The Benefits of Navigating the Complex Waters of Seafood Traceability
January 5, 2024
Meeting the requirements of FDA’s Food Traceability Rule, FSMA 204, is particularly complex for seafood producers. Seafood is one of the most highly traded food commodities in the world. It might pass through several countries and a dozen different companies before reaching a dinner plate.
Even with all the challenges, however, source-to-table food traceability promises significant benefits by addressing challenges that have long been faced by this massive, global industry.
On November 13, 2023, iFoodsDS wrote about the importance of looking beyond the challenges of FSMA 204, discussing the need to step back and recognize that this work will yield benefits far beyond compliance with current regulations. It will lead you to a new way of doing business and a new relationship with your customers and suppliers.
For the seafood industry, in particular, traceability will help mitigate risks beyond food safety. It will give the industry tools to help prevent fraud, mislabeling and environmental damage.
The Tools that FSMA 204 Provides
The Food Traceability Rule establishes additional record-keeping requirements for the producers of foods on the Food Traceability List. For the seafood industry, this list covers companies that manufacture, process, pack, or hold finfish (fresh, frozen, and smoked), crustaceans, mollusks, and bivalves.
They must capture, maintain, and share specific information about the food – called Key Data Elements (KDEs) – for certain Critical Tracking Events (CTEs) in the food supply chain with their trading partners. These KDEs help describe the product and enable the FDA to more easily trace it forward and back across the full supply chain.
Critical Tracking Events (CTEs)
The Critical Tracking Events pertaining to the seafood supply chain that require KDEs begin with the first land-based receiver of the seafood but the data points they capture are from earlier in the chain, such as the species of fish and where and when it was caught. The first land-based receiver assigns the Traceability Lot Code (TLC) to identify the product. The CTEs that follow the land-based receiver are shipping, receiving and transformation, which occurs when and if a a new food is produced from the fish. The TLC remains the same as the product moves through the supply chain unless there is a transformation event, in which case the new product gets a new TLC.
Each entity in the seafood supply chain, including the packer, shipper, processor, distributor, and retailer, is responsible for collecting data from one or more CTEs. For example, a processor will need to collect Receiving KDEs from their supplier, they will need to share Shipping KDEs with their distributor, and they might need to track Transformation KDEs if they transform the product (e.g. heading, gutting, tailing, or filleting).
There Are Resources to Help
It sounds complicated but there are resources online that explain this process in detail. The FDA has posted a video giving an example of the seafood supply chain, tracing the journey of fresh tuna bound for a restaurant in the form of tuna steaks, which is an example of transformation. The video and accompanying text clearly illustrate the CTEs for which KDEs are required.
And New Era Partners explains when Transformation KDEs are required.
Additionally, all entities covered by the rule are required to maintain a Traceability Plan that includes descriptions of the procedures used to comply with the rule.
Seafood Fraud and Mislabeling
The overarching goal of the Food Traceability Rule is to protect consumers from foodborne illness by enabling government and industry to rapidly identify the source of a contaminated food, shorten outbreaks of foodborne illness, and facilitate faster and more targeted recalls.
For the seafood industry, enhanced traceability will also help reduce fraud. It’s well known that a large number of the fish captured, both legally and illegally, are mislabeled.
According to a 2019 Oceana report, 21 percent of seafood tested was mislabeled. Oceana collected more than 400 samples in 24 states and the District of Columbia, including from restaurants, large grocery stores and smaller market. The sea bass and snapper tested had the highest percentage of mislabeling at 55 and 42 percent. Other fish found to be mislabeled included Alaskan halibut (actually Greenland turbot) and Dover sole (actually walleye). This issue creates a host of problems, not the least of which is establishing accurate pricing.
FSMA 204 And The Transparency It Creates
The global data network that FSMA 204 will create means that information that clearly identifies the food will be shared throughout the supply chain, from when it leaves the fishing vessel to when it arrives at a restaurant or grocery store.
Restaurant owners understand the importance of transparency when it comes to serving their patrons what’s on the menu vs. appearing to deceive by serving something else. One bad review can damage a restaurant’s reputation.
The Value of Consumer Trust
Consumer trust is critical for the food industry, and Americans eat a lot of fish. According to the National Fisheries Institute, Americans ate 20.5 pounds of seafood per capita in 2021. A study released in October 2023 by the consulting firm Deloitte showed that fresh food in general is important to most consumers, who believe it minimizes health risks and contributes to weight loss.
And now, more than ever, consumers care about understanding the provenance of the products they buy and the companies they are supporting. This interest comes as a response to concerns around food safety, ethical sourcing, data security, and environmental impact, according to a 2021 report from Forbes.
Transparency Can Differentiate Your Brand
Retailers recognize that transparency can differentiate their brands. In the thin-margin seafood industry, where cents per pound makes the difference between profit and loss, traceability can also add value to products by giving them an origin story. Telling stories about fishermen or farmers on product packaging instills confidence and promotes brand loyalty with consumers. These stories cannot be told without tracing the product through the supply chain.
Impact on the Environment
Illegal, Unreported, and Unregulated Fishing (IUU)
An October 2023 report by the World Benchmarking Alliance states that seafood is the sector with the biggest impact on marine biodiversity. It is estimated that 20% of the world’s catches originate from illegal, unreported, and unregulated (IUU) fishing.
According the U.S. Customs and Border Protection, IUU fishing threatens the stability of marine fisheries, decreases food security of coastal communities, and poses increased risk to endangered and protected species. The National Oceanic and Atmospheric Administration notes that these practices include intruding on protected marine areas and fishing in a manner that is inconsistent with conservation measures there.
A High Percentage of Seafood is Caught in Violation of Regulations
The World Wildlife Federation also reports that too much of the fish that comes to market is caught in violation of regulations meant to ensure that fish stocks remain healthy, and marine and coastal environments are protected. WWF points to an International Trade Commission report that 11% of total U.S. seafood imports in 2019 were derived from IUU fishing. (According to the National Oceanic and Atmospheric Administration, the U.S. imports 70–85 percent of its seafood).
WWF is promoting increased traceability of seafood around the world to enable businesses to trace seafood back to where, how, and when it was caught and engage fishing communities in traceability initiatives.
Value In Standards and Data-Sharing
The uniform standard for digital data collection and sharing established by FSMA 204 creates seafood traceability systems that will provide specific information about the origin, species, harvesting and processing of seafood products. Companies will know they are sourcing legally-caught seafood and not supporting practices that deplete fish stocks and damage marine ecosystems.
Returning to the FSMA 204 compliance challenges, it’s important to realize that you may already be on the path to meeting these requirements, with processes in place that reflect an awareness of consumer concerns.
For example, a growing number of seafood companies and business partners, including iFoodDS, have committed to traceability, working with various non-governmental organizations to develop the Global Dialogue on Seafood Traceability standards. These seafood-specific standards are based on GS1 standards. GS1 is the non-profit standards organization that provides a common foundation for business by uniquely identifying, accurately capturing, and automatically sharing vital information about products, locations, assets and more.
Companies can meet CTE and KDE data capture requirements by using existing GS1 Standards. A blog on the iFoodDS website outlines how those of you who already follow GS1 standards in your processes have a head start towards FSMA 204 compliance.
You don’t have to take this journey alone. iFoodDS and New Era Partners have resources to help you find the best traceability and technology solutions. For more information, visit iFoodDS’ FSMA Rule 204 Information Hub and explore the resources available from New Era Partners.
There is still work to be done to meet the January 2026 FSMA 204 compliance deadline. But once your organization achieves end-to-end traceability, you will be part of a transparent food supply chain and have the data you need to make informed decisions about your business, giving your customers the confidence they deserve in the quality and safety of the food you provide.