The short answer

A GFSI certificate is helpful, but it is not automatic FSVP compliance. FDA does not recognize or endorse any private scheme — BRCGS, FSSC 22000, SQF, IFS or others — as meeting the Foreign Supplier Verification Program rule. What FDA looks at is whether the audit itself meets the FSVP conditions, and whether the importer reviewed the results.

DocumentUseful for FSVP?Why
GFSI certificate onlyLimitedShows a pass against a private standard; does not show FDA rules were considered
Full audit reportYes, if it covers FDA rulesShows scope, findings, corrective actions and auditor
Recent FDA inspectionYes, can replace the auditAllowed under 21 CFR 1.506(e)(1)(i)(E) if within one year of the audit due date

What GFSI is

The Global Food Safety Initiative is an industry body that benchmarks private certification schemes. Schemes that pass are “GFSI-recognized”; suppliers are then audited and certified by private certification bodies. GFSI is widely trusted by retailers — but it is a private system, separate from FDA law.

What FSVP requires from an onsite audit

Under 21 CFR 1.506, the US importer must verify each foreign supplier. The options are an onsite audit, sampling and testing, a review of the supplier's food safety records, or other appropriate activities. When an onsite audit is used, 1.506(e)(1)(i) says it must:

  1. 1Be done by a qualified auditorSomeone with the right education, training or experience — not necessarily through FDA's accredited third-party program.
  2. 2Consider the applicable FDA food safety regulationsFor example the preventive controls rule or the produce safety rule — and include a review of the supplier's written food safety plan, if any, and how it is carried out.
  3. 3Be documentedAudit procedures, dates, conclusions, corrective actions and the auditor's qualifications.

For hazards that could cause serious harm or death and are controlled by the supplier, the default is an onsite audit before the first import and at least once a year (1.506(d)(2)), unless the importer documents that another approach is adequate.

⚠️ The importer cannot hand verification to the foreign supplier itself (except sampling and testing), and the people verifying must not have financial conflicts of interest (1.506(e)(2) and (e)(4)).

How to use a GFSI audit for FSVP

FDA has published optional comparison templates so importers and audit schemes can check whether a private standard covers FDA's preventive controls, animal food and produce safety requirements. In practice, importers do this:

Example

A US importer buys olive oil from Italy and snacks from Mexico. Both suppliers hold GFSI-scheme certificates. For the snack maker, where allergens are a supplier-controlled hazard, the importer gets the full audit report, checks that allergen controls and the food safety plan were reviewed against FDA expectations, records the auditor's details, and signs off the review. The certificate alone would not have been enough.

What FDA checks in your FSVP file

The supplier audit is only one part of FSVP. During an FSVP inspection, FDA usually asks the importer for:

A GFSI audit report can support several of these points, but it cannot replace the hazard analysis or the importer's own evaluation and review.

Checklist for importers

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Frequently asked questions

Does FDA recognize GFSI certification for FSVP?

FDA does not recognize or endorse any private certification scheme as meeting FSVP. An onsite audit used for FSVP must be done by a qualified auditor and must consider the applicable FDA food safety regulations. A GFSI-scheme audit can be used if it meets those conditions.

Is a GFSI certificate alone enough for my FSVP file?

Usually not. The certificate shows the supplier passed an audit against a private standard. For FSVP you need the audit report showing what was checked, evidence that FDA requirements were considered, the auditor’s qualifications, and your own review of the results.

Is an annual onsite audit always required?

An annual onsite audit is the default when the supplier controls a hazard that could cause serious adverse health consequences or death. The importer can choose other verification activities or a different frequency if it makes and documents an adequate written determination.

Can a recent FDA inspection replace the audit?

Yes, in some cases. An inspection for compliance with FDA food safety rules by FDA (or another US authority), or by the food safety authority of a country FDA recognizes as comparable or equivalent, conducted within one year of the date the audit was due, may be used instead.

Sources

Dates, fees and regulation numbers checked against FDA and Federal Register sources on November 8, 2026. This article is general information, not legal advice.

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