods, you must declare the Federal Canning Establishment number to the FDA. Make sure clearance documentation prominently displays this number.
5. Clearly mark Harmonized Tariff Schedule numbers. Make sure the clearance paperwork shows an accurate U.S. Harmonized Tariff number. Consult with your U.S. customs broker to ensure that you are using the proper tariff number.
6. Get familiar with the Bioterrorism Act (BTA) of 2002.Most people importing and exporting food articles to and from the United States are familiar with the BTA's import requirements for food, but may not know it also covers dietary supplements. These are defined as any products that provide sustenance or nutritional value to humans or animals.
7. Make sure the shipment documentation states the number and types of packaging. When reporting quantities to the FDA, your agent will provide a "base unit" of weight or volume. The documentation must also detail the type of material comprising the packaging touching the product, as well as the preservation method used to package the goods.
8. Include the FDA product code on clearance documents. The product code gives the FDA and your service providers information about the goods being imported.
9. Make sure the paperwork provided is legible and complete. The misinterpretation of one number or letter could delay clearing your goods.
10. Seek advice in advance. Ask your agent or broker questions before products ship. Keep communication lines open and provide emergency contact numbers. This step can prevent delivery delays, storage and warehousing charges, angry clients, and unnecessary inspections and detentions.