2026.10.16

Documents to Request Before Importing Bubble Tea Ingredients: Certificate of Origin, FDA Registration, COA and More

Quick Answer

Before importing bubble tea ingredients, ask your supplier for 6 documents: a Certificate of Origin, the factory’s FDA food facility registration (for the US), an ingredient and additive spec sheet, a Certificate of Analysis (COA), food safety certificates (HACCP, ISO 22000 / FSSC 22000, Halal) and lot traceability records. Under the US FDA FSVP rule, verifying foreign suppliers is the importer’s own responsibility; if paperwork is missing, the importer bears the risk of detention and returns.

Why Importers Have to Check

  • The legal duty sits with the importer: the US FDA Foreign Supplier Verification Programs rule (FSVP, 21 CFR Part 1 Subpart L) requires importers to verify that food from foreign suppliers meets US safety standards and to keep records. The FDA keeps issuing warning letters to importers without an FSVP.
  • Rules differ by country: permitted additives, colors and limits vary. Legal in the exporting country does not mean legal in yours. See Food additive rules by country: Taiwan, US, EU and China.
  • Origin claims are under scrutiny: US customs has seized food declared as Taiwanese that actually came from elsewhere, and Taiwan customs stepped up enforcement against origin washing in 2025. Printing “Made in Taiwan” on a bag is not enough; you need official documents. See Origin washing: the legal risks of transshipment.

The 6 Documents at a Glance

DocumentPurposeHow to check
Certificate of OriginProves the goods were produced in Taiwan; also needed for some preferential tariffsIssued by authorized Taiwan bodies and verifiable with the issuer. See how to apply
FDA food facility registrationFood facilities exporting to the US must register with the FDA and renew every two yearsAsk for the factory’s registration confirmation and check that it can host an FDA inspection
Ingredient and additive spec sheetConfirms ingredients, additives, colors and allergens meet your country’s rulesAdditives should be listed by official name or INS / E number and checked one by one
Certificate of Analysis (COA)Shows this lot meets specs for microbes, heavy metals, preservatives and moreThe lot number must match the goods; third-party labs are preferred. See how to read a COA
Food safety certificatesShows the factory runs a structured food safety systemHACCP, ISO 22000 / FSSC 22000, Halal; the factory name and address must match the actual producer, and the certificate must be valid
Lot traceability recordsLets you find and recall the same lot quicklyGive the supplier a lot number and see whether they can trace raw materials, production date and shipments

How to Tell Whether Documents Are Genuine

  • Certificates can be looked up: FSSC 22000 publishes an official register of certified organizations, and most certification bodies offer certificate lookups by number.
  • Names must match: the company, factory address and product name should be the same on the certificate, COA and Certificate of Origin. If the certificate names factory A but factory B makes the goods, ask why.
  • Be wary of perfect numbers: identical COA values on every lot, or results sitting exactly at the limit, may not be real test results.
  • See it in person: before large or long-term orders, arrange a factory audit. See Factory audits vs. product inspections.

A Suggested Pre-Order Process

  • Request samples together with the spec sheet and COA
  • Check additive and labeling rules in your country
  • Verify certificates and the Certificate of Origin
  • Place a trial order and check that lot numbers and documents match
  • Arrange a factory audit before large or long-term orders

How Tang Sugar Helps

Our partner factories are certified to ISO 22000 (SGS), FSSC 22000 and HACCP, Halal-certified products are available, and we support FDA registration and filing for your market along with ingredient specs and test documents. Mixed containers ship with the paperwork in one set. See the full list on our certifications page, contact us for the document list, or request samples.

Note: this is general purchasing guidance, not legal advice. Regulations change, so check the latest notices from the authorities in your importing country.

FAQ

Is a Certificate of Origin always required?

Not in every country, but it is usually needed for preferential tariffs under trade agreements, and customs may ask for it when origin is in doubt.

Who is responsible for FSVP?

The US importer: it must evaluate foreign suppliers, verify that products meet US safety standards and keep records.

Can I accept a supplier’s in-house COA?

For routine items it can be a reference, but for new suppliers or high-risk items, ask for a third-party lab report.

How do I verify a certificate?

Look up the certificate number on the certification body’s website and check that the factory name, address and validity match the actual producer.

Related Reading

Also see: Factory audits vs. product inspections、How to choose a Taiwan trading company

Sources

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