Verification Activity Strategy
Ensuring Your Foreign Suppliers Control Hazards—Not Just Claim To
Published by FSVP SERVICES | A Service by Consultare Inc. Group – A Compliance Company
Under the FDA’s Foreign Supplier Verification Program (FSVP), U.S. importers must verify that foreign suppliers consistently control hazards associated with their products.
Verification is not paperwork; it is a risk-based, evidence-driven strategy that confirms the supplier’s preventive controls are effective in real-world conditions.
A well-designed Verification Activity Strategy determines what you verify, how you verify it, how often, and why the selected verification activities are scientifically and regulatory justified.
This approach protects public health, supports defensible compliance, and ensures imported foods are produced under conditions delivering equivalent U.S. safety standards.
This guide outlines the essential components of an effective Verification Activity Strategy aligned with 21 CFR 1.506–1.510, Codex verification principles, and globally recognized food safety practices.
Verification Activity Strategy Checklist
✔ Establish Risk-Based Verification Requirements
- Match the product risk and identified hazards with appropriate verification measures
- Determine activities based on severity, likelihood, and supplier historical performance
- Prioritize high-risk ingredients, vulnerable populations, and high-risk process steps
- Incorporate scientific evidence, regulatory enforcement history, and audit outcomes
✔ Select Verification Activity Types
- Document Reviews: Assess HACCP/HARPC plans, process controls, and validation data
- Product Testing: Verify microbiological, chemical, or allergen compliance
- On-Site Supplier Audits: Confirm operational controls, sanitation, and training
- Corrective Action Assessments: Validate root-cause processes and preventive measures
- Certification Verification: Review GFSI, ISO 22000, or regulatory inspection reports
- Ongoing Performance Monitoring: Track deviations, nonconformance, and trend data
✔ Define Frequency and Intensity of Verification
- Set time-based intervals proportional to the supplier’s risk level
- Determine trigger-based reviews for changes, incidents, or new products
- Increase frequency after product failure, process modifications, or audit findings
- Decrease frequency only with documented evidence of sustained compliance
✔ Scientific Justification & Documentation
- Provide written rationale linking hazard risk → control effectiveness → verification choice
- Reference validated methods, regulatory expectations, and industry standards
- Record the basis for sampling plans, laboratory methods, or testing frequency
- Ensure documentation is structured, traceable, and inspection-ready
✔ Verification Method Evaluation
- Confirm that labs have appropriate accreditation and validated methodologies
- Review corrective actions, retesting results, and supplier responses to deviations
- Verify that implemented controls are maintained—not assumed from certificates
- Reassess supplier performance based on new hazards, recalls, or enforcement actions
✔ Corrective Actions for Failures
- Define decision thresholds for nonconforming results
- Establish escalation pathways (testing → audit → suspension)
- Require documented preventive actions to prevent recurrence
- Maintain records of supplier improvement efforts and importer decision-making
Support for Verification Activity Strategy
Food Safety Systems provides comprehensive services to help importers design and execute FSVP verification strategies that meet FDA expectations:
- Customized verification plans based on product and supplier risk
- Scientific justification templates for verification decisions
- Audit protocols aligned with Codex, GFSI, and FDA requirements
- Laboratory testing programs with accredited partners
- Trending and deviation-tracking systems
- Managed FSVP services for high-risk product categories
- On-site or virtual consultation for importer teams
Let our experts help you build a defensible verification strategy that aligns with your products, suppliers, and operational realities.
Ready to Build Your Verification Strategy?
Create a risk-based, defensible, and inspection-ready FSVP program.
Request Verification Activity Strategy like this…
- Book Your Free FSVP Consultation
- Request a Sample Verification Strategy Template
- Get a Custom Proposal for Your Imported Products
This content is adapted from publicly available requirements and guidance related to the Foreign Supplier Verification Program (FSVP), including sections of 21 CFR Part 1 Subpart L, FDA compliance guidance, Codex Alimentarius risk analysis principles, and industry best practices used in global food safety programs.
For regulatory compliance, importers must follow the officially published requirements applicable to their region and product type, as issued by the FDA or other competent authorities. This material is intended for educational and informational purposes and does not substitute for review of official regulations.
FSVP Services is an independent service provider and is not affiliated with, endorsed by, or certified under any specific FSVP, FDA, Codex, or GFSI program owner.
References to FDA regulations, Codex principles, or GFSI frameworks are for informational purposes only and do not imply endorsement, approval, or partnership by any regulatory body, program owner, or certification authority.
Fees and Subscriptions
Optional Add-On Modules (Subscribe per user/month)
| Add-On Feature | Description | Price/User/Month |
|---|---|---|
| Supplier Approval Management | Manage organization’s legal records and entity information | $59 |
| Products Management | Organize product specifications, attributes, labeling, packaging, testing, and category risk | $59 |
| Customer Requirements Management | Maintain customer requirements documentation for traceability | $59 |
| Food Fraud Vulnerability Assessment (FFVA) | Document Food Fraud Vulnerability Assessments and mitigation plans | $69 |
| Corrective and Preventive Action (CAPA) Management | Track and resolve non-conformities, audit findings, and follow-up tasks | $49 |
| E-Forms (up to 10) | Digitized monitoring and verification forms | $99 |
| Custom Digital Form | One-time setup for custom form workflows | $300/form |
| Risk Assessment | Build and manage product- or category-specific hazard evaluations | $59 |
| Internal Audit Module | Schedule and track internal audits, findings, and improvements | $59 |
Custom Packages Available
- • Starts at $649 per month per facility, with core modules and certain add-ons included
- • Ideal for medium to large enterprises, corporations, and multi-facility organizations
Ideal For:
- • U.S. Importers under FSVP
- • Foreign Suppliers using U.S. Agents
- • Food Brands entering the U.S. market
- • Regulatory Consultants managing multiple importers
- • Warehouses or co-packers verifying international shipments
