FSVP generally requires a U.S. food importer to identify itself as the FSVP importer, determine whether the food is subject to the regulation, assign a qualified individual, analyse hazards associated with the imported food, evaluate and approve the foreign supplier, conduct risk-based verification activities, take corrective action when required, and maintain the required programme records. The exact verification process depends on the food, the identified hazards and the supplier’s performance. Verification activities are risk-based — not every Indian supplier automatically requires the same annual onsite audit.
Importing food from India into the United States creates a food-safety responsibility that extends beyond selecting a supplier and checking whether the foreign facility is registered with FDA. For many imported foods, the U.S. importer must develop and follow a Foreign Supplier Verification Program — commonly known as FSVP.
FSVP is an importer verification programme. It is not simply a certificate obtained from the Indian exporter or a record that the facility appears on the FDA registration database. For U.S. buyers sourcing spices, seeds, agricultural ingredients and other food products from India, FSVP should be addressed before regular commercial imports begin.[1]
Asking a supplier “Are you FSVP certified?” starts the wrong conversation. The U.S. importer generally holds the FSVP obligation and must build the required verification programme for each imported food and foreign supplier.
What Is FSVP?
FSVP stands for Foreign Supplier Verification Program. The rule forms part of the U.S. Food Safety Modernization Act framework and applies to many importers of food for humans and animals.
Its central principle is that imported food should not be treated as safe simply because it has reached the United States from an overseas supplier. The importer must perform specified risk-based activities to verify that the foreign supplier is producing food in accordance with applicable U.S. food-safety requirements — including that relevant processes provide the required level of public-health protection and that food is not adulterated or misbranded with respect to allergen labelling.[2]
FSVP is generally food-specific and supplier-specific. An importer must develop, maintain and follow a separate FSVP for each imported food and each foreign supplier unless an exemption or modified procedure applies.[3]
Step 1: Determine Who the FSVP Importer Is
The first question is not which documents the Indian supplier can provide. It is: who is the FSVP importer?
Under the FDA definition, the FSVP importer is generally the U.S. owner or consignee of the food at the time it enters the United States. If there is no U.S. owner or consignee at the time of entry, the FSVP importer can be the U.S. agent or representative of the foreign owner or consignee, subject to applicable requirements and written consent.[3]
The FSVP importer may not always be the same entity a commercial team casually calls the “importer.” This distinction should be established before the shipment is entered into the United States. The FSVP importer must also be properly identified during the entry process.
Define the FSVP importer in the transaction structure before cargo is shipped. Do not assume the customs broker, freight forwarder or Indian supplier automatically carries the FSVP responsibility.
Step 2: Determine Whether the Food Is Subject to FSVP
The FSVP regulation applies broadly to imported food, but contains exemptions and modified requirements for certain foods and import situations. Importers should confirm the regulatory treatment of the exact food being imported — considering the product, its intended use, the applicable FDA food-safety regulation and whether an exemption or modified FSVP procedure applies.[4]
This is particularly important when a company imports different categories of food. A compliance process designed for one product should not automatically be copied to every other imported commodity.
Start with regulatory applicability for the exact food. Do not build a generic “India supplier FSVP file” and assume it covers every food purchased from that supplier.
Step 3: Assign a Qualified Individual
FSVP activities must be performed by a qualified individual where required by the regulation. A qualified individual must have the education, training or experience — or a combination of these — necessary to perform the assigned FSVP activity and must be able to read and understand the language of any records that must be reviewed.[4]
This does not necessarily mean every importer must employ a full-time internal FSVP specialist. However, responsibility for FSVP activities should be assigned to people with the knowledge required to perform those activities correctly.
FSVP should have a named compliance owner or qualified resource. It should not exist as an unassigned folder of supplier certificates maintained by the purchasing team.
Step 4: Conduct a Hazard Analysis for the Imported Food
The importer must evaluate known or reasonably foreseeable hazards associated with the food and determine whether any require a control. Hazards can be biological, chemical or physical. The analysis should consider the food itself and the conditions under which it is manufactured, processed, packed and held.[4]
For spices, microbiological hazards deserve particular attention. FDA’s risk work on spices has identified Salmonella as the pathogen most commonly associated with human illness attributed to contaminated spices.[8] The hazard analysis may also need to consider chemical hazards, pesticide residues and other potential hazards based on the exact product, production process, origin and intended use.
The importer may conduct the hazard analysis directly or, under the applicable FSVP provisions, review and assess a hazard analysis conducted by another entity. Where another entity’s analysis is used, the importer still has review, assessment and documentation responsibilities.
A Certificate of Analysis for one shipment is not a substitute for understanding the hazards associated with the food and how those hazards are controlled at the supplier level.
Step 5: Evaluate the Indian Supplier
FSVP requires more than evaluating the food. The importer must also evaluate the performance of the foreign supplier and the risk posed by the food.[6]
This evaluation can include the supplier’s procedures, processes and practices related to food safety; applicable FDA food-safety requirements; the supplier’s compliance history; and other relevant factors. For an Indian food supplier, the U.S. buyer may therefore need information beyond commercial specifications and price.
Depending on the product and hazard analysis, relevant supplier information may include food-safety procedures, process controls, laboratory testing practices, audit information, regulatory history and records demonstrating how identified hazards are controlled. This evaluation forms the basis for supplier approval.
Supplier onboarding for the U.S. market should include a structured food-safety review. A strong quotation and clean export history do not, by themselves, complete an FSVP supplier evaluation.
Step 6: Approve the Foreign Supplier
The importer must approve foreign suppliers based on the required evaluation and document the approval.[5] The FSVP framework generally requires importers to establish and follow written procedures designed to ensure food is imported from approved foreign suppliers.
In limited circumstances, food may be imported temporarily from an unapproved supplier when the food is subjected to adequate verification activities before import. For routine sourcing, however, supplier approval should be completed as part of the importer’s compliance process before commercial imports begin.
Maintain a documented approved-supplier decision connected to the food and FSVP evaluation. An email saying “supplier looks good” is not a substitute for the required compliance records.
Step 7: Determine the Appropriate Supplier Verification Activities
This is one of the most misunderstood parts of FSVP. FSVP does not automatically require the same audit programme for every foreign supplier. Supplier verification activities are determined by the food’s risk and the supplier evaluation.[1]
Possible activities can include onsite auditing of the foreign supplier; sampling and testing of the food; review of relevant supplier food-safety records; and other appropriate verification activities. The importer must determine which activity or combination is appropriate and establish the frequency at which it should be performed.
| Verification approach | When applicable |
|---|---|
| Annual onsite audit | Generally required when the supplier controls a hazard for which exposure could result in serious adverse health consequences or death (SAHCODHA), unless an alternative approach is documented |
| Sampling and testing | Risk-based; type and frequency determined by the food hazard and supplier evaluation |
| Review of food-safety records | Risk-based; appropriate where supplier records directly demonstrate control of the identified hazard |
| Combination of activities | Determined by the specific food risk, hazard analysis and supplier performance information |
The verification programme should follow the hazard — not a standard purchasing checklist.
Ask the Indian supplier for evidence connected to the identified hazard and control. Collecting twenty unrelated certificates does not necessarily provide better FSVP verification than reviewing the three records that directly demonstrate control of the relevant hazard.
Step 8: Maintain the Required FSVP Records
FSVP is documentation intensive because the importer must be able to demonstrate that required activities were performed. Depending on the applicable requirements, records can relate to hazard analysis; foreign supplier evaluation; supplier approval; written approval procedures; verification activities and results; reevaluation; corrective actions; and other applicable programme activities.[7]
Applicable FSVP records are subject to retention requirements. Many records must be retained for at least two years, although the exact retention period can depend on the type of record and when it was created, obtained or ceased to be used. FDA also operates an FSVP Importer Portal that allows importers to upload records electronically after receiving a written FDA request.[9]
Build the FSVP record system before FDA asks for the records. Supplier documents scattered across purchasing emails, messaging apps and freight folders make compliance review unnecessarily difficult when an FDA request arrives.
Step 9: Reevaluate the Supplier and Food Risk
Supplier approval is not permanent simply because the first shipment cleared successfully. The importer must reevaluate the foreign supplier’s performance and the risk posed by the food when relevant new information becomes known. In the absence of an earlier trigger, the required reevaluation generally must occur at least every three years.[5]
New information can change the risk assessment — a food-safety issue, regulatory action, change in the supplier’s process or other relevant development may require the importer to reconsider the supplier evaluation or verification approach.
FSVP is an active supplier-management programme. Treating the first supplier approval as a permanent compliance decision misses the ongoing nature of the regulation.
Step 10: Take Corrective Action When Something Goes Wrong
If the importer determines that a foreign supplier is not producing food in accordance with applicable requirements, the importer must promptly investigate and determine appropriate corrective action.[7] The corrective action depends on the circumstances and can include discontinuing use of the foreign supplier until the cause of noncompliance has been adequately addressed. Corrective actions must be documented where required.
FDA’s FSVP enforcement activity — including warning letters issued in 2026 — confirms that importer compliance remains an active agency priority. The importer should have a defined escalation process for failed tests, adverse audit findings, regulatory issues and other information that calls supplier compliance into question.
Agree internally on who holds authority to stop purchasing or suspend a supplier for food-safety reasons. Compliance decisions should not be delayed because procurement, quality and management have unclear escalation authority.
What to Request from an Indian Food Supplier
The exact document request should follow the food and hazard analysis — not a generic onboarding checklist. Depending on the product and verification programme, the importer may request product specifications, process information, food-safety procedures, relevant audit reports, laboratory test reports, Certificates of Analysis, records relating to identified hazard controls and other compliance information.
The objective is not to build the largest supplier document folder. The objective is to obtain and evaluate information that directly supports the importer’s FSVP responsibilities for that food and that supplier. A supplier should also understand that FSVP information requests may continue after commercial onboarding — verification is an ongoing process, not a one-time pre-shipment event.