Importers Should Prepare Early for Fee-Based VQIP Program

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FDA Encourages Importer Preparation for Next VQIP Application Cycle

by: Food and Drug Law at Keller and Heckman of Keller and Heckman LLP - The Daily Intake

Tuesday, May 29, 2018

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As previously discussed on this blog, the Food Safety Modernization Act (FSMA) established a voluntary, fee-based program for the review and importation of foods from importers who achieve and maintain a high level of control over the safety and security of their supply chains. The Voluntary Qualified Importer Program (VQIP) is a voluntary fee-based program that provides expedited review and import entry of human and animal foods into the U.S. Importers are required to meet certain eligibility requirements, such as ensuring that the facilities of their foreign supplier are certified under the Accredited Third-Party Certification Program.
On May 25, 2018, FDA released a constituent update encouraging importers to prepare for the next application cycle. While the VQIP application portal opened in January and lasts through May 31, FDA does not anticipate that importers will be able to apply during this application cycle while certification bodies (also known as third-party auditors) receive their accreditation. So far, FDA has recognized two accreditation bodies, ANSI-ASQ National Accreditation Board (ANAB) and the American National Standards Institute (ANSI), to assess and accredit certification bodies. Currently, no certification bodies have been accredited.
Because no such certification bodies have yet been accredited, importers are not able to apply to participate in VQIP for the FY19 benefit year. Due to the time needed to accredit certification bodies, FDA is considering an early opening for the FY20 application portal later this calendar year once certification bodies have been accredited. This would allow importers to submit their completed applications early. For importers interested in participating, FDA encourages the following preparation:
- Submit a notice of intent to participate
- Begin working on the application
- Review the Public Registry of Recognized Accreditation Bodies to find links to certification bodies