Missing a Food Facility Registration Renewal
Every Even-Numbered Year, October–December
Situation
Every facility that exports, manufactures, or holds food for the U.S. must hold an FDA Food Facility Registration, renewed every two years between October 1 and December 31 of even-numbered years.
Problem
A meal-kit exporter missed its 2024 renewal and the registration expired automatically. In March 2026, when a container bound for LA arrived, FDA notified them that the facility's registration had expired. The container sat at port racking up daily storage fees, and the exporter ultimately had to register a new U.S.-side facility.
Timeline
- Root cause 1 — confused which years require renewal (even years only)
- Root cause 2 — staff turnover meant the reminder was missed
- Root cause 3 — an old U.S. Agent whose relationship had ended was left in place