JAS USA COMPLIANCE

News & Insights from JAS Worldwide Compliance

JAS Forwarding (USA), Inc.

6165 Barfield Road
Atlanta GA, 30328
United States
Tel: +1 (770)688-1206
Fax: +1 (770)688-1229

FDA Registration

November 1, 2022

The Food and Drug Administration’s (FDA) Food Facility Registration Renewal is from Oct. 1 through Dec. 31, 2022. All food facilities must submit a timely renewal. Failure to do so will cause product to be denied entry into the U.S.

Importantly, a DUNS number for the food facility location must be provided as part of the FDA renewal (a DUNS number for the corporate headquarters is not sufficient!). In the past, FDA has been flexible, allowing the use of “pending” if a DUNS’ number could not be obtained. FDA will no longer offer such flexibility.

As of October 1, the FDA will open its portal where food facilities must renew their food facility registrations. The window for renewal will run until December 31. All food facilities in your supply chains must submit a timely renewal. Failure to do so will cause product to be denied entry into the U.S.

This time, every registrant must have a DUNS number associated with the physical location of the food facility (a DUNS number for the corporate headquarters is not sufficient!). The FDA will no longer accept the use of “pending” in lieu of a valid DUNS number.  

A special warning: the name and contact information on the FDA food facility registration must exactly match the DUNS number contact information. If not, the registration may be cancelled. For example, if the FDA registration identifies “ABC Manufacturing” at “123 Main Street,” while the DUNS number info is listed as “ABC Manufacturing LLC” at 123 Main St.,” the registration will be denied. The two must be an exact match in every way.

Renewal Link
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Latest News

Forced Labor Focus

The recent June 12, 2024, Federal Register notice added three entities to the UFLPA Entity List showing increasing focus on three additional commodities. The entities which were added are suspected of working with the Xinjiang Uyghur Autonomous Region to recruit, transport, transfer, harbor or receive forced labor or Uyghurs, Kazakhs, Kyrgyz, or members of other persecuted groups out of the Xinjiang Uyghur Autonomous Region.

The areas of increased focus include shoe and shoe materials, frozen seafood, vegetables, quick frozen convenience food and other aquatic food, and electrolytic aluminum, graphite carbon, and prebaked anodes.

To read more, check out the full register notice linked below.

Fines with disclosure

On June 24, 2024, the Assistant Secretary of Commerce, Matthew S. Axelrod signed a settlement agreement with an exporter for violations of EAR. The violations occurred because of forty-two different shipments over the course of 4 years which were classified under ECCNs 1C353. These instances were subject to export licenses, but no licenses were obtained prior to exportation.

The exporter has a compliance team and upon recognition of the issue, submitted a voluntary self-disclosure. To read more details, check out the link below.

BIS imposed a civil penalty of $44,750 for violations of the antiboycott provisions of the Export Administration Regulations (EAR)

On June 3, 2024, the BIS imposed a civil penalty of $44,750 for violations of the antiboycott provisions of the Export Administration Regulations (EAR).  In the press release, Assistant Secretary for Export Enforcement, Matthew S. Axelrod said “Our antiboycott rules against furnishing prohibited information and failing to report boycott-related requests apply with the same force even when another U.S. company is the one making the information requests.”  He goes on to say “U.S. companies are reminded to be vigilant in examining all transaction documents, regardless of the source, to ensure terms and conditions comply with our antiboycott rules.”

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