Why Indian Spice Shipments Get Held at US Customs, and the Documents That Prevent It

Quick answer: A US-bound spice container clears when four parties each file on time: the facility that packed the lot (FDA registration), the importer (FSVP identity and the Importer Security Filing), the broker (Prior Notice and entry), and the exporter (a document pack that matches the lot, plus any certificate a specific import alert demands). Black pepper from India needs one certificate most buyers have never heard of: an Export Inspection Council certificate under FDA Import Alert 28-02.

The eight causes, and who fixes each

1. Prior Notice

Every food shipment into the US needs FDA Prior Notice before it arrives: at least 8 hours before arrival by sea and at least 4 hours by air. Through CBP's ACE system it can be filed up to 30 days ahead; through FDA's own Prior Notice System Interface, up to 15 days (21 CFR 1.279). The broker usually files it, but the data comes from the exporter: product, quantity, the packing facility's FDA registration number, the shipper and the container. A late or mismatched Prior Notice is the single most common avoidable hold.

2. FDA food facility registration

The registration that matters is the one held by the facility that manufactured, processed or packed the lot, not the trading company's. Registrations must be renewed every two years between 1 October and 31 December; for 2026 that window is open now, and FDA treats any registration not renewed by 31 December 2026 as expired. A unique facility identifier is required, and FDA currently accepts the DUNS number (FDA, 29 September 2026). If you buy from India in January 2027, ask your supplier for the packing facility's renewed registration in December.

3. Black pepper: the EIC certificate

FDA Import Alert 28-02 allows detention without physical examination of black pepper from India, whole, ground or cracked, unless the shipment is accompanied by a certificate from India's Export Inspection Council (EIC). The certificate must give the lot identification, the number and size of containers, the methods used, and the results for Salmonella, filth, mould and foreign matter, signed and stamped by the authorising official. Without it, the importer has to prove the lot clean with private laboratory analysis before FDA will consider release (FDA Import Alert 28-02, published 5 March 2026). Ask for the EIC certificate on every black pepper order, alongside the commercial CoA.

4. Salmonella import alert

Import Alert 99-19 lists firms and products whose food has been found with Salmonella; their later shipments can be detained without examination until FDA removes them from the alert (FDA import alerts, spices; 99-19 last updated 5 November 2026). Before you place an order, search the alert for your supplier's and its packing facility's names. A lot-specific CoA showing Salmonella absent in 25 g is the baseline, not a guarantee.

5. Testing before shipment

India's Spices Board runs mandatory sampling and testing of export consignments for certain products and destinations. For the United States, its schedule sets total aflatoxin at 20 ppb, Salmonella absent in 25 g and Sudan I–IV dyes not detected for chilli products, and Salmonella for cumin (Spices Board Circular 24/2022-23, effective 27 March 2023). Testing in India, before the container is sealed, is far cheaper than a failure found at Savannah or Newark.

6. Importer Security Filing (10+2)

For ocean freight, CBP requires the importer or its agent to file the Importer Security Filing at least 24 hours before the cargo is loaded on the vessel at the foreign port. Late, inaccurate or missing filings can draw liquidated damages of up to $5,000 per violation (American Spice Trade Association). The exporter's part is to give the booking, container, seller, manufacturer and consolidation details in time.

7. FSVP importer at entry

Under the Foreign Supplier Verification Program, the US importer must be identified at entry with its own DUNS number; FDA stopped accepting the “UNK” placeholder in 2022 (FDA guidance on the FSVP unique facility identifier). The exporter's part is the supplier file the importer verifies against: hazard analysis, lot CoAs and the packing facility's food safety documents.

8. Paperwork that does not match the lot

Customs and FDA compare the invoice, packing list, bill of lading, Prior Notice and labels with each other and with the cargo. A different net weight, a lot number missing from the bags, or an HTS line that does not fit the product invites an examination. Agree the HTS line before shipment: Chapter 9 spices are excluded from the 10% Section 301 duty on goods of India, but only if they are classified where they belong (HTS 9903.05.44 and Indian spices).

The document pack to ask for

Frequently asked questions

Sources

1. U.S. Code of Federal Regulations, 21 CFR 1.279, When must prior notice be submitted to FDA?, read 9 November 2026.
2. U.S. Food and Drug Administration, “FDA Reminds Food Facilities of Biennial Renewal Requirements”, 29 September 2026.
3. U.S. Food and Drug Administration, Import Alert 28-02, Detention Without Physical Examination of Black Pepper from India, published 5 March 2026.
4. U.S. Food and Drug Administration, Import alerts for spices, flavours and salts, including Import Alert 99-19, read 9 November 2026.
5. Spices Board India, Circular 24/2022-23, Mandatory sampling and testing of export consignments, 23 March 2023.
6. American Spice Trade Association, “10+2 Importer Security Filing and Additional Carrier Requirements”.
7. U.S. Food and Drug Administration, Guidance: providing an acceptable unique facility identifier for FSVP.

For landed cost line by line, see what it costs to import spices from India. For the US document pack we provide, see the United States market page.