August 2012

CBP Symposium Registration is OPEN (for now)!

REGISTRATION IS NOW OPEN!

Registration opened on August 29, 2012 at 1:00 pm eastern standard time.

The CBP Symposium will take place from October 29-30, 2012 at the Renaissance DC Downtown Hotel in Washington, DC.

To register, click here.  For those of you that don’t want to travel to DC, webinar is an option, and that registration is available here.  The full agenda may be found here.

If you’re going, send me an email at jdiaz@becker-poliakoff.com!  Let’s meet in DC!



Don’t Let Your Bioterrorism Act Registration Lapse

has for the first time, specifically put the onus on importers to have a program to verify that the food products they are bringing into this country are safe. The idea behind FSMA is to change FDA regulatory enforcement and focus to more of a preventative approach, instead of reactionary. These new requirements include risk-based controls, foreign supplier verification program, certification, and audits. A brief overview of the requirements may be found here.

I’ve summarized the requirements relevant to your Bioterrorism Act Registration below, so you can be sure your registration doesn’t lapse.

New Biennial Registration Requirements
FSMA amended the Food, Drug & Cosmetic Act (FD&C Act) Section 415 to provide for biennial registration updates. Facilities which are required to register will have to re-register every 2 years, during the period beginning on October 1 and ending on December 31 in even numbered years. This will first occur in October-December 2012.

Note that even facilities which are already registered with the FDA are still required to renew their registrations during the October 1 – December 2012 registration renewal period.

U.S. Agent
FDA requires that foreign facilities have a U.S. agent. The U.S. agent must:

  1. live or maintain a place of business in the U.S. and
  2. be physically present in the U.S.

The U.S. Agent is also responsible for the payment of “reinspection fees” of foreign facilities and failure to comply with recall orders.  Reinspections are follow-up inspections conducted by the FDA after a previous inspection by the FDA where the FDA identified non-compliance issues materially related to food […]

By |2022-07-06T13:47:59-04:00August 29, 2012|Food, FSMA, Import|0 Comments

CBP Symposium Date Change & C-TPAT Conference Postponed

REGISTRATION IS NOW OPEN!  cpb Registration opened on August 29, 2012 at 1:00 pm eastern standard time.

Originally CBP planned to hold the CBP Symposium right after the CTPAT conference from September 24-28th in DC.  I thought that was a great idea and hope it works in the future. For now, the CTPAT conference is postponed and the CBP Symposium has a new date.

So mark your calendars for the CBP Symposium titled “Transforming Trade for a Stronger Economy”, it is now October 29-30 in Washington, DC. CBP is limiting attendance to 3 representatives per company, so plan accordingly. Registration has not yet been announced – but, I will say, you need to act fast, it’s sold out within a day typically. It’s an excellent opportunity to meet with all levels at CBP – take advantage!  The Symposium already took place on the West Coast, for a sneak peak at what to expect in DC, see the agenda here. Questions for CBP about the symposium may be sent to tradeevents@dhs.gov

CBP advised all member of CTPAT that ” CTPAT will not be holding its 2012 Conference in September due to scheduling and logistics challenges.  We are currently working to revise the planning in order to bring you the conference material at a later date.  We will provide updated information as we get it on both the www.cbp.gov website and through email messages on the CTPAT Portal. We apologize for any inconvenience […]

CBP Now Has Mutual Recognition with EU for C-TPAT

 

On May 4, 2012, U.S. Customs and Border Protection (CBP) signed a Mutual Recognition Decision (MRD) with the European Union (EU).  This is CBP’s sixth Mutual Recognition Arrangement (MRA) to date.  The other five MRAs include New Zealand (2007), Canada and Jordan (2008), Japan (2009), and Korea (2010).

The MRD with the EU and its 27 Member States will be implemented in two phases:

Phase I will commence in July of 2012, and it will have two components:

 

  1. CTPAT will start to recognize and accept the status of an Authorized Economic Operator (AEO) company in the EU in its overall validation process.  If a CTPAT validation visit is necessary as part of your validation or revalidation process, no such visit will need to take place in order for your company to be in the “Certified/Validated” status if that foreign facility is AEO certified.  Less redundant validations and a faster validation process are two of the benefits under Mutual recognition. A further benefit is that it will be easier for your company to document to your CTPAT Supply Chain Security Specialist (SCSS) that your business partners comply with the CTPAT program’s securitycriteria because these partners are AEO certified and the US recognizes that foreign program as one compatible to CTPAT by the fact that the US signed a MRA with that country.  There will be a period after July 2012 when CTPAT validation visits to AEO members may occur from time to time; the reason for this is that some of these validations […]
By |2015-12-01T07:03:26-05:00August 10, 2012|CTPAT|0 Comments
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