Exporting UK food to the USA: what FDA registration, US labelling and your EHC actually require
What UK food exporters must know to ship to the USA — FDA food facility registration, FSVP, US labelling under 21 CFR, and the EHC via EHCO. Plain-English guide.
Exporting UK food to the USA: what FDA registration, US labelling and your EHC actually require
Your UK EHC gets the goods out of Britain. It does nothing to get them into America. The USA has its own gate.
That single misread is behind more US port refusals than any other. UK food exporters tend to treat the export health certificate (EHC) — raised in APHA's EHCO system and signed by an authorised certifier — as the document that opens the whole journey. It isn't. It satisfies the UK side. The United States runs an entirely separate regime governed by the FDA, built on FDA food facility registration, US food labelling under 21 CFR, and the Foreign Supplier Verification Programs (FSVP) rule your American importer carries. To export food to the USA you have to clear both gates, in two countries, under two rulebooks. This piece walks through what each actually requires — UK side and US side — so you can see where the work sits and who owns it.
A caution before we start: this is practical trade guidance, not regulated advice, and US food rules change. Treat every rule here as the position to verify against the current FDA and GOV.UK guidance for your specific commodity and route — or ask us to check it for you.
Does your UK food need a US gate as well as a UK one?
Yes. Exporting food to America is two separate compliance jobs. The UK side gets the goods lawfully out — for products of animal origin (POAO) that means an EHC raised in EHCO. The US side gets them lawfully in — FDA facility registration, a US agent, US-compliant labelling, and the importer's FSVP. Neither side covers the other.
It helps to picture two gates with a stretch of ocean between them. The UK gate is administered by APHA (the Animal and Plant Health Agency) and, for the certificate itself, signed off by an authorised certifying officer. The US gate is administered by the FDA under the Federal Food, Drug, and Cosmetic Act and the FDA Food Safety Modernization Act (FSMA). The mistake that costs exporters money is assuming a document issued at the first gate carries any weight at the second. It doesn't. The FDA has never seen your EHC and does not act on it.
So the right mental model is: do the UK-side work and the US-side work, in parallel, and reconcile the two so they describe the same goods. Get that wrong and the consignment can be refused at the US port of entry — and a refusal mid-Atlantic is far more expensive than a question answered before you booked freight.
What is FDA food facility registration, and does it apply to a UK site?
FDA food facility registration applies to any facility — UK premises included — that manufactures, processes, packs or holds food for consumption in the United States. Under the FDA's rule you register the facility (not the product) with the FDA, you must name a US agent, and you must renew the registration in every even-numbered year. There is no fee.
This catches UK exporters off guard because the obligation reaches across the Atlantic and lands on your British site. If your factory makes the biscuits, sauces, cheese or beverages destined for an American shelf, that factory is a "food facility" in the FDA's terms and has to be registered. The registration produces an FDA registration number that ties your premises into the US system.
Two parts of this trip people up.
The US agent. The FDA requires every foreign facility to designate a US agent — a person or business physically in the United States who acts as the FDA's point of contact for that facility, available during US business hours. This isn't your importer by default, and it isn't a formality you can leave blank. The agent must consent to the role. Many exporters discover at the last minute that they have no one named.
The biennial renewal. Registrations must be renewed during a window the FDA sets — historically between 1 October and 31 December of each even-numbered year. Let it lapse and the FDA cancels the registration; an unregistered facility's food can be refused at the border. This is the kind of date that disappears off the calendar two years after you set it up, then resurfaces as a refused consignment. Check the FDA's current Food Facility Registration guidance for the exact window and process before you rely on the dates here.
Who is responsible for the FSVP — you or your US importer?
The FSVP sits with your US importer, not with you. Under the FDA's Foreign Supplier Verification Programs rule, the US importer of record must verify that the food they bring in was produced to standards meeting US safety requirements. That means they carry a documented programme covering your facility — and if they don't have one, your goods are exposed even though the obligation isn't legally yours.
This is the part of the workflow most likely to fail quietly, because it lives in another company, in another country, out of your sight. The FSVP importer has to identify hazards for your food, evaluate your facility's controls, and keep records the FDA can inspect. If your US buyer has never imported a product like yours, they may not know they are the FSVP importer, or may not have a programme in place.
You can't complete the FSVP for them — it's their legal responsibility. But you can do two practical things. First, ask the question early: "Who is the FSVP importer for this product, and is the programme in place?" If the answer is a blank look, that is the finding, and better found now than at the port. Second, be ready to supply what they need to build it — your food safety documentation, hazard analysis, and evidence of your controls. A US importer with a smooth FSVP is far more likely to keep buying from you. Refer to the FDA's FSVP guidance for what the programme must contain.
Will your UK label meet US food labelling rules?
Almost certainly not, as it stands. US food labelling is governed by the FDA under 21 CFR and differs from UK and EU labelling in concrete ways: it requires a US-format Nutrition Facts panel (not the UK's nutrition declaration), US allergen declarations under US law, ingredient listing to US conventions, and specific net-quantity and identity statements. Your existing UK artwork — and anything you built for "Not for EU" — does not transfer.
"Not for EU" labelling has nothing to do with the USA. American labelling is a separate rulebook, and it's the one part of this you can get fully right before the product ever crosses the Atlantic. Treat it as a deliverable, not an afterthought. The headline gaps to expect:
- Nutrition Facts panel. The US format, serving sizes, and the values it requires differ from the UK back-of-pack declaration. It's a redesign, not a tweak.
- Allergens. US allergen labelling law names its own list of major allergens and its own declaration format. Map your ingredients against the current US requirements rather than assuming your UK allergen box satisfies them.
- Ingredient and additive names. Some additives permitted and named one way in the UK are named differently — or treated differently — in the US. Colours are a frequent example.
- Identity, net quantity and the responsible party. US labels carry specific statements of identity, US units, and the name and place of business of the manufacturer, packer or distributor.
Because the FDA does not pre-approve labels, the burden is on you to get it right before print. A non-compliant label is a classic reason for a consignment to be detained on arrival — and reprinting artwork mid-shipment is exactly the cost you're trying to avoid. Before it goes to print, have the label checked against current 21 CFR requirements for your product category.
What does the UK side — the EHC via EHCO — actually require?
For products of animal origin, the UK side means an export health certificate (EHC) raised in EHCO, APHA's online system, and signed by an authorised certifier before the goods move. EHCO is where you find the right certificate for your commodity and destination, apply for it, and manage it. The certificate attests, under the certifier's signature, that the goods meet the conditions the destination market requires.
A few practitioner points. First, not every food needs an EHC — it's POAO (meat, dairy, fish, eggs, products containing them) and certain other controlled goods that do. A shelf-stable ambient biscuit with no animal ingredients is a different conversation from a chilled cheese. Check whether your specific commodity needs certification before assuming either way.
Second, the EHC is destination-specific. The certificate and its attestations are tied to the market you're exporting to — a US certificate is not an EU one. Use EHCO to find the correct certificate for the USA and your commodity.
Third, lead time is real and the signature can't be backdated. The certifier — often an Official Veterinarian or other authorised certifying officer — has to sign before the consignment leaves, after the goods exist and can be verified. You can't sign it after the fact. Build that into your dispatch timeline rather than discovering it on the day. See GOV.UK's export health certificate guidance and the EHCO service for how to apply and who can certify.
How do the UK certificate and the US declaration have to line up?
They have to describe the same goods. Your EHCO application declares what the consignment is; your US importer's entry and FSVP describe what they're bringing in to the FDA. If those two descriptions diverge — different product description, different composition, a mismatch in what's certified versus what's declared — you create a reconciliation gap that surfaces at the US port, not before.
This is an ownership question as much as a paperwork one. Map it out: who owns the FDA registration and its renewal, who is the named US agent, who is the FSVP importer, who signs the EHC, and who checks that the US entry matches the UK certificate? If the answer to any of those is "nobody", that gap is your real exposure. A held consignment finds these blind spots for you — at the worst possible moment.
A worked example: a UK cheesemaker's first US shipment
Walk it through end to end. A UK dairy producer wants to send a hard cheese to a distributor in the US.
- Classify and confirm the route. Cheese is a product of animal origin, so the UK side will need an EHC. Confirm the commodity and the destination so you're working to the right rules from the start — get the commodity code and product description settled, because everything downstream has to agree with it.
- Register the facility with the FDA. The site that makes the cheese registers as a food facility and obtains its FDA registration number. No fee — but it must be done before goods arrive.
- Name a US agent. Designate a US-based agent who consents to act as the FDA's contact for the facility. Do this as part of registration, not as an afterthought.
- Confirm the FSVP importer. Establish with the US distributor that they are the FSVP importer and have a programme covering your dairy. Supply your food-safety documentation so they can build it. If they've never imported cheese, expect to lead this conversation.
- Build a US-compliant label. Redesign artwork for a US Nutrition Facts panel, US allergen declarations (milk, here, declared the US way), US ingredient naming, identity and net-quantity statements, and the responsible party. Get it checked before print.
- Raise the EHC in EHCO. Find the correct US certificate for your dairy commodity, apply, and arrange certification. Book the certifier with enough lead time to sign before dispatch.
- Reconcile UK and US descriptions. Check that the EHC description and the US entry/FSVP describe the same product before you book freight.
- Then ship. With both gates cleared and the descriptions aligned, the consignment has a clear path through the US port.
Run that sequence before you commit to freight, not after. Sort the FDA registration, US agent, FSVP and labelling ahead of booking — once the goods are at the US port, your options narrow and the cost of a problem climbs.
What does each route actually need? A quick reference
- Ambient food, no animal ingredients: FDA facility registration + US agent, US-compliant label, FSVP held by the US importer. Usually no EHC.
- POAO (meat, dairy, fish, eggs): all of the above plus an EHC raised in EHCO and certified before dispatch.
- Always: reconcile the UK certificate/declaration with the US entry; confirm who owns registration renewal, the US agent, and the FSVP relationship.
None of this is a one-time setup. The biennial FDA renewal, the live FSVP relationship, and label maintenance as US rules change all need an owner. And because the US side genuinely sits across an ocean and inside another company, it's the part most worth scoping deliberately before your first shipment.
Borders are complicated. We aren't. If you're planning your first US food shipment, tell us the product and the market and we'll give you a trade-barrier reality check — what you need on the UK side, what your US importer carries, and where the gaps are before they cost you at the port.
Tell us the goods and the route — we'll tell you exactly what you need.
FAQ
No. An EHC raised in EHCO and signed by an authorised certifier satisfies the UK side — it gets the goods lawfully out of Britain. The USA runs a separate FDA regime: facility registration, a US agent, US labelling and the importer's FSVP. You must clear both gates.
Yes. The FDA's rule covers any facility — UK premises included — that manufactures, processes, packs or holds food for US consumption. You register the site, name a US agent, and renew in every even-numbered year. There's no fee. Check the FDA's current guidance for the exact renewal window.
Your US importer. Under the FDA's Foreign Supplier Verification Programs rule, the US importer of record must verify your food meets US safety standards and keep records the FDA can inspect. You can't complete it for them, but supply your food-safety documentation and confirm early that their programme covers your product.
Almost certainly not. US labelling under 21 CFR requires a US-format Nutrition Facts panel, US allergen declarations, US ingredient naming, and specific identity and net-quantity statements. "Not for EU" and UK artwork don't transfer. Because the FDA doesn't pre-approve labels, get yours checked against current rules before print.
No. EHCs apply to products of animal origin — meat, dairy, fish, eggs and products containing them — and certain other controlled goods. An ambient product with no animal ingredients usually won't need one, though it still needs FDA registration and a compliant label. Check whether your specific commodity requires certification.
A question about your goods specifically?
Tell us the product and the route — we'll tell you exactly what you need.