Greenwich Mercantile

For mid-market and enterprise

Importer of record and FSVP importer are distinct roles.

A customs appointment does not automatically assign food-safety responsibility. Identify the responsible parties and program work before importing food into the United States.

Service scope, responsibilities and fees are agreed in writing. No guarantee of clearance or savings.

Two responsibilities, not two interchangeable labels.

The customs importer of record and FDA’s FSVP importer are defined for different purposes. They may be the same entity in a particular transaction, but that must not be assumed. A customs broker’s role or a Prior Notice submission does not automatically make it the FSVP importer.

Identify the FSVP importer under the applicable rule.

FDA generally identifies the U.S. owner or consignee at entry. If none exists, the foreign owner or consignee’s U.S. agent or representative must consent in writing to the FSVP role. Applicability, exemptions and modified requirements depend on the circumstances.

Separate program support from legal appointment.

A provider may help assemble evidence or perform agreed activities. That is not the same as accepting the legally designated role. Record who owns the FSVP program, who performs activities and who provides information for entry.

Registration and Prior Notice are separate questions.

Identify any facility-registration and U.S.-agent requirements separately from the FSVP importer. Assign responsibility for Prior Notice preparation, submission and confirmation. Neither task substitutes for the applicable food-safety program.

Scope the Greenwich engagement explicitly.

Confirm the Greenwich contact, licensed broker, any separately designated regulatory party, included tasks and exclusions. No automatic Greenwich FSVP-importer or U.S.-agent appointment is stated.

Questions, answered directly.

Is the FSVP importer always the importer of record?

No. The roles have different definitions. Determine the responsible parties from the actual transaction and applicable requirements.

Does a broker filing Prior Notice become the FSVP importer?

No. Preparing or submitting information is not an automatic appointment to the FSVP role.

Do all dietary supplements follow identical FSVP requirements?

No. FDA identifies circumstances with modified requirements. Determine applicability for the actual product, importer and supply arrangement.

Sources and limits

Sources support the stated context, not an endorsement of Greenwich or a shipment-specific determination.

Define your next U.S. decision.

Agree the question, evidence and responsibilities before acting.

Import readiness review