A shrimp processing facility outside Ho Chi Minh City had been exporting to the United States for six years. Regular shipments. No problems. A good relationship with their American importer.
Then a 40-foot reefer container was held at the Port of Los Angeles. The FDA's system flagged it. The reason: the facility's FDA food facility registration was no longer active.
What happened
FDA food facility registrations must be renewed every two years during the October–December window of even-numbered years. The facility's previous compliance provider — a company they found online — had handled the original registration in 2020. They charged $1,200 for what is a free government filing. They never mentioned renewal.
The 2022 renewal window opened on October 1 and closed on December 31. The facility never received a reminder. The FDA does not send renewal notices — the burden is entirely on the registrant. On January 1, 2023, the registration went inactive.
For fourteen months, the facility continued to export shrimp, unaware that their registration had lapsed. Every shipment during that period entered the US on borrowed time. The moment the FDA's PREDICT system flagged the container in Los Angeles, it was over.
The cost
The detained container held $38,000 worth of frozen shrimp. Demurrage charges at the port started accumulating at $250 per day. The importer was furious. The factory owner flew to Ho Chi Minh City from his vacation to deal with the crisis.
We received the call on a Thursday afternoon. By Friday morning, we had acquired a new DUNS number (the old provider had registered it under their own account, not the factory's), completed a new FDA food facility registration, and designated ourselves as US Agent. By Monday, the registration was active in FDA's system.
The container was released on Tuesday. Total hold time: 6 days. Total demurrage: $1,500. The shrimp survived because the reefer unit kept running. It could have been much worse.
The lesson
Your FDA registration is not a one-time filing. It expires. And no one will remind you. If you do not know when your next renewal is due, or if you are not sure your current provider is tracking it — contact us at fdabridge.com/contact. We track every renewal deadline for every client, and we send reminders 90 days before the window opens.