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
Under the FDA's Foreign Supplier Verification Program (21 CFR Part 1, Subpart L), the US owner or consignee of imported Nigerian food must have a written programme for each food: a hazard analysis, an evaluation and approval of the supplier, verification activities, corrective actions and records kept for at least two years. Very small importers, with under $1 million a year in human food (inflation-adjusted), can instead rely on written supplier assurances renewed at least every two years.
Who the FSVP importer is
The FSVP rules put the food safety question on the American side of the deal. Section 1.500 defines the importer as the US owner or consignee of the food at the time of entry. If there is no US owner or consignee, it is the US agent or representative of the foreign owner, confirmed in a signed statement of consent. A customs broker who only files paperwork is not the importer unless it owns or receives the goods.
So if you buy garri, ogbono or snacks from Lagos and they are shipped to your warehouse in Houston, the programme is yours. For each entry line you must give CBP your name, email address and a unique facility identifier the FDA accepts, under section 1.509.
Foods outside the programme
- small, non-commercial quantities for personal consumption that are not sold;
- food for research or evaluation, labelled as such, in small quantities and not sold;
- fish and seafood, and juice, from suppliers complying with the FDA's seafood or juice HACCP rules (parts 123 and 120), which carry their own importer checks;
- certain alcoholic beverages, food transshipped through the US, and food imported for processing and export without sale; and
- meat, poultry and egg products under USDA jurisdiction.
Low-acid canned food is a partial case: the importer verifies that it was produced under part 113 for the hazards that part controls and runs a full programme for the rest.
The five parts of a full programme
| Element | Section | What you do |
|---|---|---|
| Hazard analysis | 1.504 | write down the biological, chemical (including radiological) and physical hazards for each food, including economically motivated adulteration, and judge their likelihood and severity |
| Supplier evaluation | 1.505 | consider who controls each hazard and the supplier's record, including FDA warning letters, import alerts, test results and audits; approve in writing; reevaluate when new information arrives and at least every three years |
| Verification | 1.506 | import only from approved suppliers; pick onsite audits, sampling and testing, or records review, and how often |
| Corrective action | 1.508 | act promptly if a supplier is not compliant, up to dropping it; document what you did |
| Records | 1.510 | signed and dated, English translation on request, retrievable within 24 hours, kept for at least two years |
The hazard analysis can draw on another entity's analysis if you review and document it. If you conclude a food has no hazard needing a control, sections 1.505 and 1.506 do not apply, but the written analysis is still required.
When an onsite audit is required
Where the supplier controls a hazard with a reasonable probability of serious adverse health consequences or death, section 1.506(d)(2) calls for an onsite audit by a qualified auditor before the first import and at least once a year, unless you make a written determination that other verification is adequate. The supplier and its own staff cannot do your verification, except sampling and testing, and the verifier cannot be paid according to the results.
Why it matters for Nigerian food in particular
The supplier evaluation must look at import alerts, and the FDA's page for Nigeria listed 14 active ones when it was posted on 21 October 2026, covering mycotoxins, Salmonella, filth, pesticides, heavy metals, undeclared colours and sulfites and misbranding. Import Alert 23-14 names Nigerian shelled peanuts and melon seeds for aflatoxin. An FSVP for egusi that ignores aflatoxin would not stand up. See what FDA import alerts mean for Nigerian products.
The very small importer route
Many diaspora food businesses qualify. Section 1.500 defines a very small importer of human food as one whose sales plus US market value of human food imported, made or held averaged less than $1 million a year, adjusted for inflation, over the three years before the year in question, counting subsidiaries and affiliates. For animal food the figure is $2.5 million.
- Document your eligibility before you first import as a very small importer, and again by 31 December each year.
- You are exempt from the full hazard analysis, evaluation, verification, corrective action and records sections.
- You must still meet sections 1.502 and 1.503 (including using a qualified individual) and identify yourself at entry under section 1.509.
- Before importing, and at least every two years, get a written assurance from each Nigerian supplier that it meets the FDA food safety rules that apply to it.
Worked example
Example: an Atlanta grocery imported $280,000 of Nigerian food in 2023, $350,000 in 2024 and $410,000 in 2025, and has no affiliates. The three-year average is $346,667, well under $1 million, so for 2027 it can use the very small importer route (the three-year window ends one year before the calendar year in question). It still needs a signed assurance from each supplier dated within two years, kept on file.
Steps to set up a programme
- List every food and every Nigerian supplier; check each supplier has an FDA registration number.
- Decide whether you are a very small importer and document the calculation.
- Name a qualified individual who can read the records your suppliers send.
- Write the hazard analysis and supplier evaluation, or obtain written assurances if you qualify.
- Agree verification with suppliers: lab tests by an accredited laboratory, records, or audits.
- Keep everything for at least two years in a form you can produce within 24 hours.
Your supplier's side is covered in food facility registration for Nigerian suppliers.
Where Pryme fits
FSVP records are full of supplier invoices, certificates and payments. A Pryme Business Account holds USD and NGN, and a verifiable receipt or statement from VerifyDoc.ai lets an auditor confirm a payment record is unaltered. The Compliance agent can prepare reminders for assurance renewals, with a person approving.
Questions people ask
Who is the FSVP importer for Nigerian food?
The US owner or consignee of the food when it enters. If there is none, the foreign owner's US agent, confirmed in writing, is the importer.
Do small importers need an FSVP?
Yes, but an importer averaging under $1 million a year in human food (inflation-adjusted) can use the modified very small importer route, based mainly on written supplier assurances every two years.
Does FSVP apply to stockfish and dried fish?
Not the full FSVP if the supplier complies with the FDA seafood HACCP rule; the importer instead has seafood-specific verification duties under 21 CFR 123.12.
How long must FSVP records be kept?
At least two years after they are created or received, and records of procedures for two years after their use ends.
Sources
- eCFR: 21 CFR Part 1, Subpart L, Foreign Supplier Verification Programs for food importers (current text) · accessed Oct 2026
- FDA: Import alerts by country, Nigeria (posted 21 Oct 2026) · accessed Oct 2026
- FDA: Import Alert 23-14, detention without physical examination of food products due to the presence of mycotoxins (published 22 Jun 2026) · accessed Oct 2026
- eCFR: 21 CFR Part 1, Subpart H, Registration of food facilities (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.