Background

Beginning July 24 the Food and Drug Administration will end its policy of allowing the entity identification code “UNK” (unknown) in place of the DUNS number for the foreign supplier verification program importer on entry forms.

Under the FSVP importers of human and animal food must ensure that for each entry line of imported food the unique facility identifier recognized as acceptable by the FDA for importer identification is provided electronically when filing entry with CBP. At present only the DUNS number has been so recognized.

Because this requirement was new and some factors may have prevented importers from immediately obtaining a DUNS number, since March 2018 the FDA has been allowing FSVP importers to instead transmit the value “UNK” in the UFI field. However, the FDA now states that importers have had ample time to familiarize themselves with this requirement and must therefore ensure that their valid, nine-digit DUNS number is provided in the entity number field. Beginning no earlier than July 24 CBP will reject entry lines of foods subject to the FSVP regulation when this requirement is not met.

For more information on this and other FDA issues, please contact FDA consultant Domenic Veneziano at (202) 734-3939 or via email.

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