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
Iru (fermented locust bean), ogiri and similar fermented seasonings are regulated by the FDA as ordinary food: the Nigerian maker must be FDA-registered, each commercial shipment needs prior notice, the US importer needs a supplier verification programme, and labels must meet US rules in English. Moist products sealed in jars or tins can also fall under the FDA's low-acid or acidified food rules, which have their own import alert for Nigeria.
What the FDA sees when it looks at iru
No US rule names iru, ogiri or dawadawa. They are foods, and the FDA applies the same framework it uses for any imported food. That framework has four parts: the facility, the shipment, the importer and the label. What makes fermented seasonings different is not the law but the hazards the law asks you to think about.
| Requirement | Who | Rule |
|---|---|---|
| Food facility registration | the Nigerian processor that ferments and packs | 21 CFR Part 1, Subpart H |
| Prior notice | whoever files for each shipment | 21 CFR Part 1, Subpart I |
| Foreign Supplier Verification Program | the US owner or consignee | 21 CFR Part 1, Subpart L |
| Labelling and allergens | whoever puts the product on sale | FDA labelling rules and the nine major allergens |
Hazards your supplier checks must cover
The FSVP hazard analysis under section 1.504 must cover biological, chemical and physical hazards and weigh how likely and how serious each is. For traditionally fermented seeds, sensible questions include:
- Biological: traditional fermentation is often done at ambient temperature, so how is contamination controlled and is the product dried or cooked after fermenting? The FDA's Nigeria import alerts include Salmonella (99-19) and filth (99-46).
- Mycotoxins: where the raw seed is melon seed, note that Nigerian melon seeds are on the red list of Import Alert 23-14 for aflatoxin.
- Chemical: added colour or preservative must be declared; Nigeria-listed alerts cover illegal or undeclared colours (45-02) and undeclared sulfites (99-21).
- Physical: grit, stones and packaging fragments.
Which of these apply depends on how your supplier makes the product. Ask for a description of each step, and keep it with the hazard analysis.
Dry, frozen or in a jar
The form you import matters. Dried, smoked or powdered seasoning in a sealed pouch is ordinary dry food. A moist paste or seasoning sealed in a jar or tin and kept at room temperature can be a low-acid canned food or an acidified food, and those need a scheduled process filed with the FDA. The FDA's Nigeria page lists Import Alert 99-37, for low-acid canned and acidified foods without filed scheduled processes. If your supplier jars iru in oil or brine, ask a food process authority whether it falls in that category before you order a pallet. Frozen product avoids that question but brings its own cold-chain costs; see frozen foods and cold-chain rules.
Labelling iru and ogiri for US shelves
The FDA does not pre-approve labels, so the label is your risk. The FDA's Food Labeling Guide sets out the basics:
- A statement of identity in English: a common or descriptive name such as "fermented locust bean (iru)" rather than iru alone.
- Net quantity in both metric and US units in the bottom 30% of the main panel, for example "Net Wt 7 oz (200 g)".
- An ingredients list in descending order by weight.
- Name and address of the manufacturer, packer or distributor, with "Distributed by" if it is you.
- Nutrition Facts unless an exemption, such as the small business exemption, applies and no nutrient claim is made.
- Country of origin, near the US name and address where one appears.
If any Yoruba, Hausa or Igbo wording appears on the label, every required statement must appear in both English and that language. Allergens need care: some dawadawa-style seasonings are sold made from soybeans rather than locust beans, and soybeans are one of the nine major allergens that must be declared. Read labelling Nigerian foods for US shelves.
Worked example: first order
Example: a Brooklyn grocer orders 400 pouches of dried iru, 100 g each, from an Ibadan processor, by air. The processor holds an FDA registration and a D-U-N-S number. The grocer's FSVP file has a written hazard analysis naming Salmonella and filth as hazards controlled by drying and sieving, and the processor's written description of the process. Because the grocer imports well under $1 million of food a year, it uses the very small importer route and holds a signed assurance from the processor. The broker files prior notice once the air waybill exists. The pouches are printed "Fermented locust bean (iru), Net Wt 3.5 oz (100 g), Product of Nigeria".
Questions to ask the processor
- Which seed is used, where it is sourced, and how it is stored before fermenting?
- How long is it fermented, and is it boiled, dried or smoked afterwards?
- What is added: salt, ash, colour, preservative, oil?
- How is the packing area cleaned, and is there a written procedure?
- Has any FDA, NAFDAC or other authority inspected the site, and can you see the report?
Before reordering, check the FDA Nigeria country page for new import alerts that could touch the product. See also spices and suya pepper rules.
Where Pryme fits
Small seasoning makers in Nigeria usually want naira. A Pryme Business Account opened from the US holds USD and NGN with local details, and you can pay in naira after a Swap; the app shows the rate and the fee before you approve. A verifiable receipt helps your FSVP file show what you bought and when.
Questions people ask
Can I import iru to the US?
Yes, as a food. The Nigerian processor must be FDA-registered, each commercial shipment needs prior notice, and you need a supplier verification programme and a compliant English label.
Is ogiri allowed in America?
There is no specific ban on ogiri. It is treated as food, so the same registration, prior notice, FSVP and labelling rules apply, and the FDA can detain any shipment that appears adulterated or misbranded.
Does iru in a jar need special FDA approval?
A moist seasoning in a sealed jar kept at room temperature may be a low-acid or acidified food, which needs a scheduled process filed with the FDA. Check before shipping.
What English name should I put on iru?
Use a common or descriptive name such as "fermented locust bean (iru)", so a US buyer knows what it is.
Sources
- 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 H, Registration of food facilities (current text) · accessed Oct 2026
- FDA: Food Labeling Guide (guidance revised Jan 2013; landing page current as of 15 Jan 2025) · accessed Oct 2026
- FDA: Import alerts by country, Nigeria (posted 21 Oct 2026) · accessed Oct 2026
- FDA: Food allergies (content current as of 11 Mar 2026) · 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.