When foreign food manufacturers research FDA food facility registration requirements, they encounter the term 'Unique Facility Identifier' — UFI — in the FDA's regulations implementing the Food Safety Modernization Act. The UFI is the identifier that the FDA requires in food facility registration submissions to uniquely identify the physical facility being registered. The DUNS number, issued by Dun & Bradstreet, currently serves as the UFI accepted by the FDA. Understanding the distinction between the UFI concept and the DUNS number that implements it helps foreign manufacturers understand both the requirement and its practical implications.
What the UFI requirement means in practice
FSMA directed the FDA to require a Unique Facility Identifier in food facility registrations. The FDA designated the DUNS number as the UFI. This means that a foreign food facility cannot complete an FDA registration submission without a valid DUNS number that identifies that specific physical location. The UFI/DUNS must be current and must match the facility information on the registration. It is not a field that can be left blank or filled with a placeholder — the FDA's registration system requires a valid DUNS number to process the submission. Facilities that are part of a larger corporate group may have multiple DUNS numbers if the parent company has registered different sites or legal entities separately; the correct DUNS to use is the one assigned to the specific physical facility being registered, not the parent company's DUNS.
Why DUNS numbers can be wrong even when they exist
A common problem for foreign food manufacturers is discovering that a DUNS number already exists for their facility — obtained years earlier for banking, export credit, or business directory purposes — but the information in the DUNS record is outdated. The legal business name may have changed. The physical address may have moved. The phone number or primary contact may no longer be accurate. The FDA validates the DUNS number it receives against the D&B database; if the name and address in the DUNS record do not match the name and address in the FDA registration, the validation fails. Before using a pre-existing DUNS number for FDA registration, the D&B record should be reviewed and corrected if necessary — which D&B allows through their website.
How the UFI interacts with traceability requirements
FSMA's Food Traceability Rule — which applies to a defined list of higher-risk foods including leafy greens, certain cheeses, and raw shell eggs — requires that food chain records include a traceability lot code and the source of the food at each step in the supply chain. The FDA's traceability requirements for foreign shippers include the ability to identify the specific facility where food was packed or held using an identifier that can be traced back to the facility's FDA registration. The FEI number — issued after registration — serves this traceability identification function. The DUNS/UFI is what gets the facility registered; the FEI is what appears in traceability records and Prior Notice submissions going forward.
Keeping the UFI record current
Once a food facility is registered, the DUNS number on file with the FDA should be maintained to reflect the current legal name and address of the facility. If the facility moves, changes its legal name, or undergoes a corporate restructuring that affects the legal entity, both the DUNS record and the FDA registration must be updated to remain consistent. An FDA registration that references a DUNS number with outdated information creates an inconsistency in the FDA's records that can surface during import reviews or inspections.
How FDABridge manages UFI and DUNS for registered facilities
FDABridge verifies DUNS records against FDA registration data for all clients and monitors both for changes that require synchronization. We handle DUNS acquisition, verification, and correction as part of our food facility registration service. Visit fdabridge.com/food to learn more, or fdabridge.com/apply/food to get started.
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