We recently sat down with Customs and International Trade lawyers Jessica Rifkin and Roy León, to get their take on the current environment with respect to the White House, Customs, and inter-agency cooperation using the ACE system. Enforcement by Federal Agencies...
Law & Regulatory
So it Begins: FSVP Inspections
FDA has begun inspecting U.S. food importers for their compliance with the Foreign Supplier Verification Program (FSVP). The FSVP regulation has a staggered compliance date between May 30, 2017 through July 27, 2020 (depending on the food type and the foreign...
100% Re-inspection ≠ 100% Testing: USDA/FSIS’s Inspection of Imported Catfish
Starting on August 2, USDA required all shipments of siluriformes (colloquially catfish)[1] fish and fish products’ to be presented to USDA’s FSIS for re-inspection. While FSIS will perform 100% “re-inspection” for all imported shipments, the agency does not intend to...
What is Healthy Food? FDA Hasn’t decided yet
Healthy is a word that we use every day, but when we use it in terms of food labeling, the word takes on a more important and controversial meaning. In 2015, the FDA issued a warning letter to the KIND company stating that the use of the motto “healthy and tasty” on...
What do Vending Machines and Menus have in Common? FDA Rules of Course!
Editor’s Note: On September 29, 2017, FDA proposed to extend the compliance dates for the Nutrition Facts panel final rule to January 1, 2020 for manufacturers with $10 million or more in annual food sales. Manufacturers with less than $10 million in annual food...
Immediate Enforcement Crackdown on FSVP? Not so Fast
UPDATE 01-29-2018 : The next compliance date is March 19, 2018 for most food importers (who purchase food from foreign suppliers with fewer than 500 FTEs) . FDA’s Foreign Supplier Verification Plan (FSVP) first implementation date was May 30, 2017, which had...
Relief for Newly Deemed Tobacco Products: 3 Month Compliance Reprieve
In an email to stakeholders on May 1st FDA alerted the “deemed” tobacco products industry that FDA intends to delay enforcement of all compliance deadlines concerning newly deemed tobacco products for 3 months. Though, this did not come through the usual FDA channels,...
FDA Law and Consulting Practices Expand to South Florida and Hire New Senior Attorney
FDAImports.com, A Fast Growing Consulting Practice Strengthens Resources Miami, FL – Consulting practice FDAImports (http://www.fdaimports.com) is pleased to announce that Roy León, has joined the firm to further develop our growing portfolio of regional and national...
This is a What … Unforeseen Pitfalls when Classifying a Medical Device
Editor’s note: This blog by affiliated attorneys John Johnson and Schevon Salmon was originally published by greenlight.guru. “This is a what” is not only a torturous summer-camp game, but an essential question when working to bring a medical device to market. An...
What does Food Safety Modernization Act Mean to Animal Food?
The animal food industry experienced a sudden increase in the regulatory obligations in recent years. Through the Food Safety Modernization Act (FSMA) and its implemented regulations, food facilities must now operate under legally established current Good...