Dried Fruit and Nuts Exports to the USA: FDA Registration

ABD’ye kuru meyve ve kuruyemiş göndermek için FDA tesis kaydı zorunludur, ücretsizdir ve iki yılda bir yenilenir. Ancak kayıt tek başına yeterli değildir. Türkiye’den giden kuru üzüm, incir ve Antep fıstığı için asıl belirleyici olan, ürünün FDA’nın import alert listelerinde yer alıp almadığıdır. Bu listelerdeki sevkiyatlar ABD gümrüğünde fiziksel inceleme yapılmadan alıkonabiliyor.

Below, you will first find information on the purpose of the registration, followed by two import alert lists that directly concern Turkey, the aflatoxin limit, labeling requirements, and the tax rate change scheduled for 2026.

What does FDA registration do, and what doesn't it do?

FDA facility registration is the process of reporting a manufacturing facility to the FDA system. The registration process is free, and the facility is assigned an 11-digit number.

There is a common misconception: registration does not indicate that a product was produced safely or that it complies with U.S. standards. The FDA does not approve food; it merely records the existence of the facility. For this reason, using the phrase “FDA-approved” on a food product is considered a misleading claim in the U.S. We discussed the difference in detail in our article titled “The Difference Between FDA Registration, Approval, and Certification.”

For dried fruit and nut exporters, the registration process consists of three parts:

• Facility registration. This is done through the FDA Industry Systems and is free of charge.
• U.S. Authorized Representative. This is required for every food facility located abroad; communication between the FDA and the facility takes place through this individual. For more details, see our article on U.S. representatives.
• Prior Notice per shipment. Registration is a one-time process; Prior Notice must be submitted separately for each shipment. These are two separate obligations.

Main topic: Which import alert lists does Turkey appear on?

An import alert is a pre-detention mechanism implemented by the FDA for certain products and companies. Its acronym is DWPE, which stands for “detention without physical examination.” When a shipment on the list arrives at a U.S. port, it can be detained without the need for sampling; it is up to the exporter to demonstrate that the product is compliant.

Dried fruits and nuts originating in Turkey appear on two separate lists, and the scope of each list differs from the other:

This distinction makes a big difference in practice. Since the list for raisins applies nationwide, your shipment may still be subject to the restrictions even if your company has never had any issues. For pistachios and figs, however, the list applies on a company-by-company basis; if your company is not on the list, your shipment will not be subject to these restrictions.

There is also a way to be removed from the list. The FDA can place companies that demonstrate compliance on an exemption list known as the “green list.” A Turkish company in the raisin sector received such an exemption in 2018. The process requires analysis results and a history of consecutive compliant shipments; it takes time, but it’s not an impossible hurdle.

You can check your status on the Import Alert 99-15 and Import Alert 23-14 pages. The lists are being updated, so it’s a good idea to check them before shipping.

If I've been added to the list, how do I get removed?

Being added to the import alert list is not permanent. The process for being moved to the exemption list—which the FDA refers to as the “green list”—works as follows:

1. Identify the cause and eliminate it. If it’s aflatoxin, you need to determine where it formed in the harvesting, drying, and storage process. If it’s pesticide residue, the issue lies in pesticide application. The other steps are meaningless unless the cause is eliminated.
2. Establish a history of consecutive compliant shipments. The FDA generally requires that a certain number of consecutive shipments be found compliant based on independent laboratory analysis.
3. Prepare the file. Corrective action report, analysis results, changes in production and storage conditions
4. Submit the application. The request is forwarded to the FDA and reviewed

The process isn’t quick; it takes months. But the fact that a Turkish company obtained an exemption for raisins through this process in 2018 shows that the door isn’t completely closed.

Meanwhile, shipments aren’t coming to a complete halt. A company on the list can still make shipments, but it must document compliance for each shipment and factor in the detention period. This means port fees and storage costs, so for most companies, it makes more commercial sense to be removed from the list.

What happens if a shipment is held up?

The detention notice is sent to the importer in the U.S., not to the manufacturer. The importer must respond within a certain period of time. There are two options: provide documentation proving that the product complies with regulations, or return the product without bringing it into the U.S. or destroy it.

To demonstrate compliance, it is generally necessary to have the product analyzed at a laboratory recognized by the U.S. FDA. Analyses conducted in Turkey are not always considered sufficient. This difference in cost and time highlights why pre-shipment preparation is so important.

What is the aflatoxin limit?

The FDA’s total aflatoxin action level for human food is 20 ppb (parts per billion). The same level applies to the entire nut category, including pistachios, peanuts, and Brazil nuts. There is a separate and much lower level for aflatoxin M1 in milk—0.5 ppb—but that falls outside our product category.

The key point here is this: 20 ppb is not a “permissible pollution” limit, but rather an action level established for unavoidable situations. In other words, the goal is not simply to stay below the target limit, but to keep levels as low as possible.

The European Union's border requirements are less stringent than those of the U.S. for certain products. A manufacturer shipping to the EU has already established the necessary analytical infrastructure, which also makes things easier on the U.S. side.

What should be included on the label?

Simply translating the Turkish label into English is not enough; the layout must be restructured according to U.S. standards. Required headings for nuts and dried fruit:

• Nutrition Facts table. In the U.S. format, with serving sizes based on U.S. measurements
• Allergen notice. Tree nuts are among the major allergens in the U.S. Hazelnuts, almonds, walnuts, and pistachios are listed as follows: “Contains: Hazelnuts”
• Table of Contents. In descending order of weight, in English
• Net amount. In both metric and U.S. units
• Name and address of the manufacturer or importer
• Sulfur dioxide declaration. If used in dried apricots and certain other dried fruits, it must be declared if the level exceeds 10 ppm.

Who is responsible for FSVP?

This is where the confusion arises most often. The party required to maintain the FSVP record is the importer in the U.S., not the manufacturer in Turkey.

However, the importer requests documents from the manufacturer to complete that file: a hazard analysis, preventive controls, test results, and supplier verification records. So, even though the responsibility lies with the importer, part of the work falls on the manufacturer. A manufacturer who keeps these documents on hand is an easier supplier for the importer.

What happened with taxes in 2026?

The additional customs duty, which took effect on July 24, 2026, is being applied at a rate of 12.5 percent. This rate was not added to the previously discussed rates; rather, it replaced them.

There is a list of tax exemptions, but it includes raw materials not grown in the U.S., such as coconuts, cocoa, and palm kernel oil. The hazelnuts, dried figs, dried apricots, and raisins exported by Turkey are not on this list, meaning they remain subject to the tax.

The exemption list is organized by eight-digit tariff codes. The fact that a four-digit position appears on the list does not mean the product is exempt; the verification must be based on the eight-digit code. For a breakdown of all cost items, please refer to our article on the cost of exporting food to the U.S.

When is registration renewal?

FDA food facility registrations are renewed in even-numbered years, between October 1 and December 31. The 2026 renewal window opens on October 1, 2026, and closes on December 31, 2026. Registrations that are not renewed are considered expired and are revoked.

Renewal is free, just like registration. During this period, you may receive invoices from intermediary companies titled “renewal fee”; before paying, it’s a good idea to verify whether the transaction was actually processed using the registration number.

What should I do next?

1. Check to see if your product is on any import alert lists. This is the first step, because the result affects everything else.
2. Have aflatoxin and residue analyses performed at an accredited laboratory, and keep the results on file
3. Register your facility with the FDA and appoint your U.S. representative
4. Restyle the label according to the U.S. format
5. Discuss FSVP documents with your importer in advance
6. Use your eight-digit rate code to determine the tax rate
7. Provide Prior Notice for each shipment

We handle the entire process for dried fruits and nuts from start to finish. If you’d like to discuss your situation, please contact us.