DTC & E-commerce Imports: PN, Returns, and Recordkeeping

Introduction

The direct-to-consumer (DTC) and e-commerce landscape has transformed how international brands reach US consumers. With just a few clicks, customers can order products from anywhere in the world and have them delivered to their doorstep. But behind this seamless experience lies a complex web of product tracking, returns management, and recordkeeping requirements that importers must navigate to stay compliant and profitable.

For businesses shipping products directly to US consumers, understanding these operational aspects isn’t just good business practice—it’s essential for regulatory compliance and customer satisfaction.

Product Numbers (PN)

What Are Product Numbers?

Product Numbers (PNs), often called SKUs (Stock Keeping Units) or UPCs (Universal Product Codes), are unique identifiers assigned to each product variant. Think of them as your product’s unique fingerprint in the digital retail world.

For DTC e-commerce importers, these identifiers serve as the backbone of inventory tracking, especially when dealing with multiple product variations like different flavors, sizes, or formulations of dietary supplements.

Why PNs Matter for E-commerce Imports

Product numbers do more than just identify what’s in a box. They’re crucial for:

• ✔️ Inventory Tracking: PNs allow you to monitor stock levels across warehouses and fulfillment centers, preventing both stockouts and overstock situations.
• ✔️ Customs Clearance: When importing products, customs officials often reference your PNs to verify that what’s being shipped matches what’s declared.
• ✔️ Returns Processing: When a customer returns a product, the PN helps quickly identify the item, its original price, and where it belongs in your inventory.
• ✔️ Data Analysis: PNs enable you to track which products are selling well and which aren’t, helping you make smarter purchasing decisions.

A supplement company I worked with reduced their customs delays by 40% simply by implementing a consistent PN system that aligned their internal inventory records with their customs documentation.

Returns Management

For e-commerce importers, returns can be particularly challenging due to international shipping costs, customs considerations, and FDA compliance issues. A poorly managed returns process can quickly erode profits and damage customer relationships.

Creating Effective Return Policies

Your return policy should balance customer satisfaction with regulatory compliance and business sustainability. Key elements to include:

• ✔️ Clear timeframes (e.g., “30 days from delivery date”)
• ✔️ Condition requirements (e.g., “unopened and in original packaging”)
• ✔️ Who covers return shipping costs
• ✔️ Special provisions for international returns
• ✔️ FDA considerations for food and supplement returns

For dietary supplements and food products, you’ll need additional policies addressing product safety and quality concerns. For example, temperature-sensitive products may need different return protocols than shelf-stable items.

Streamlining the Returns Process

An efficient returns management system for e-commerce imports should include:

• ✔️ Easy-to-access return labels: Consider including pre-printed return labels or offering digital return label generation through your website.
• ✔️ Clear return instructions: Provide step-by-step guidance in multiple languages if you’re serving international markets.
• ✔️ Tracking capabilities: Both you and your customers should be able to track returned items throughout the process.
• ✔️ Returns assessment protocols: Establish clear guidelines for evaluating returned products, especially for food and supplement items that may have safety implications.
• ✔️ Regulatory documentation: For regulated products like dietary supplements, you’ll need to maintain records of returns for potential FDA inspection.

One DTC beauty brand I consulted with reduced their returns processing time by 60% by implementing a digital returns portal that automatically generated customs-compliant return documentation.

Recordkeeping Requirements

Perhaps the most critical aspect of DTC e-commerce importing is proper recordkeeping. Beyond being good business practice, robust record maintenance is required for FDA compliance and customs verification.

Legal Requirements for Importers

E-commerce businesses importing products to the US must maintain records related to:

• ✔️ Product source and manufacturing information
• ✔️ Import documentation and customs entries
• ✔️ Product testing and quality assurance
• ✔️ Customer transactions and shipping records
• ✔️ Returns and complaints
• ✔️ FSVP (Foreign Supplier Verification Program) documentation for food and supplements

For FDA-regulated products, the recordkeeping requirements are especially stringent. The FDA may request access to your records during inspections or in response to product complaints.

Essential Records for DTC Importers

At minimum, your recordkeeping system should include:

• ✔️ Sales transaction records: Complete purchase details including customer information, product PNs, quantities, and dates.
• ✔️ Inventory records: Comprehensive tracking of all product movements, including receipts, shipments, returns, and disposals.
• ✔️ Supplier documentation: Information about your product sources, including manufacturing facilities, quality certifications, and testing results.
• ✔️ Customs documentation: Copies of all import entries, duties paid, and related correspondence.
• ✔️ Returns documentation: Detailed records of all returns, including reason codes, resolution, and disposition of returned products.

Recordkeeping Best Practices

To maintain FDA compliance for e-commerce retailers, implement these practices:

• ✔️ Integrated systems: Use software that connects inventory, sales, shipping, and returns data to minimize manual entry errors.
• ✔️ Regular backups: Store records securely with regular backups, especially for FDA-required documentation.
• ✔️ Retention policies: Establish clear guidelines on how long different types of records should be kept (FDA requirements typically range from 2-5 years).
• ✔️ Staff training: Ensure everyone handling products knows their recordkeeping responsibilities.
• ✔️ Audit readiness: Organize records so they can be easily retrieved during FDA inspections or customs audits.

A food importer I worked with avoided significant FDA penalties by implementing a cloud-based recordkeeping system that made it easy to demonstrate compliance during an unexpected inspection.

Regulatory Considerations for Different Product Categories

Different product types face varying levels of scrutiny when imported through DTC channels:

• ✔️ Food products: Subject to FDA registration, labeling requirements, and possibly FSVP compliance requirements.
• ✔️ Dietary supplements: Face strict labeling regulations, structure/function claim limitations, and ingredient restrictions.
• ✔️ Cosmetics: Require ingredient listings and may need to submit to FDA’s Voluntary Cosmetic Registration Program.
• ✔️ Medical devices: Subject to classification-based requirements, from simple registration to premarket approval.

Conclusion

Managing product numbers, returns, and recordkeeping might seem like back-office functions, but they’re critical to success in DTC e-commerce importing. A well-organized system helps you stay compliant with FDA regulations, manage inventory effectively, handle returns efficiently, and maintain the documentation needed for smooth customs clearance.

By implementing robust systems for these operational aspects, you’ll not only avoid regulatory headaches but also create a smoother customer experience that builds trust and encourages repeat business.

Are you struggling with the complexities of importing your products directly to US consumers? Global Import Agent specializes in helping international brands navigate FDA compliance requirements for e-commerce operations. Our experienced team can help you establish compliant recordkeeping systems, develop return policies that satisfy both customers and regulators, and ensure your product numbering system supports efficient inventory management and customs clearance.

Whether you’re just launching in the US market or looking to improve your existing compliance program, we provide affordable, practical guidance tailored to your specific product category. Contact us today for a consultation and discover how we can help your DTC business thrive while staying on the right side of US import regulations.