Guide
FDA US agent, importer of record, and FSVP importer are three different jobs
Sellers treat the three titles as one American on file. FDA does not. The registration agent is a communications link. The importer of record is a Customs role. The FSVP importer is a food-safety role with its own consent statement.
Updated 2026-08-24
The short answer
The US agent on a foreign food facility’s registration acts as a communications link between FDA and that facility for routine and emergency contact. FDA will treat the agent’s statements as the facility’s. That is 21 CFR 1.227.
It is not, by itself, the importer of record at CBP, and it is not the FSVP importer. One person can hold more than one of these roles. The filings still have to name the right role in the right system.
What the registration agent is not required to do
The agent is not required to know the formula. FDA’s Q&A says the agent must be able to serve as the communication link because FDA will contact the agent in an emergency unless the registration lists another emergency contact.
The agent may be authorised to register the facility. The agent is not required to. Commercial sales, Amazon listings and warehouse contracts do not have to run through this person.
FSVP uses the same English words for a different job
Under the Foreign Supplier Verification Programs rule, a US agent or representative must be designated to serve as the FSVP importer when there is no US owner or consignee at the time of entry. That person is the importer of the food for FSVP purposes and must confirm the role in a signed statement of consent.
FDA’s FSVP guidance says, in as many words, that this FSVP agent serves a different role from the US agent named on the facility registration. The registration agent may also serve as the FSVP agent, but only if that person has signed the FSVP consent.
What Amazon sellers should put in which box
Amazon asking for “US agent” is usually the registration agent: name, US address, phone, email. Do not paste a customs-broker code or an FSVP importer name unless that is actually the person on the FDA registration.
If you need both roles covered, say so. They are billed as what they are. A year of registration US-agent service is $299. We do not treat that fee as FSVP importer work.
Common questions
Can my customs broker be all three?
Possibly, if the broker agrees in each system. Brokerage terms often cover CBP entry only. Get the FSVP consent and the FDA agent confirmation in writing.
If I am the US importer, am I automatically the registration agent?
No. FDA’s Q&A says a foreign facility may use its US importer as its US agent. “May” is not “is”.
Does naming a US agent satisfy FSVP?
No. FSVP is a separate importer duty with a signed consent when a US agent or representative is used as the FSVP importer.
Who does FDA call in an emergency?
The US agent on the food-facility registration, unless the registration specifies another emergency contact.
Does Amazon care which of the three I send?
Amazon’s field is Amazon’s. Sending the wrong person does not rewrite FDA’s three definitions. Send the registration agent if that is what they asked for.
Sources
- 21 CFR 1.227 — US agent as communications link; FDA treats representations by the agent as those of the foreign facility; commercial business need not run through the agent — ecfr.gov
- FDA, Questions and Answers Regarding Food Facility Registration (Seventh Edition), C.7 — who can be a US agent; importer may serve; agent need not know the product; FDA contacts the agent in an emergency unless another contact is listed — fda.gov
- FDA, FSVP draft guidance A.16–A.18 — FSVP US agent or representative is a different role from the registration US agent; signed consent required (21 CFR 1.500) — fda.gov
This guide is general information about three US-side roles that Amazon sellers often collapse into one, not legal advice, and it does not create a client relationship.
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