June 2014

Do You Want to be a “Trusted Trader”? C-TPAT is No Longer Enough

U.S. Customs and Border Protection (CBP) recently published the long awaited Federal Register Notice, dated June 16, 2014, discussing the “Announcement of Trusted Trader Program Test.” This new “Trusted Trader” program is big news for U.S. and non-resident Canadian importers, and if implemented will combine the Customs-Trade Partnership Against Terrorism (CTPAT) and Importer Self Assessment (ISA) programs, making ISA extinct.  CBP is currently recruiting test companies that have to be willing to go through an 18 month program test.
What is the Trusted Trader Program?

  • CBP will unify CTPAT and ISA programs into a new “Trusted Trader” program.  Companies will still have the option to apply for CTPAT and opt out of the Trusted Trader Program, but, the ISA program will be replaced by the Trusted Trader program.  CBP aims to align the Trusted Trade program with Authorized Economic Operator (AEO) programs, which focus on a combined trade and security compliance model.
  • CBP is collaborating with the U.S. Consumer Product Safety Commission (CPSC) and the U.S. Food and Drug Administration (FDA), to develop the new “Trusted Trader” program aims to “streamline the process through which importers can establish to CBP that they strive to secure their supply chains and strengthen their internal controls for compliance with the existing laws and regulations administered or enforced by CBP.” The 3 government agencies will collaborate, share information, streamline the application and validation process; and increase the efficiencies in the existing trade programs.
  • CBP plans to utilize the Centers of Excellence and Expertise […]

FDA Issues Final Compliance Policy Guide for Food Facility Registration


The U.S. Food and Drug Administration (FDA) has issued the “Compliance Policy Guide Sec. 100.250 Food Facility Registration – Human and Animal Food” (the CPG).  The CPG provides guidance for FDA staff pertaining to the enforcement of the food facility registration provisions of section 415 of the Federal Food, Drug, and Cosmetic Act (FD&C Act), which were amended by the FDA Food Safety Modernization Act (FSMA).  Under these provisions, any food facilities which manufacture, process, pack or hold food for human or animal consumption in the United States must be registered with the FDA.  Additionally, each registered facility is required to biennially renew their registrations with the FDA.  The CPG further describes the FDA’s authority to suspend a food facility’s registration.

In April 2013, the FDA published a draft of the CPG and of the two comments received, no significant changes were recommended to the draft CPG.  Therefore, no substantive changes were made from the draft to the final version of the CPG.

Please note that this CPG replaces the previously issued “Compliance Policy Guide Sec. 110.300 Registration of Food Facilities Under the Public Health Security and Bioterrorism Preparedness and Response Act of 2002.”

If you wish to obtain additional information on which food facilities must be registered with the FDA, or if you would like assistance in registering your food facility, please feel free to call me at (305) 260-1053, or email me at JDiaz@bplegal.com.

By |2022-07-07T10:18:37-04:00June 2, 2014|FDA Issues, Food, FSMA|1 Comment


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