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The Food Safety Modernization Act: Will FSMA Require Changes to Company Supplier Verification Programs?

A couple of weeks ago I attended a Michigan Food Protection and Defense Working Group meeting.  The crowd included many folks from the food industry and from state government.  A few people raised the following question: Under the Food Safety Modernization Act, what will U.S. food companies be required to do to ensure that their foreign suppliers are selling safe and compliant products into the U.S.? 

In other words, will FSMA require changes to company supplier verification programs?  The answer, to the surprise of several attendees in the room, is yes.  FSMA required the FDA to issue guidance on the development of foreign supplier verification programs and to publish regulations regarding the content of those programs.  The deadline on FDA has passed, but the regulations and guidance could be issued at any time. By January of 2013, U.S. food companies will be required to perform risk-based foreign supplier verification to confirm that their suppliers' food is in compliance with appropriate risk-based, preventative controls that provide the same level of protection as provided by FSMA.  U.S. food companies will need to begin preparing to comply with these new requirements. 

I encourage you to take a proactive approach – begin assessing your suppliers' food safety systems, including sanitation and traceability.

© 2019 Varnum LLP

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About this Author

Varnum's Food Law practice includes more than a dozen attorneys experienced in the sophisticated areas of law that apply to food regulation. We help regulated businesses bring their products to market. In particular, we counsel USDA- and FDA-regulated businesses in the following areas:

  • Product labeling, advertising and other promotional materials.

  • The regulatory scheme affecting or governing such products, including mandatory and voluntary submissions (FDA-required petitions and notifications) and...

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