NCBFAA Comment Letter to FDA Suggests Caution When Defining Importer
Washington, DC: In a letter today to the U.S. Food and Drug Administration (FDA), the National Customs Brokers & Forwarders Association of America, Inc. (NCBFAA) President Jeffrey Coppersmith commented on the FDA's implementation of the Food Safety Modernization Act, which places primary responsibility for the safety of imported food on the people who have knowledge and control over the supply chain. In the NCBFAA’s view, these are the U.S. owner, the consignee who purchases the product, or a U.S. person who specifically takes on the role as the agent of the foreign owner for this purpose.
“We think the importer for FDA purposes should be the person who caused the goods to come to the U.S. - that is, the party in the U.S. with a financial interest in the product or a U.S. agent designated by a foreign manufacturer or supplier through a specific written agreement between the foreign entity and the U.S. agent and filed with the FDA,” wrote President Coppersmith.
“Either of these parties should be required to register with the FDA and receive a registration number, which would be provided at the time of entry,” he wrote. “This would provide the certainty required for FDA and would ensure that a true party in interest is responsible for the food product.”
Headquartered in Washington, DC, the NCBFAA represents nearly 800 member companies with 100,000 employees in international trade - the nation's leading freight forwarders, customs brokers, ocean transportation intermediaries (OTIs), NVOCCs and air cargo agents, serving more than 250,000 importers and exporters. Established in 1897 in New York, NCBFAA is the effective national voice of the industry. Through its various committees, counsel and representatives, the Association maintains a close watch over legislative and regulatory issues that affect its members. It keeps them informed of these and other related issues through its weekly Monday Morning eBriefing, and various meetings and conferences throughout the year.
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