William F Beadle - Comment

In the case of importing food, will the FDA contact the importer of record or the manufacturer/processor when records are needed? The importer of record has taken possession of the product that is being imported and the manufacturer/processor has no direct-obligation to allow FDA access to documents. If known that this will be importer of record responsibility to provide, importers could include this in contracts with the manufacturer/importer. My company uses around 200 different suppliers around the world so this would greatly effect our business. All charges that occur when FDA examines a shipment is our responsibility so we would much rather be the one responsible in providing these documents since it is part of the service we offer. Often, the manufacturer/processor does not want to have to deal with the importing aspects. Maintaing records for 2 years is not a big a deal at all since all documents are required for longer then this by the IRS.