From October 1 through December 31, 2026, food facilities required to register with the Food and Drug Administration (FDA) must complete the biennial renewal of their Food Facility Registration. The requirement also applies to foreign facilities that manufacture, process, pack, or hold food for consumption in the United States, making the upcoming renewal period directly relevant to many food companies exporting to the U.S. market.
Renewal should not be confused with updating information already on file. If a registration is not renewed by the deadline, it is considered expired, which can also affect the entry of products from that facility into the United States.
Who needs to renew a Food Facility Registration
Unless a specific exemption applies, U.S. regulations require domestic and foreign facilities to register with FDA if they manufacture, process, pack, or hold food for human or animal consumption in the United States.
Exporters should note that registration applies to each individual food facility, not to the company as a whole. A single organization may therefore hold multiple registrations for different facilities.
The requirement can also apply to certain storage facilities. For example, a foreign warehouse that holds food before export to the United States will generally need to be registered unless the food subsequently undergoes more than minimal processing at another foreign facility before being exported.
Several exemptions are available, including those that may apply, under certain conditions, to farms, restaurants, and retail food establishments.
What U.S. importers and distributors should check
The renewal period is also relevant to U.S. supply chain operators. An importer or distributor operating a facility in the United States where food is received or stored may be subject to Food Facility Registration unless an exemption applies, such as the one available to qualifying retail food establishments.
Companies importing food from overseas must also consider the Foreign Supplier Verification Program (FSVP). When a U.S. operator qualifies as the FSVP importer, it must establish and maintain a verification program covering the imported food and the relevant foreign supplier, including an assessment of potential risks, compliance with FDA requirements, and the verification activities required.
Importers and distributors should also confirm that foreign facilities required to register maintain a valid and up-to-date registration. FDA registration information is not publicly searchable. To confirm a facility's status, companies need to contact the supplier directly, while FDA performs its own checks through internal systems at the time of importation.
The 2026 renewal window runs from October 1 through December 31
Under Section 415 of the Federal Food, Drug, and Cosmetic Act, facilities subject to the requirement must renew their registration between October 1 and December 31 of every even-numbered year.
One easily overlooked point concerns newly registered facilities. If a facility completes its initial registration before October 1, 2026, it must still renew during the window beginning October 1. The same applies if an existing registration has simply been updated before the biennial renewal period begins.
FDA clearly distinguishes between an update and a renewal. Updating one or more registration details does not satisfy the biennial renewal requirement.
Renewal can be completed electronically through FDA Industry Systems. Paper submissions are permitted only for facilities that have received the specific waiver provided for under FDA regulations.
UFI and DUNS: what to verify before October
Food Facility Registration requires a Unique Facility Identifier (UFI). FDA currently recognizes the Data Universal Numbering System (DUNS) number, issued and managed by Dun & Bradstreet, as an acceptable identifier for registration purposes.
The UFI allows FDA to verify a facility's identity and physical address. Before the renewal window opens, companies should therefore make sure that the legal name and address associated with the DUNS number match the information used in the Food Facility Registration.
This is particularly important following a change of address, corporate reorganization, or change in legal name. In general, changes to required registration information must be reported to FDA within 60 calendar days. A change of ownership follows a different procedure: the former owner must cancel the existing registration, while the new owner must register the facility again.
Foreign facilities still require a U.S. agent
Every foreign food facility required to register must also designate a U.S. agent. The agent must reside in or maintain a place of business in the United States and be physically present in the country.
The U.S. agent serves as the point of contact between FDA and the foreign facility for registration-related communications and emergencies. A foreign facility may designate only one U.S. agent for Food Facility Registration purposes, although it may work with multiple brokers or other intermediaries for its commercial activities.
Exporters should also distinguish the U.S. agent from the FSVP importer under the Foreign Supplier Verification Program. These are separate roles, although the same entity may perform both if it meets the applicable requirements.
Before renewing, companies should confirm that the U.S. agent listed in the registration is still active and that its address, telephone number, and email address are up to date.
What happens if a registration is not renewed
According to FDA instructions for the 2026 renewal cycle, registrations that are not renewed by December 31 are considered expired and removed from the account.
FDA also states that if a foreign facility required to register is not properly registered, food from that facility offered for import into the United States is subject to refusal under Section 801(l) of the Federal Food, Drug, and Cosmetic Act.
For companies that regularly export to the U.S. market, allowing a registration to expire can therefore create a significant commercial and logistical problem, potentially delaying shipments or preventing them from entering the country.
What to check before starting the renewal
The weeks leading up to the renewal window are a good opportunity to carry out several checks:
- identify all company facilities subject to Food Facility Registration;
- confirm access to the FDA Industry Systems account and review the registrations linked to it;
- check the DUNS/UFI associated with each facility and make sure the identifying information is consistent;
- verify the legal name, address, contact details, trade names, and other information included in the registration;
- confirm that the U.S. agent is still active and that its contact information is correct;
- make sure any corporate or ownership changes have been handled according to the required procedure.
Renewal does not result in the issuance of a new Food Facility Registration Number. A facility that successfully renews its registration keeps its existing number.
Companies should also remember that FDA does not charge a fee for registration or renewal and does not require the use of private firms or third-party registrars. A U.S. agent or external consultant may charge for its own services, but this is a private commercial arrangement and not a fee imposed by the Food and Drug Administration.
Official instructions for the 2026 cycle are available in the FDA Biennial Registration Renewal guide.
