Can my U.S. distributor act as the importer of record for me?

Yes, and this is common. Whoever is listed on the customs entry as the importer of record takes on FSVP responsibility for that shipment, whether that is your own U.S. entity or a distributor.

US Food Importer Requirements for Coffee 2026

Q: Is the U.S. importer the same as the U.S. Agent?

No. The U.S. Agent is named by the foreign facility to receive FDA communications on its behalf. The U.S. importer of record is the party bringing the goods into the U.S. and bears FSVP responsibility — they are often different parties, sometimes the same company.

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Two Different Roles — Don't Confuse Them

Exporters often assume compliance is entirely their responsibility, or entirely their buyer's. In reality, it splits:

The foreign facility handles Food Facility Registration, the U.S. Agent appointment, and Prior Notice filing for each shipment.
The U.S. importer of record — whether that's your own U.S. entity, a distributor, or a roastery — carries FSVP responsibility and must confirm your registration is current before each shipment.

These can be the same company or entirely different companies. What matters is that both sets of obligations are covered by someone — a shipment with a compliant exporter but a U.S. buyer who hasn't done their FSVP homework is still at risk.

What a U.S. Importer of Record Must Do

Maintain an active, current FSVP plan for each foreign coffee supplier
Verify the exporting facility's FDA registration is valid and unexpired before each shipment
Confirm Prior Notice has been properly filed for the shipment
Keep FSVP and verification records available for FDA review on request

Why this matters to you as the exporter: A U.S. buyer with a lapsed or incomplete FSVP program can hold up your shipment even if your own registration and Prior Notice are perfect. Worth confirming your buyer's FSVP status before shipping, not after a hold.

Frequently Asked Questions

Is the U.S. importer the same as the U.S. Agent?

No — the U.S. Agent is named by the foreign facility to receive FDA communications. The U.S. importer of record is the party bringing goods into the U.S. and carries FSVP responsibility. They're often different parties.

Can my U.S. distributor act as the importer of record?

Yes — this is common. Whoever is listed as importer of record on the customs entry takes on FSVP responsibility for that shipment.

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