FDA Stories #016 — An Egyptian Dates Exporter's Prior Notice Had the Wrong FDA Registration Number

A dates processing and packing company in Aswan, Egypt, exported premium Medjool dates to specialty food stores in the United States. Their FDA food facility registration was current. Their labels were compliant. Their US Agent was responsive. On paper, they were a model exporter.

But the Prior Notice filings for their shipments — submitted by their US importer's customs broker — contained the wrong FDA registration number. The number belonged to a different Egyptian food facility in Cairo that the customs broker had on file from a previous client.

How it went undetected

Prior Notice filings are processed electronically through the FDA's system. The system checks whether the registration number exists and is active — it does not automatically verify whether the registration number matches the actual manufacturer of the food being imported. The Cairo facility's number was active, so the Prior Notice filings were accepted. For eight months, every shipment of dates was filed with a registration number that pointed to the wrong facility.

The error was discovered during an FSVP audit. The importer's FSVP records identified the Aswan facility as the supplier. The Prior Notice records identified the Cairo facility. The auditor flagged the discrepancy.

The fix

We corrected the Prior Notice data with the customs broker, providing the correct FDA registration number for the Aswan facility. We also created a Prior Notice data sheet for the facility — a single-page document with every data point the customs broker needs: facility name, FDA registration number, DUNS number, address, product codes, and US Agent contact information. The customs broker now uses this sheet for every filing.

Data errors in Prior Notice filings are more common than people realize. They happen because customs brokers handle thousands of entries and sometimes copy data from one client file to another. The manufacturer should provide their exact filing data to every importer and every customs broker in their supply chain — and verify periodically that the correct numbers are being used. fdabridge.com/contact.