The short answer
A Very Small Importer (VSI) can follow a much lighter version of the FSVP rule. For human food, you qualify if your average yearly food sales plus the market value of food you import without selling stayed below $1 million, adjusted for inflation, over the previous three years. FDA’s current inflation-adjusted figure is a 3-year average of $1,372,952 (2023–2025). For animal food, the base limit is $2.5 million (currently $3,432,379).
A VSI does not need a written hazard analysis or full supplier verification activities. But it still needs a written FSVP, a qualified individual, supplier assurances and records.
| Threshold | Base in the rule | FDA inflation-adjusted 3-year average (2023–2025) |
|---|---|---|
| VSI — human food | Less than $1,000,000 | $1,372,952 |
| VSI — animal food | Less than $2,500,000 | $3,432,379 |
FDA updates these figures each year on its “FSMA Inflation Adjusted Cut Offs” page (last updated May 13, 2026).
How the calculation works
- Who counts: the FSVP importer including its subsidiaries and affiliates. You cannot split one business into several companies to stay under the limit.
- What counts: sales of human food plus the market value of human food imported, manufactured, processed, packed or held without sale (for example, food imported for a fee).
- Which years: the average of the three calendar years before the current year.
- All food counts — not just imported food. A U.S. company that averages $1.5 million of food sales a year is over the current human-food limit, even if only $400,000 of that is imported food.
What a Very Small Importer must still do
- 1Document VSI statusBefore importing for the first time, and then every year by December 31. Keep the records that support it for at least 3 years.
- 2Use a qualified individualThe FSVP must be developed and carried out by a qualified individual with the right education, training or experience.
- 3Get written assurance from each foreign supplierBefore importing and at least every 2 years: a written statement that the supplier produces the food in line with U.S. safety requirements.
- 4Take corrective actionIf you learn the supplier is not meeting U.S. standards, act — for example stop importing — and document it.
- 5Identify yourself at entryYour name, email and a unique facility identifier (a D-U-N-S number is accepted) must be sent to CBP for each entry line.
- 6Keep FSVP recordsSigned, dated and available to FDA on request.
What a Very Small Importer does not need
- A written hazard analysis for each food
- A full evaluation of the supplier’s performance and the food’s risk
- Ongoing verification activities such as audits, sampling or record reviews
This is a real saving in time — but the written assurance must be meaningful. A one-line email (“our food is safe”) is weak evidence if FDA inspects you.
Other modified FSVP options
The same section of the rule (21 CFR 1.512) also allows modified requirements when an importer — of any size — buys from certain small foreign suppliers, such as facilities that are “qualified facilities” under the preventive controls rules. In that case the importer collects the supplier’s written assurance and status documents instead of doing full verification. Ask your supplier whether it has filed a qualified facility attestation — see Form FDA 3942a.
Example
A small U.S. shop imports olive oil from Italy and spices from India. Its total food sales are about $600,000 a year, so it qualifies as a VSI. It documents its status each December, gets written assurances from both suppliers every two years, names a qualified individual, and makes sure its broker sends its D-U-N-S number on every entry. If sales grow above the limit, it must move to the full FSVP for the next year.
VSI or full FSVP?
VSI is simpler, but it is not always the best choice:
- If your suppliers won’t sign assurances, VSI does not work — you need them under both options.
- If your business is growing fast, a full FSVP avoids rebuilding everything when you cross the limit.
- For higher-risk foods (sprouts, raw seafood, nuts, spices), a full hazard analysis protects you even when not required.
Our FSVP compliance audit and gap assessment ($250) checks your status and documents. FSVP program development from $400; QI retainer $200 per year.
Frequently asked questions
What is the Very Small Importer limit in 2026?
For human food, the rule sets a base of less than $1 million per year, adjusted for inflation. FDA’s current 3-year average figure (2023–2025) is $1,372,952. For animal food it is $3,432,379. Check FDA’s inflation-adjusted cut-offs page for updates.
Does a Very Small Importer need a hazard analysis?
No. A VSI does not need a written hazard analysis or supplier verification activities. It does need written assurances from each supplier at least every 2 years, corrective actions, importer identification at entry and records.
How often must VSI status be documented?
Before you first import as a VSI, and then each year by December 31. Keep the supporting records for at least 3 years.
Is a VSI exempt from FSVP?
No. A VSI follows modified FSVP requirements, not an exemption. FDA can still inspect a VSI and issue warning letters if the modified requirements are not met.
Sources
- FDA — FSMA Inflation Adjusted Cut Offs (updated May 13, 2026)
- FDA — FSVP Small Entity Compliance Guide
- Federal Register — FSVP final rule (November 27, 2015)
Dollar thresholds and requirements checked against FDA sources on November 11, 2026. This article is general information, not legal advice.