FSVP for Coconut Sugar Buyers: Your Obligations as US Importer
Direct answer
What is FSVP, and what do I owe FDA as the US importer of coconut sugar?
FSVP is the US importer’s program, not the factory’s. For each food it imports, the importer must develop, maintain and follow a Foreign Supplier Verification Program that gives adequate assurances about the foreign supplier. We supply documents that can support that program; whether a document meets a requirement is decided by the importer’s own qualified individual.
This page maps our documents to the FSVP rule, 21 CFR Part 1 Subpart L, read on 31 October 2026. It belongs to importing coconut sugar into the USA.
1. Who the importer is under FSVP
The importer is “the U.S. owner or consignee of an article of food that is being offered for import into the United States” (US eCFR, 21 CFR 1.500, as read 31 October 2026). Where there is no US owner or consignee at entry, the foreign owner or consignee must designate a US agent or representative as the importer (US eCFR, 21 CFR 1.509(b), as read 31 October 2026).
A qualified individual, a person with the education, training or experience the activity needs, carries out the FSVP work; that person may be, but does not have to be, the importer’s employee (US eCFR, 21 CFR 1.500, as read 31 October 2026).
2. What an FSVP covers
For each food it imports, the importer must develop, maintain and follow an FSVP (US eCFR, 21 CFR 1.502(a), as read 31 October 2026). The rule’s sections name the work:
- Hazard analysis: “What hazard analysis must I conduct?” (21 CFR 1.504).
- Supplier approval: “What evaluation for foreign supplier approval and verification must I conduct?” (21 CFR 1.505).
- Verification: “What foreign supplier verification and related activities must I conduct?” (21 CFR 1.506).
- Identification at entry: the importer’s name, email and unique facility identifier with each line entry (21 CFR 1.509).
- Records: kept at least 2 years (US eCFR, as read 31 October 2026) after they were created or obtained, under 21 CFR 1.510(c)(1).
3. The mapping table: our documents and FSVP
The right-hand column says what a document can support, never that it satisfies a requirement.
The buyer question, answered
| FSVP requirement | What we provide that can support it |
|---|---|
| Hazard analysis (21 CFR 1.504) | A Certificate of Analysis for every lot; a specification sheet with every quote |
| Supplier evaluation and approval (21 CFR 1.505) | An FDA-registered facility (the registration number is not published); a sample from every production lot, retained for five years; third-party testing at SGS and Sucofindo, both in Indonesia |
| Verification activities (21 CFR 1.506) | Your own inspector before loading, at your cost, with 3 working days’ notice |
| Records (21 CFR 1.510) | The shipping documents for each order: commercial invoice, packing list, Bill of Lading, Certificate of Analysis and certificate of origin |
4. Common first-timer mistakes
Four patterns, each set against the rule it misses.
Treating our documents as the FSVP
Our documents feed the program; the program itself is the importer’s, kept for each food it imports (US eCFR, 21 CFR 1.502(a), as read 31 October 2026).
No importer named at entry
Each line entry carries the importer’s name, email address and unique facility identifier (US eCFR, 21 CFR 1.509(a), as read 31 October 2026).
No US agent when there is no US owner
A foreign owner or consignee designates a US agent or representative as the importer before the food is imported (US eCFR, 21 CFR 1.509(b), as read 31 October 2026).
Records not kept long enough
FSVP records are kept at least 2 years (US eCFR, as read 31 October 2026) after they were created or obtained, under 21 CFR 1.510(c)(1).
FSVP questions
Does the factory file the FSVP? No. The FSVP is the US importer’s program: for each food it imports, the importer must develop, maintain and follow one (US eCFR, 21 CFR 1.502(a), as read 31 October 2026). The factory is the foreign supplier the program verifies, and supplies documents that can support it.
Who is the importer if there is no US owner or consignee? Before the food is imported, the foreign owner or consignee must designate a US agent or representative as the importer (US eCFR, 21 CFR 1.509(b), as read 31 October 2026).
Does the qualified individual have to work for the importer? No. A qualified individual may be, but is not required to be, an employee of the importer (US eCFR, 21 CFR 1.500, as read 31 October 2026).
How long must FSVP records be kept? At least 2 years (US eCFR, as read 31 October 2026) after the importer created or obtained them, under 21 CFR 1.510(c)(1).
Sources
- US Government Publishing Office (eCFR) / US Food and Drug Administration (FDA) · 21 CFR 1.500 — What definitions apply to this subpart? · government · fetched
- US Government Publishing Office (eCFR) / US Food and Drug Administration (FDA) · 21 CFR 1.502 — What foreign supplier verification program (FSVP) must I have? · government · fetched
- US Government Publishing Office (eCFR) / US Food and Drug Administration (FDA) · 21 CFR 1.504, 1.505, 1.506 — section titles · government · fetched
- US Government Publishing Office (eCFR) / US Food and Drug Administration (FDA) · 21 CFR 1.509 — How must the importer be identified at entry? · government · fetched
- US Government Publishing Office (eCFR) / US Food and Drug Administration (FDA) · 21 CFR 1.510 — How must I maintain records of my FSVP? · government · fetched