FSVP & FDA Food Rules: Importing Thai Food to the USA (2026)
Thailand is a top-five supplier of seafood, canned fruit, rice, coconut products and sauces to the US market. Food imports carry a compliance layer most industrial buyers never touch: the Foreign Supplier Verification Program (FSVP) under FSMA.
Are you the FSVP importer?
The FSVP importer is the US owner or consignee at the time of entry — or, if there is none, the US agent named by the foreign owner. That is often you, not your broker and not the Thai factory. Only one party can hold it per entry, and their name and unique facility identifier (DUNS number) must appear in the ACE entry data.
The FSVP core obligations
| Requirement | What it means in practice |
|---|---|
| Hazard analysis | Identify biological, chemical (including allergens) and physical hazards for each food |
| Supplier evaluation | Assess the Thai supplier's performance, food-safety history and FDA compliance record |
| Verification activity | Usually an annual on-site audit for SAHCODHA hazards; sampling or records review otherwise |
| Corrective action | Documented response when a supplier fails verification |
| Records | Signed, dated, retained 2 years and available to FDA in English on request |
What FDA checks at the border
- Prior Notice filed before arrival (through ACE or the PN Web Interface).
- Food facility registration for the Thai manufacturer, renewed in even-numbered years.
- FSVP importer identification in the entry — a missing DUNS is the top cause of FSVP-related holds.
- Product-specific programs: seafood HACCP (21 CFR 123), LACF/acidified food registration and process filings for canned Thai fruit and coconut milk, and produce safety rules for fresh items.
Labeling that trips up first-time importers
- Nutrition Facts in the current format, with added sugars.
- All nine major allergens including sesame.
- English ingredient statement using common names, not Thai transliteration.
- Net quantity in both US customary and metric.
- US importer name and address.
Practical timeline for a new Thai food supplier
- Weeks 1–2: confirm factory registration, request HACCP plan, GMP/BRC/IFS certificates and lab results.
- Weeks 3–5: hazard analysis and written FSVP plan for each product.
- Weeks 6–8: audit (in person or approved third party), label review, artwork lock.
- Week 9+: first shipment with Prior Notice and correct FSVP entry data.
Related reading: FDA compliance overview and customs and CBP basics.
FAQ
Who has to comply with FSVP for Thai food imports?
The US owner or consignee of the food at the time of US entry. If there is no US owner, the US agent designated by the foreign owner takes the role.
Do I need an annual on-site audit of my Thai supplier?
An annual audit is required where the hazard requires a preventive control and could cause serious adverse health consequences. Otherwise other verification, such as sampling and testing or records review, may be adequate.
Is a BRC or IFS certificate enough for FSVP?
It supports supplier evaluation but does not replace your written hazard analysis, verification records and corrective-action procedures.
What is the most common FSVP violation at entry?
Missing or invalid FSVP importer identification, usually an absent DUNS number in the ACE entry.
Does canned Thai coconut milk need extra filings?
Yes. Low-acid canned and acidified foods require FDA food canning establishment registration and scheduled process filings before shipment.
How long must FSVP records be kept?
Two years, in English, retrievable within 24 hours of an FDA request.