January 1, 2019, was to be the opening of the second annual registration period for Voluntary Qualified Importer Program (VQIP) applications. But to allow importers extra time to submit their Notice of Intent to Participate and their completed VQIP applications for the Fiscal Year 2020 benefit period – FDA has opened the portal three months early. And this time, importers should be able to apply throughout the period. VQIP is a voluntary, fee-based program that provides expedited review and import entry of human and animal foods into the U.S. for participating importers. The portal is scheduled to be open each year between January 1 and May 31, with the first having opened earlier this year. However, because no certification bodies were yet accredited, FDA had not anticipated that importers would be able to apply during that application cycle. Certification bodies, (also known as third-party auditors) which receive their accreditation under the Accredited Third-Party Certification Program, are needed to conduct food safety audits of foreign food facilities and issue certifications that importers need to participate in VQIP. But it was not until early February that FDA recognized the first accreditation body. Since then, a number of accreditation bodies have been recognized by the agency, as listed on the FDA Public Registry of Recognized Accreditation Bodies. To participate and reap the benefits of VQIP, importers must meet eligibility criteria and pay a user fee that covers cost associated with the FDA’s administration of the program – all of which we discussed in our February 14, 2018, newsletter, VQIP Now Live – What Does It Mean to You? – which still provides a current overview for those interested in the program. In brief, VQIP participation enables importers to import their products to the U.S. with greater speed and predictability, avoiding unexpected delays at the point of import entry. Additionally, because participation requires robust management of the safety and security of the supply chains, FDA expects that consumer also will benefit. The initial step is the submission of a notice of intent to participate through the creation of an account on the FDA Industry Systems website. Once you have an account, selecting VQIP under the FSMA Program options will take you to the VQIP Application Page, which will take you through the steps. As the portal was closing last year, FDA provided additional information on what importers can do to prepare early for the next year’s application period. With an extra three months application time, this page also can provide some general information on simply getting started in the application process. FDA has also developed a complete step-by-step guide, Submission of VQIP Application User Guide, detailing each step of the process with instructions, information/attachments needed, and screen prints of each webpage and section. Once submitted, you can check the status of your application at http://www.access.fda.gov. Applications made during open-portal period receive consideration for the following benefit year. You can also submit a notice of intent to participate in VQIP for the 2019 application cycle by setting up an account via the FDA Industry Systems website. Time will tell how much benefit the VQIP program really brings to the food industry. Skeptics of this program say that you are so unlikely to have your product stopped by FDA during importation that the VQIP offers little benefit. My personal view is that in time FDA will focus more on importers and risks associated with imported foods, so the benefits will likely increase over time. Another whole spin of the VQIP is whether it will offer a business advantage to foreign facilities that have the VQIP status. Domestic companies looking to import products and minimize risks could give preference to those with VQIP as suppliers of choice. However, the program is too early to really know if the standards needed to qualify for VQIP will raise the bar in terms of food safety. If you want to know more, additional information also is available on the VQIP webpage, and questions can be submitted to the VQIP Importer’s Help Desk by phone, 1-301-796-8745, or email, [email protected]. About The Acheson Group (TAG) Led by Former FDA Associate Commissioner for Foods Dr. David Acheson, TAG is a food safety consulting group that provides guidance and expertise worldwide for companies throughout the food supply chain. With in-depth industry knowledge combined with real-world experience, TAG’s team of food safety experts help companies more effectively mitigate risk, improve operational efficiencies, and ensure regulatory and standards compliance. Learn more at: www.AchesonGroup.com
