FDA refusal charge NO PROCESS: no process filing

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The NO PROCESS charge appeared in 934 FDA import refusals between 2020 and 2026 — 3.5% of all 26,358 US import refusals. The charge is a process, registration or approval failure, not a contaminant or pathogen found in the product. The origins cited most often are China, Mexico, India. The most-affected product category is Vegetables and Vegetable Products. Volume in 2025 was up 61% on 2024.

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What FDA's charge says

NO PROCESS is the code FDA prints on a refusal; below is the charge language FDA publishes for it, quoted from its charge table, with the sections of the FD&C Act it cites.

The article is subject to refusal of admission pursuant to Section 801(a)(3) in that the manufacturer's failure to file a scheduled process demonstrates that the product is not being manufactured under the mandatory provisions of 21 CFR Part 108 and therefore appears to have been manufactured, processed, or packed, under insanitary conditions whereby it may have been rendered injurious to health.

Sections 402(a)(4), 801(a)(3); ADULTERATION

NO PROCESS refusals by year

YearRefusalsYoY
2020105—
2021134+27.6%
202296-28.4%
2023116+20.8%
2024123+6.0%
2025198+61.0%
2026162—YTD
Total934

Origins most often refused under NO PROCESS

#Origin countryRefusals
1China125
2Mexico67
3India63
4South Korea43
5Egypt38
6Canada31
7Taiwan31
8Japan30
9Vietnam30
10Thailand28
11Guatemala26
12Italy23
13Turkey20
14Brazil18
15Philippines16
16Spain16
17Jordan15
18United Kingdom15
19Honduras14
20United States14
21Jamaica12
22Yemen12
23France11
24Myanmar11
25Poland11
26Portugal11
27Colombia9
28Pakistan9
29Nigeria8
30Syria8

Product categories refused under NO PROCESS

#Product categoryRefusals
1Vegetables and Vegetable Products199
2Fruit and Fruit Products158
3Multiple Food Dinners, Gravies, Sauces, and Specialties (Total Diet)89
4Milk, Butter, and Dried Milk Products86
5Fishery/Seafood Products71
6Dressings and Condiments60
7Soft Drinks and Waters49
8Bakery Products, Doughs, Bakery Mixes, and Icings23
9Coffee and Tea23
10Filled Milk and Imitation Milk Products16
11Vitamins, Minerals, Proteins, and Unconventional Dietary Specialties for Humans15
12Snack Food Items (Flour, Meal, or Vegetable Base)14
13Spices, Flavors, and Salts14
14Whole Grains, Milled Grain Products, and Starch14
15Baby (Infant and Junior) Food Products13

Latest refusals citing NO PROCESS

About NO PROCESS

What does the FDA import refusal charge NO PROCESS mean?

FDA uses NO PROCESS for: no process filing. Its published charge language reads: “The article is subject to refusal of admission pursuant to Section 801(a)(3) in that the manufacturer's failure to file a scheduled process demonstrates that the product is not being manufactured under the mandatory provisions of 21 CFR Part 108 and therefore appears to have been manufactured, processed, or packed, under insanitary conditions whereby it may have been rendered injurious to health.”

Is NO PROCESS a food safety finding?

No. NO PROCESS is a process, registration or approval failure: the charge records a missing filing, registration, approval or process control, not a contaminant or pathogen found in the product. This site counts a refusal citing it alone with paperwork. It can still mean the product cannot lawfully be sold in the US.

What happens to a shipment refused under NO PROCESS?

Under section 801(a) of the FD&C Act a refused entry has to be exported or destroyed, normally within 90 days of the notice of refusal. Bringing a product into compliance, for instance by relabelling, is something the importer asks FDA for before the decision is final. The notice itself and FDA's guidance govern a particular case; this page describes the published data and is not legal advice.