Coffee Import Compliance Checklist: 15 Things Your Importer Should Be Doing But Probably Isn't
By Caffé Premium
Most green coffee importers are doing the minimum.
They're filing the CBP entry. They're getting the coffee through the port. And they're stopping there.
What they're not doing is the full stack of what a genuinely compliant, genuinely transparent import partner should provide: the FSVP guidance that protects you from FDA audits, the documentation that proves your coffee is what it claims to be, the moisture protection that keeps your green coffee alive through a six-week ocean voyage, and the quality of communication that lets you run your business instead of chasing shipment updates.
This is not a theoretical coffee import compliance checklist. These are the 15 things that separate a compliant, professional import operation from one that is leaving you exposed - legally, operationally, and commercially.
Print it. Take it into your next conversation with your current importer. Ask them about every item. Their answers will tell you what you need to know.
Caffé Premium, through InGain LLC, covers all 15 items on this checklist as standard. If you find items your current importer cannot confirm, we are ready to talk.
Category 1: FDA & CBP Compliance
✔ 1. Supplier FDA Facility Registration Verified Before Every Order
What it is: Every foreign facility that packs or holds food for US consumption must hold an active FDA facility registration, renewed every two years. Your importer should verify registration status before initiating any shipment from a supplier.
Why it matters: If your shipment arrives and the supplier's FDA registration is expired or missing, the FDA can place a hold on your cargo at the port. Resolving a hold takes days to weeks and costs real money in storage and detention fees - on top of lost production time.
✓ Your importer IS doing this if: They can provide the FDA facility registration number for every supplier they use. They can confirm it was current at the time of shipment.
✗ They probably AREN'T if: They say "our suppliers are all registered" but cannot produce the registration number or confirm the renewal date.
✔ 2. DUNS Number Included in Every CBP Entry Filing
What it is: Since July 2022, FSVP importers must provide the foreign supplier's DUNS (Data Universal Numbering System) number in their CBP entry filing. The DUNS number is a nine-digit business identifier issued by Dun & Bradstreet.
Why it matters: Missing or incorrect DUNS numbers trigger FDA flags on the entry. Flagged entries are more likely to be selected for examination and can result in delays.
✓ Your importer IS doing this if: The DUNS number appears on your CBP entry documentation. Your importer can tell you what it is without looking it up.
✗ They probably AREN'T if: They've never heard of the DUNS requirement. Or they say "that's the customs broker's job" without being able to confirm it's actually being done.
✔ 3. ISF Filed Before Vessel Departure - Not on Arrival
What it is: The Importer Security Filing (ISF) must be submitted to CBP before the vessel departs the last foreign port. It requires specific data elements including supplier name and address, country of origin, and HTS code.
Why it matters: Late ISF filing results in fines of up to $5,000 per violation. There is no grace period. The deadline is before departure - not 48 hours before US arrival, as some brokers misstate.
✓ Your importer IS doing this if: Your ISF confirmation is timestamped before the vessel's departure from the last foreign port. Your importer confirms this proactively.
✗ They probably AREN'T if: You received an ISF fine and your importer called it "a routine issue." Or you've never been shown ISF confirmation timestamps at all.
✔ 4. FDA Prior Notice Filed Correctly for Every Shipment
What it is: The FDA requires Prior Notice for every commercial food shipment entering the US. For ocean freight, this must be filed at least 8 hours before the vessel's scheduled arrival at the US port.
Why it matters: A shipment without compliant Prior Notice can be refused entry or held for FDA review. The filing must include accurate product description, country of origin, supplier details, and US recipient.
✓ Your importer IS doing this if: Your entry documentation includes a Prior Notice confirmation number. Your importer files this as a standard part of every shipment not on request.
✗ They probably AREN'T if: Your importer has "delegated" Prior Notice to your customs broker, neither of whom has confirmed it's being filed accurately and on time.
✔ 5. FSVP Guidance Provided - You Know Your Obligations
What it is: As the US buyer (owner or consignee of imported food), you are the FSVP importer. You must have a documented hazard analysis, a supplier evaluation, and ongoing verification activities. Your importer cannot hold these obligations for you but a good one will guide you through them.
Why it matters: The FDA is actively auditing green coffee importers for FSVP compliance. An importer who lets you sign off on a shipment without confirming your FSVP program is in place is leaving you exposed to Form 483 citations, import alerts, and civil penalties.
✓ Your importer IS doing this if: They have walked you through your FSVP obligations. They have provided hazard analysis templates or guidance. They have shared supplier documentation that supports your supplier evaluation and verification activities.
✗ They probably AREN'T if: They've never mentioned FSVP. Or they say "we handle compliance" without clarifying that FSVP importer status is yours, not theirs.
Category 2: Quality Documentation
✔ 6. Certificate of Analysis (COA) Provided Before You Commit
What it is: A COA documents the green coffee lot's moisture content, screen size distribution, defect count, Q grade (if applicable), water activity, and OTA test result. It should be available before your order is confirmed not after the coffee has shipped.
Why it matters: You cannot make an informed sourcing decision without seeing the specs. A COA received after shipment is a transparency failure - the decision has already been made before you had the information you needed.
✓ Your importer IS doing this if: The COA is part of the quotation package. You review moisture, screen size, defect count, and crop year before placing the order.
✗ They probably AREN'T if: You receive the COA after the coffee ships, or only on request, or not at all. "Our coffee is high quality" is not a substitute for documented specifications.
✔ 7. Green Analysis Report Available - Not Just Marketing Language
What it is: A green analysis report documents the physical attributes of the lot: bean size distribution, color, defect classification (primary and secondary), and foreign matter. Distinct from and complementary to the COA.
Why it matters: The gap between "Grade 1" as a claim and Grade 1 as a documented reality is where quality disputes happen. A green analysis report provides the evidence base for the grade claim.
✓ Your importer IS doing this if: They can produce the green analysis report for any lot they're offering. The report is issued by a third party, not self-certified by the supplier.
✗ They probably AREN'T if: Grade claims are unsubstantiated. "This is premium Grade 1" without documentation is a marketing statement, not a quality guarantee.
✔ 8. OTA Testing Results Available on Request
What it is: Ochratoxin A (OTA) is a mycotoxin produced by Aspergillus moulds that can develop in green coffee stored at high moisture or water activity. The EU maximum limit is 10 ppb in roasted coffee. US buyers with EU export plans or rigorous food safety programs should confirm OTA levels.
Why it matters: OTA is a biological hazard that should be addressed in your FSVP hazard analysis. If your importer cannot provide OTA test results, you have no third-party verification of this specific food safety risk.
✓ Your importer IS doing this if: OTA test results are available for current-crop lots, or they can arrange testing through an accredited laboratory on request. Results are consistently below 5 ppb for their standard lots.
✗ They probably AREN'T if: They've never offered OTA testing. Or they say it's "not an issue" without evidence. Or they provide only supplier self-declarations rather than accredited lab results.
✔ 10. Moisture Protection During Transit - GrainPro or Hermetic Bags
What it is: Standard jute bags are porous. Green coffee in jute alone is vulnerable to moisture absorption during ocean transit, particularly in LCL shipments where temperature and humidity fluctuations are common. GrainPro liners or hermetic bags create a moisture barrier inside the jute outer bag.
Why it matters: Moisture absorbed during transit can push green coffee above 12% - degrading quality, creating OTA risk, and invalidating the moisture reading on the origin COA. Moisture-related quality disputes are one of the most common post-arrival issues in green coffee importing.
✓ Your importer IS doing this if: They specify GrainPro or hermetic liner as standard, or offer it as an option for specialty lots. They can confirm bag specification at order time.
✗ They probably AREN'T if: They can't tell you what bag specification they use. Or they say "it's never been an issue" - which is not the same as saying "we protect your coffee."
Category 3: Transparency and Service
✔ 11. Itemized, Transparent Pricing - No Bundled Mystery Costs
What it is: Your importer should be able to tell you exactly what you're paying for. FOB price, freight, insurance, IOR service fee, and any additional charges should be itemized - not bundled into an opaque "landed price" that prevents you from understanding your cost structure.
Why it matters: If you don't know what your landed cost per kilogram actually comprises, you cannot build an accurate margin model, negotiate intelligently, or identify which cost components have changed when prices move.
✓ Your importer IS doing this if: They provide an itemized quote showing FOB price, freight estimate, insurance, and service fees separately. You can reconcile the quote against the final invoice.
✗ They probably AREN'T if: You receive a single "landed price" with no breakdown. When you ask for detail, the answer is vague or changes the subject.
✔ 12. Samples Available Before You Commit to a Production Run
What it is: Any credible green coffee importer should be able to provide a sample - typically 200–500g of current-crop green coffee before you place an order for a full pallet or more.
Why it matters: Cupping a sample is the only way to confirm that the coffee you're about to buy matches the profile you need for your blend, single origin, or private label product. Buying without sampling is accepting a quality risk that a good importer would never ask you to take.
✓ Your importer IS doing this if: Samples are dispatched within 5-7 business days of request. The sample is from the same lot or a representative sample of the current crop you're being offered.
✗ They probably AREN'T if: Samples are not available. Or they're available "only for orders above X kg." Or the sample takes more than three weeks to arrive without explanation.
✔ 13. Clear Communication on Shipment Status Throughout Transit
What it is: From the moment your coffee is loaded until it arrives at your roastery, you should be able to get a clear answer on where it is, what has happened at the port, and when to expect delivery. This means proactive updates, not just responses to your chase emails.
Why it matters: Operational surprises - a shipment selected for examination, a port delay, a document discrepancy cost more money and cause more stress when they arrive without warning. A good import partner communicates proactively, not reactively.
✓ Your importer IS doing this if: You receive shipment updates at key milestones: departure, vessel tracking, port arrival, customs clearance status, and delivery confirmation. Your messages are returned within one business day.
✗ They probably AREN'T if: You spend more time chasing shipment status than your importer spends providing it. Delays are explained after the fact. You find out about problems from your freight carrier, not your importer.
✔ 14. A Corrective Action Protocol When Quality Issues Arise
What it is: Even with pre-shipment COAs, quality issues can occur: moisture above spec on arrival, unexpected defects, or profile deviations from the approved sample. Your importer should have a documented process for handling these including what constitutes a claimable issue, how it's investigated, and what resolution looks like.
Why it matters: Without a clear protocol, quality disputes become informal negotiations where the outcome depends on who is more persistent. A documented corrective action process protects both parties and demonstrates that your importer is running a serious compliance program under FSVP.
✓ Your importer IS doing this if: They have a written procedure for quality claims. They specify tolerance parameters (e.g., moisture deviation, defect count variance) that trigger a claim investigation. They act on quality issues promptly.
✗ They probably AREN'T if: Quality claims are handled case-by-case with no documented process. "We've never had a complaint" is not a protocol. Past good luck is not a quality management system.
✔ 15. FSPCA-Certified Team - Not Just Generic Compliance Claims
What it is: The Food Safety Preventive Controls Alliance (FSPCA) is the FDA-recognized curriculum for FSMA compliance training. An FSPCA-certified individual has completed standardized training in preventive controls for human food - the same regulatory framework that underpins FSVP.
Why it matters: When your importer provides FSVP guidance, the quality of that guidance depends on the depth of the compliance knowledge behind it. Generic "we handle compliance" claims from uncertified staff are not the same as guidance from an FSPCA-certified professional.
✓ Your importer IS doing this if: Your importer can name the FSPCA-certified individual on their team and describe the specific guidance they provide. The certification is verifiable through FSPCA's training records.
✗ They probably AREN'T if: They claim "compliance expertise" or "FSVP support" without being able to name the certified individual or describe the substance of the guidance they provide.
The Caffé Premium Standard: All 15, Every Shipment
We built Caffé Premium around the belief that a coffee importer should be able to answer yes to every item on this list not as a marketing claim, but as a verifiable operational standard.
Here is how we address each of the 15:
FDA registration & DUNS: Verified for every supplier before any order is initiated. Numbers provided on request.
ISF filing: Filed before vessel departure, confirmation timestamped. Handled by InGain LLC as IOR under CIF+IOR.
Prior Notice: Filed as standard on every shipment. Confirmation number available.
FSVP guidance: Provided by our FSPCA-certified team. We walk you through hazard analysis, supplier evaluation, and verification activity requirements. You always remain the FSVP importer - we ensure you're equipped to do that correctly.
COA before commitment: Provided as part of the quotation package, before order confirmation.
Green analysis reports: Available for all lots. Third-party verified.
OTA testing: Available on request. Results consistently below 5 ppb for our standard lots.
Crop year: Documented on all COAs and quotations. Current-crop only for specialty lots.
Moisture protection: GrainPro-lined bags available and recommended for all specialty shipments.
Transparent pricing: Itemized quotes showing FOB, freight, insurance, and service fee separately.
Samples: Available for all origins. Dispatched within 5-7 business days.
Communication: Milestone updates throughout transit. All messages returned within one business day.
Corrective action: Documented protocol in place. Tolerance parameters defined. Claims handled promptly.
Minimum order: 1 pallet. No full-container commitment required to get started.
FSPCA certification: Our founder Davit Ghazaryan is personally FSPCA-certified. Guidance comes from him directly.
Is Your Current Importer Checking All 15?
If not - let's talk.
You deserve an import partner who operates to the full standard. Request a quote from Caffé Premium and see the difference a properly run import operation makes from the first conversation.
Related Reading
Caffé Premium is a brand of InGain LLC, a Wyoming-registered coffee importer and Importer of Record (IOR) with FSPCA-certified compliance capability. This article is for informational purposes only.
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