How to Build a Foreign Supplier Verification Program
Take on the importer obligation to verify that foreign food suppliers meet US standards.
What a how-to is not
A how-to is SPEQ’s practitioner method, not a procedure. It does not replace your own SOP, it is not a validated approach, and the judgement calls in it belong to your quality unit.
US food importers carry a personal obligation: to verify that each foreign supplier produces food meeting an equivalent level of public health protection. It is not a customs formality and it is not discharged by a certificate. The importer is named, identified at entry, and answerable for the verification — which makes this one of the few supply-chain obligations that attaches to a company by its role rather than its facility.
- 1
Determine whether you are the importer for each food
The obligation attaches to the US owner or consignee at entry, or to the US agent where there is none. Companies frequently discover they are the importer of record for foods they consider someone else’s responsibility, and the determination is made per food and per supplier.
- 2
Analyse hazards for each food
Identify biological, chemical and physical hazards reasonably likely to cause illness or injury, and decide which require control. The analysis is food-specific — one done for a category will miss what makes a particular product hazardous.
- 3
Evaluate the supplier as well as the food
The evaluation covers the supplier’s performance history, its compliance status, and who is controlling each hazard — the supplier, you, or a customer further down. Where the hazard is controlled elsewhere, that has to be documented rather than assumed.
- 4
Choose verification activities that match the risk
An onsite audit is expected where a hazard has a reasonable probability of causing serious adverse health consequences and the supplier controls it. Sampling and testing, records review, or other activities may suit lower risks, and the choice is justified rather than defaulted to the cheapest.
- 5
Perform the activities and keep the records
Verification is what you did, evidenced. The programme is inspected on records, so an activity performed and not documented does not count — and the records must connect each activity to the supplier and food it verified.
- 6
Act on corrective actions and reassess on a cycle
Where verification shows a supplier is not adequately controlling a hazard, take prompt action up to discontinuing use. Reassess periodically and whenever new information about the supplier or the food emerges.
- !Assuming a customs broker or the foreign supplier carries the obligation, when it attaches to the US importer.
- !A hazard analysis performed by product category rather than for the specific food.
- !A certificate accepted as verification, when verification is an activity you perform and evidence.
- !Hazard control assumed to sit downstream without the documentation that assumption requires.
How to Build a Foreign Supplier Verification Program: frequently asked questions
Common questions on build a foreign supplier verification program.
Who is the importer for these purposes?
The US owner or consignee of the food at the time of entry, or the US agent or representative of the foreign owner where there is no US owner or consignee at entry. It is a defined role rather than a commercial description, and companies are regularly surprised to find it is them.
Is a supplier certificate enough?
No. Verification is an activity the importer performs and documents — an audit, sampling and testing, a records review — chosen to match the hazard and the risk. A certificate is at most an input to that judgement, and treating it as the verification itself is the most common defect in these programmes.
When is an onsite audit expected?
Where a hazard has a reasonable probability of causing serious adverse health consequences or death and the foreign supplier is the one controlling it. Other activities may be appropriate for lower risks, but choosing them requires a written justification tied to the hazard rather than to cost or convenience.