US FSMA 204 · Seafood

FSMA 204 from vessel to counter.

FDA Food Traceability Rule · finfish, crustaceans and molluscan shellfish on the FTL · compliance extended to 20 July 2028.

Seafood is the Food Traceability List's hardest case: product changes hands fast, gets transformed early and often, and begins its record at sea. FSMA 204 makes the first land-based receiver responsible for capturing origin data — vessel, catch area, harvest date — and every subsequent hop must keep the chain intact to 20 July 2028's compliance date and beyond.

FSMA 204FTL: seafoodFirst receiverCTEs & KDEs20 Jul 2028
What the rule requires

The record starts at the dock.

First-receiver capture

The first land-based receiver records harvest-origin KDEs — vessel or harvest location identification, harvest date — the data every later record depends on.

Transformation events

Filleting, portioning, breading, canning: each transformation assigns a new traceability lot code linked to its inputs. Seafood transforms more than almost any FTL food.

Cold-chain-compatible records

Records must survive an environment of ice, brine and speed. Capture that requires clean hands and a keyboard will simply not happen on a processing floor.

The same 24-hour spreadsheet

As with all FTL foods: FDA gets an electronic sortable spreadsheet of the relevant CTEs/KDEs within 24 hours of request.

The dates

The timeline, as it stands.

The compliance date is 20 July 2028, extended by FDA. Import-heavy seafood chains should assume their US customers will push the data requirement upstream to foreign processors well before the date.

Rule final2022
Extended compliance date20 Jul 2028
Buyer mandates upstreamalready moving
What to do now

Three moves that de-risk the deadline.

01 · Step

Fix the first receipt

Get vessel, catch-area and harvest-date capture working at the dock — electronically. Everything downstream inherits this record's quality.

02 · Step

Chain the transformations

Map every cut, pack and repack as a transformation event with linked lot codes. This is where seafood traceability chains break.

03 · Step

Push the standard upstream

If you import, your foreign processors are inside your record. Hand them the capture standard now, before the requirement lands as a crisis.

How Aeroz fits

Records that survive ice, brine and speed.

Aeroz puts the traceability lot code on a sealed chip carrier at tote, case or pallet level — readable through ice and gloves with a tap or dock pass, writing each CTE as an EPCIS 2.0 event automatically. The chain from vessel to counter assembles itself, and the 24-hour FDA request becomes an export rather than an archaeology project.

FAQ

FSMA 204 for seafood, answered.

Which seafood is on the Food Traceability List?

Finfish, crustaceans and molluscan shellfish — fresh and frozen, whole and processed. Most commercial seafood operations touch the list somewhere.

Who is the 'first receiver' and why does it matter?

The first land-based facility that takes ownership of the catch. FSMA 204 assigns it the harvest-origin KDEs — vessel identification, catch area, harvest date — that anchor every downstream record.

How do transformations affect lot codes?

Each transformation — filleting, portioning, canning — assigns a new traceability lot code linked to its input lots. Break one link and FDA's traceback stops at your door, which is exactly where you do not want it to stop.

Can imported seafood comply?

Yes, but the record must start abroad: foreign processors capture origin KDEs and pass them with product. US importers should be pushing the capture standard upstream now, not in 2028.

Readiness audit

Know exactly where you stand — in 14 days.

A fixed-fee Aeroz audit maps your products against fsma 204 for seafood requirements and returns a written readiness assessment, a data-mapping review, and a scoped pilot plan with cost and timeline.

Fixed fee 14-day written report No commitment to proceed