Is your company ready for the 2020 U.S. FDA Biennial Renewal Food Facility Registration? The renewal time period just started on October 1, 2020 and is through December 31, 2020. Even though there are still many weeks left for the biennial renewal, we at USFDA Corp Consultants believe it’s necessary to prepare and renew as early as possible.
Under federal law, all food facilities are required to renew their registrations with FDA by December 31, 2020. New legislation, called the Food Safety Modernization Act, went into effect two years ago requiring that food facilities registered with FDA updated their registrations at the end of every even-numbered year (e.g., 2020, 2022, 2024, etc.).
It is possible to renew company registrations right now. The FDA registration module features a button labeled, “Biennial Registration Renewal – 2020,” allowing facilities to review and update their registrations.
Companies should prepare for the 2020 biennial renewal before submitting the renewal request to FDA. How can food companies prepare for the FDA Food Facility Biennial Renewal?
Here are some suggestions we have on how to plan for this year’s renewal:
- Review the current registration in its entirety. Has any information changed since the registration was last updated? Technically, any changes or alterations must be reported to FDA and made on the registration within 60 days of said change. Many companies don’t realize this, or often forget. This is one of the many reasons why it is important to have a qualified and organized U.S. Agent: to assist in the renewal process, as well as maintain accuracy of a registration. We offer affordable U.S. Agent services for foreign food facilities..
- Has the emergency contact information changed? Make sure that all e-mail addresses and phone (including fax) numbers listed are accurate, as these are often the means by which FDA contacts a company for inspection or issues with shipment.
- Is the listed emergency contact person reliable? Again, this is an important question because it will effectively be your point of contact for any FDA-related matters. Make sure this person is responsible and checks e-mail, phone message, and regular mail on a daily basis. This is so important for both food shipments that may be detained at the port as well as for inspection purposes (when initiating an inspection, FDA requires a response within five days).
- Have any of the types of food your company exports to the U.S. changed? If so, you should make sure the food listed for your facility is accurately updated to reflect the types of products shipped to the U.S. The Agency will often pick facilities to inspect based on food products produced, especially if a particular region is associated with a food safety concern.
- Do you need to list a parent company on the registration? If your company is a subsidiary of another company, you should complete the parent company information section.
- Has the facility moved or address changed? If so, this will require a completely new FDA food facility registration, which will generate a new FDA # that you must use on all shipments to the U.S., as well as inform your importer with. This is extremely significant, as an outdated address can cause issues with shipments as well as inspections.
- Has the name of the facility changed? Again, this will require a completely new FDA food facility registration, which will generate a new FDA # that you must use on all shipments to the U.S., as well as inform your importer with. This is extremely significant, as an outdated address can cause issues with shipments as well as inspections.
- Are there any alternative trade names? If so, you should list the trade names to avoid any issues when exporting your food products to the U.S.
- Do you know what to do if there are multiple registrations for the same facility at the same address? This can cause problems with FDA and also delay shipments to the U.S.