This FDA Story is an illustrative, anonymized composite created for education. It is not a claim about a named company or a specific FDA enforcement record.
A family-owned manufacturer of jarred sauces and pickled vegetables had shipped to the United States for six years. A local consultant registered the facility in its first year, named a US Agent, and handled the 2022 and 2024 renewals. The company paid the consultant's invoice each time and never logged in to FDA's systems itself. In 2025 the consultant closed the business. Nobody at the manufacturer thought about FDA again until a US customer placed a large order for January delivery.
Everyone assumed someone else had renewed
In November 2026 the export manager saw a trade-press reminder about the renewal deadline. She asked the US importer, who replied that renewal was the manufacturer's responsibility. She emailed the former consultant and received no reply. The company did not know the FDA Industry Systems login, did not have the registration PIN, and had only an old PDF showing the registration number. The team decided the consultant had probably renewed for two years in 2024 and that nothing was urgent.
That assumption was wrong. Food facility registrations do not renew on a two-year schedule from the last filing. They must be renewed in every October-to-December window of an even-numbered year, and FDA considers registrations that are not renewed by December 31, 2026 to be expired.
The January container
The order shipped in mid-December. The importer's broker filed Prior Notice in January using the registration number from the old PDF. That registration was no longer valid. Food from a foreign facility that is not registered as required is held at the port of entry until the facility registers, so the container was held. Demurrage and storage charges started to accumulate, and the US customer began asking about penalty clauses for late delivery.
Getting back into compliance
With the old registration expired, the manufacturer could not simply renew. It had to submit a new registration from an account it controlled. That meant a DUNS number whose legal name and address matched the facility exactly, and a US Agent who would actually confirm the appointment. The DUNS record still showed the factory's previous address from before a move, so it had to be corrected first. Each step was routine. Doing them while a container sat at the port was not.
Once the new registration was in place, the importer's broker resubmitted Prior Notice with the new number and asked for the hold to be resolved. The shipment cleared, more than two weeks late. The manufacturer also had to send the new registration number to every US customer, update its export documents, and correct product records that still cited the old number.
What went wrong
- The registration was effectively owned by a third party, and the company had no independent access.
- No one inside the company owned the renewal date.
- The team relied on an assumption instead of a renewal confirmation.
- The DUNS record had drifted out of date after the facility moved.
- The US Agent role had ended with the consultant's business, and nobody noticed.
The lesson
Renewal is easy when access, data and the agent are in order, and very hard to fix after December 31. Ask for proof of every renewal, keep the registration number and access in company hands, and check the DUNS record whenever anything about the facility changes. If your current provider has gone quiet, read our guide to renewing when you are locked out of your FDA account, and see what happens after the renewal deadline. FDABridge's renewal and US Agent transfer service exists for exactly this situation.