You found a stunning lot. An Indian Robusta from Coorg with the body your espresso blend has been missing. A natural Ethiopian from Yirgacheffe that cupped at 87 points. A Vietnamese Robusta priced perfectly for your cold brew concentrate line.
Now what?
If you've never imported green coffee into the United States before — or if you have, but you've been winging it — this guide is for you. We'll walk through every agency, every form, every deadline, and every compliance obligation that stands between your origin coffee and your roastery. No fluff. No vague "consult a customs broker" cop-outs. Just the real process, explained clearly.
At InGain LLC, we act as your Importer of Record (IOR) and provide FSVP guidance through our FSPCA-certified team. This guide reflects what we do for our customers every day.
Who Regulates Coffee Imports into the USA?
Three federal agencies have jurisdiction over imported coffee. Understanding who does what prevents costly mistakes.
U.S. Customs and Border Protection (CBP) controls the physical and administrative entry of all goods into the United States. CBP enforces trade laws, collects duties and fees, and processes your entry documentation. Every coffee shipment — regardless of size — passes through CBP.
The U.S. Food and Drug Administration (FDA) regulates coffee as a food product under the Federal Food, Drug, and Cosmetic Act (FDCA) and the Food Safety Modernization Act (FSMA). The FDA ensures your coffee is safe for human consumption, free from harmful contaminants, and properly documented at the supplier level.
The U.S. Department of Agriculture (USDA) enters the picture primarily if you are importing organic-certified coffee. The USDA's National Organic Program (NOP) requires proof of accredited organic certification from the exporting country. For conventional green coffee, USDA involvement is minimal.
Most importers underestimate the FDA's role. They focus on CBP paperwork and miss the compliance infrastructure the FDA now requires — especially under FSVP. More on that below.
Step 1: Classify Your Coffee Correctly (HTS Codes)
Before anything else, you need the right Harmonized Tariff Schedule (HTS) code. This determines your duty rate, your documentation requirements, and how CBP processes your entry.
For green (unroasted) coffee beans:
ProductHTS CodeImport DutyGreen coffee, not decaffeinated0901.11.00000%Green coffee, decaffeinated0901.12.00000%Roasted coffee, not decaffeinated0901.21.0015 / 0901.21.00250%Roasted coffee, decaffeinated0901.22.00000%Coffee husks and skins0901.90.10000%
The good news for roasters: Green coffee carries a 0% import duty regardless of origin. This applies whether you're sourcing from India, Vietnam, Ethiopia, Burundi, or anywhere else — no tariff surcharges, no country-of-origin penalties on the duty rate itself. (Always verify the current tariff schedule at usitc.gov, as trade policy can change.)
Step 2: Ensure Your Supplier Is FDA-Registered
This is where many first-time importers get tripped up.
Under the FDA's Bioterrorism Act and reinforced by FSMA, every foreign facility that manufactures, processes, packs, or holds food for U.S. consumption must be registered with the FDA. Your green coffee supplier — the mill, the washing station, the exporter — must have an active FDA facility registration.
At the time your shipment arrives at the U.S. port of entry, CBP and FDA agents verify whether the goods originated from a registered facility. If not, the shipment can be detained, refused entry, or returned to the shipper. Monetary penalties are also possible.
What this means for you as the buyer:
- Request FDA registration confirmation from your supplier before placing your first order.
- Confirm the registration number is current (FDA registrations must be renewed every two years, in even-numbered years).
- Keep this documentation in your records.
At InGain LLC, all of our active suppliers in India, Vietnam, Ethiopia, and Burundi hold verified DUNS numbers and active FDA registrations. We confirm this before any shipment is initiated.
Step 3: File Prior Notice with the FDA
The FDA requires Prior Notice for every commercial food shipment entering the United States — including green coffee.
Prior Notice is a formal notification submitted to the FDA before your shipment arrives. It gives the agency time to review the shipment details and flag any concerns before the product clears customs.
Deadlines for filing Prior Notice:
Mode of TransportPrior Notice DeadlineOcean vesselAt least 8 hours before arrivalAir freightAt least 4 hours before arrivalRailAt least 8 hours before arrivalTruck (road)At least 2 hours before arrival
How to file:
Prior Notice can be submitted through two channels:
- CBP's Automated Commercial Environment (ACE) via the Automated Broker Interface (ABI) — the standard channel used by licensed customs brokers.
- FDA's Prior Notice System Interface (PNSI) — a direct online portal available to importers who do not use ACE.
In practice, if you are working with a licensed customs broker or an IOR like InGain LLC, Prior Notice is filed as part of the standard entry process. If you're going it alone, you will need access to PNSI and the relevant shipment details: product description, country of origin, manufacturer, shipper, quantity, and intended U.S. recipient.
Step 4: File the Importer Security Filing (ISF) — Ocean Shipments Only
If your coffee is arriving by ocean vessel (the most common method for bulk green coffee), you must file an Importer Security Filing (ISF), also known as "10+2," with CBP.
Critical deadline: ISF must be filed no later than 24 hours before the vessel departs the last foreign port. (Note: some guidance still references 48 hours before U.S. arrival — the 24-hours-before-departure rule is the operative standard.)
ISF requires 10 data elements from the importer (hence "10+2"):
- Seller name and address
- Buyer name and address
- Importer of Record number
- Consignee number
- Manufacturer (or supplier) name and address
- Ship-to name and address
- Country of origin
- Commodity HTS code (6-digit minimum)
- Container stuffing location
- Consolidator name and address
The "+2" elements are provided by the ocean carrier (vessel stow plan and container status messages).
Late or missing ISF filings can result in fines of up to $5,000 per violation. If you're working with a freight forwarder or customs broker, this is their job — but verify it's being done correctly every time.
Step 5: Understand the CBP Entry Process
Once your shipment approaches the U.S. port of entry, the formal CBP entry process begins. Here's what happens:
Entry Filing
For shipments valued over $2,500, a formal entry is required. This involves:
- CBP Entry Form (CBP Form 3461 for immediate delivery, or CBP Form 7501 for consumption entry)
- Commercial invoice (with full description, country of origin, value, and quantity)
- Packing list
- Bill of lading or air waybill
- Certificate of Origin (required by the International Coffee Organization for coffee shipments)
- Any other relevant certificates (phytosanitary, quality, organic if applicable)
For shipments under $2,500, an informal entry may suffice, though a customs bond may still be required depending on circumstances.
Customs Bond
A customs bond is a financial guarantee to CBP that all duties, taxes, and fees will be paid and all import regulations will be complied with. For formal entries, a bond is mandatory. You can obtain a single-entry bond (for one shipment) or a continuous bond (covers all shipments for a year — cost-effective if you import regularly).
Examination and Release
CBP may select your shipment for examination — a physical inspection of the cargo. While green coffee is generally low-risk, examinations do happen. If the FDA has any flags on the shipment (unregistered facility, Prior Notice discrepancy, or FSVP issues), they can place a hold that delays release.
Step 6: Comply with FSVP — The Requirement Most Roasters Miss
This is the section that gets importers into trouble.
The Foreign Supplier Verification Program (FSVP), part of FSMA (21 CFR Part 1, Subpart L), requires that any U.S. importer of food verify that their foreign suppliers are producing food in a manner consistent with U.S. food safety standards.
If you are the U.S. owner or consignee of an imported food shipment — legally, you are the FSVP importer. This is true even if someone else handled the customs clearance. The FSVP importer responsibility cannot be delegated away.
Core FSVP requirements for green coffee importers:
1. Hazard Analysis You must evaluate known and reasonably foreseeable hazards associated with green coffee — including biological hazards (Salmonella, mold, mycotoxins like Ochratoxin A), chemical hazards (pesticide residues, heavy metals), and physical hazards (foreign material). You must document this analysis.
2. Supplier Evaluation Based on your hazard analysis, you must evaluate your supplier's food safety performance and the risk posed by the food. This includes reviewing the supplier's food safety controls.
3. Supplier Verification Activities You must conduct ongoing verification activities to confirm your supplier continues to meet U.S. food safety standards. Acceptable verification activities include:
- Onsite audits (required as a standard for most FSVP importers)
- Sampling and testing of the food
- Review of the supplier's food safety records
- Third-party certifications or other appropriate methods
4. Corrective Actions If a verification activity reveals a problem, you must take prompt corrective action — potentially including stopping imports from that supplier.
5. FSVP Records All FSVP activities must be documented and records maintained for at least two years. These records must be available to FDA upon request — including during unannounced audits.
6. DUNS Number Requirement (Since July 2022) Since July 24, 2022, FSVP importers must provide a DUNS (Data Universal Numbering System) number for their foreign supplier when filing entry with CBP. No DUNS number? The FDA can flag the entry.
The FDA Is Auditing — Right Now
The FDA has been conducting surprise audits of green coffee importers specifically to check FSVP compliance. Importers caught off-guard face:
- Form 483 citations (official notices of observed violations)
- Shipment delays or seizures
- Import alerts
- Civil monetary penalties
- In serious cases, criminal prosecution
The FSVP importer and the CBP Importer of Record are not necessarily the same entity. This distinction matters enormously. A customs broker or freight forwarder who clears your goods at CBP does not assume your FSVP obligations. You do.
How InGain LLC handles this: We act as your Importer of Record (IOR) for CBP customs clearance — handling ISF, Prior Notice, entry filing, and bond. Separately, our FSPCA-certified team provides FSVP guidance to help you, as the U.S. buyer, meet your FDA obligations. We don't leave you alone with FSVP paperwork.
Step 7: Obtain a Certificate of Origin (ICO)
The International Coffee Organization (ICO) requires a Certificate of Origin for all commercial coffee exports. This document is issued by the relevant authority in the origin country and certifies the country of origin, quantity, and classification of the coffee.
For your purposes as the U.S. importer, the Certificate of Origin is part of your standard import documentation package — required by CBP and useful in validating your product's origin for HTS classification purposes.
Your supplier (or their export agent) is responsible for obtaining the ICO Certificate of Origin at the origin end. Make this a standard requirement in your purchase agreement.
Step 8: Arrange Logistics and Insurance
Green coffee is typically shipped in:
- Jute or GrainPro bags (60 kg per bag, standard for specialty lots)
- Supersacks / bulk bags (500–1,000 kg, common for commodity volumes)
- Full container loads (FCL) or less-than-container loads (LCL)
For small roasteries starting out, LCL shipments from 1 pallet (approximately 20–25 bags of 60 kg = 1,200–1,500 kg) are a practical entry point. This is exactly the minimum we offer at InGain LLC — no pressure to commit to a full container before you've validated the lot with your roastery.
Cargo insurance is not legally required but is strongly recommended. Green coffee is susceptible to moisture damage, contamination, and shifting during transit. Marine cargo insurance covers loss and damage. Arrange this through your freight forwarder or a specialist cargo insurer.
Common Mistakes First-Time Coffee Importers Make
Skipping FSVP because you used a broker. Using a licensed customs broker for entry filing does not transfer your FSVP obligations. You remain the FSVP importer.
Not verifying FDA supplier registration before ordering. Discovering your supplier isn't registered after the shipment is on the water is an expensive lesson.
Missing the ISF deadline. The ISF must be filed before the vessel departs the last foreign port. Not when it arrives in the U.S.
No hazard analysis on file. The FDA expects documented FSVP hazard analysis. "We trust our supplier" is not a compliant answer during an audit.
Treating a one-time audit as permanent compliance. FSVP requires ongoing verification activities on a schedule appropriate to the risk level and supplier performance. This isn't a one-and-done checkbox.
Ignoring the DUNS number requirement. Since July 2022, your supplier's DUNS number must appear in your CBP filing. Missing this triggers FDA flags.
The IOR Model: How InGain LLC Makes This Simpler
For roasters and brands who want to source direct-from-origin coffee without building an in-house compliance infrastructure, working with an Importer of Record (IOR) is the most practical path.
As your IOR, InGain LLC:
- Files all CBP entry documentation (ISF, entry forms, customs bonds)
- Submits FDA Prior Notice for every shipment
- Handles all communication with CBP and FDA at the port of entry
- Sources from FDA-registered, DUNS-verified suppliers in India, Vietnam, Ethiopia, and Burundi
- Provides FSVP guidance through our FSPCA-certified team
You focus on what you do best — roasting, blending, building your brand. We handle the compliance infrastructure.
You can start from just 1 pallet. No long-term volume commitments. No opaque pricing.
Summary: Your Coffee Import Compliance Checklist
Before your first shipment arrives:
- Correct HTS code identified (0901.11.0000 for green non-decaf)
- Foreign supplier has active FDA facility registration
- Supplier's DUNS number obtained and documented
- FSVP hazard analysis completed for this food and supplier
- FSVP verification plan established
- Certificate of Origin confirmed with supplier
- Licensed customs broker or IOR engaged
- Customs bond in place (single-entry or continuous)
- ISF filed before vessel departure from last foreign port
- FDA Prior Notice filed per modal deadline
- Cargo insurance arranged
Ready to Import — Without the Compliance Headache?
At InGain LLC, we've built our entire operation around making this process simple, transparent, and compliant for US roasters, private label brands, cafes, wholesalers, and marketplace sellers.
Our FSPCA-certified founder Davit Ghazaryan personally handles every inquiry and responds within one business day. We pre-vet every supplier. We manage your customs entry as IOR. And we walk alongside you through your FSVP obligations so you're never caught off-guard by an FDA audit.
Start with a sample. Scale at your pace. Import with confidence.
Request a Free Sample → Get a Quote → Contact Davit Directly →
InGain LLC is a Wyoming-registered coffee importer and Importer of Record (IOR) specializing in green and roasted coffee from India, Vietnam, Ethiopia, and Burundi. Our FSPCA-certified team provides FSVP compliance guidance for U.S. roasters and coffee brands. This article is for informational purposes only and does not constitute legal advice. Consult a licensed customs attorney or compliance professional for your specific situation.
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