AI agents for business finance: what they can and can't do
What AI agents can do in bookkeeping, close, collections and compliance today, where a person must stay in charge, and how to judge a product.
The short answer
A Nigerian factory that manufactures, processes, packs or holds food for sale in the US must register with the FDA before its food is shipped, under 21 CFR Part 1, Subpart H. Registration is free, is done online, needs a US agent and a unique facility identifier, and must be renewed between 1 October and 31 December of every even-numbered year, including 2026. Food from an unregistered facility can be held at the port.
Why the registration sits with the Nigerian factory, not with you
Many diaspora importers assume that because they are the American business, the FDA paperwork is theirs alone. Food facility registration is the exception. The duty falls on the facility that makes or packs the food. Under 21 CFR Part 1, Subpart H, a foreign facility that manufactures, processes, packs or holds food for consumption in the United States must register before it begins doing so. The FDA's own registration page puts it the same way: facilities that manufacture, process, pack or hold food for US consumption must register, and renew every other year.
So if a factory in Ikeja mills and bags your elubo, or a workshop in Kano dries and packs your pepper, that site needs its own FDA registration number. You as importer cannot register on its behalf as if you were the producer, although you can help it through the process and act as, or arrange, its US agent.
The one exemption that trips people up
A foreign facility is exempt only if its food is sent to another foreign facility for further manufacturing or processing, including packaging, before export. The regulation says activity of a minimal nature, such as putting on a label, does not count as further processing. In practice this means the last Nigerian site that does real work on the food must register. If a Lagos trader buys bulk crayfish, grinds and packs it, the trader's premises are the facility. Farms, retail food establishments and restaurants are outside the definition.
What registration involves
| Item | What the rules say |
|---|---|
| Cost | no FDA fee for registration |
| How | electronically; the regulation has required electronic registration since 4 January 2020 |
| US agent | required for every foreign facility; must be physically present in the US, not just a mailbox or answering service |
| Unique facility identifier (UFI) | required since 1 October 2020; the FDA accepts a D-U-N-S number |
| Renewal | between 1 October and 31 December of each even-numbered year |
| Approval | none: registration is not an FDA approval of the facility or its food |
The UFI is the step that causes most delay. Dun & Bradstreet says a D-U-N-S number is free to request, normal processing can take up to 30 business days, and a paid expedite option exists. The facility applies with its legal name, address, phone, owner name, legal structure and industry. Start this before the first shipment is booked.
Choosing the US agent
The US agent is the FDA's contact point in the US for the facility. It can be you, a customs broker, a consultant or another US business, as long as it has a physical US presence. If you agree to be the agent for a supplier you do not control, be clear in writing about what you will forward and what you will not sign.
What happens without it
Food from a foreign facility that should be registered but is not can be held at the port of entry under section 801(l) of the Food, Drug, and Cosmetic Act until the facility registers. Registration also feeds other filings. Prior notice for each shipment asks for the manufacturer's registration number, and under the Foreign Supplier Verification Program rules the importer must give CBP a unique facility identifier on each entry line. A missing or lapsed number shows up quickly.
Holding a number tells the FDA where the food comes from; it is not a certificate of quality, and the regulation states that registration is not an FDA approval of the facility or its food.
Worked example: a renewal year
Example: a Nigerian spice processor first registered in March 2025. Because renewals run in even-numbered years, it must renew between 1 October and 31 December 2026, even though it registered less than two years ago. If it misses the window, its registration risks lapsing, and its next shipment in January 2027 risks being held at JFK. You, as importer, should ask for the renewed number in writing by mid-December.
Steps for you and your supplier
- Confirm which Nigerian site does the last real processing or packing; that is the facility to register.
- Get the facility a D-U-N-S number as its UFI.
- Agree who the US agent is and confirm that person or firm accepts the role.
- The facility registers online with the FDA and records the US agent and UFI.
- Ask for the registration number and the UFI, and give both to your customs broker for prior notice and entry.
- Put the October to December renewal window in your calendar for every even-numbered year.
For the filing that goes with each shipment, read FDA prior notice for food from Nigeria, and for your own duties as importer see FSVP importer duties. On the Nigerian side, exporters are also expected to register with NEPC; see how to register as an exporter with NEPC.
Where Pryme fits
Registration is between your supplier and the FDA, but you often end up paying for the D-U-N-S expedite or the agent fee. A Pryme Business Account opened from the US holds USD and NGN with local details for each, so you can pay the supplier in naira with Swap; the app shows the rate and the fee before you approve. See business multicurrency accounts.
Questions people ask
Does my Nigerian supplier need FDA registration?
Yes, if its site manufactures, processes, packs or holds the food sold in the US. The only foreign exemption is where another foreign facility does further real processing before export; labelling alone does not count.
How much does FDA food facility registration cost?
The FDA charges no fee. Consultants or US agents who handle it may charge their own fees.
Can I be the US agent for my supplier in Nigeria?
Yes, if you are physically present in the US and accept the role. A mailbox or answering service does not qualify.
When does FDA registration need renewing?
Between 1 October and 31 December of every even-numbered year, so the current window closes on 31 December 2026.
Sources
- eCFR: 21 CFR Part 1, Subpart H, Registration of food facilities (current text) · accessed Oct 2026
- FDA: Registration of food facilities and other submissions (12 Jan 2026) · accessed Oct 2026
- eCFR: 21 CFR Part 1, Subpart L, Foreign Supplier Verification Programs for food importers (current text) · accessed Oct 2026
- eCFR: 21 CFR Part 1, Subpart I, Prior notice of imported food (current text) · accessed Oct 2026
This article is general information, not financial, legal or tax advice. Products described are provided under the terms on this site and are subject to regulation and eligibility.