FSMA 204 from vessel to counter.
FSMA 204 for seafood is the part of FDA's Food Traceability Rule that covers finfish, crustaceans and molluscan shellfish, requiring key data from first land-based receiving through every later handoff.
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. Every later handoff must keep that record linked; compliance is 20 July 2028.
FSMA 204 for seafood, in three facts.
FDA Food Traceability Rule · finfish, crustaceans and molluscan shellfish on the FTL · compliance extended to 20 July 2028.
Finfish, crustaceans and molluscan shellfish, fresh or frozen, are on FDA's Food Traceability List.
Source: FDA, Food Traceability ListFDA will not enforce the Food Traceability Rule (FSMA section 204) before 20 July 2028.
Source: FDA, FSMA final rule on traceability recordsUnder FSMA 204 a traceability lot code is assigned at initial packing, first land-based receiving or transformation, and travels with the food.
Source: 21 CFR Part 1, Subpart S
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 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.
Three moves that de-risk the deadline.
Fix the first receipt
Get vessel, catch-area and harvest-date capture working at the dock — electronically. Everything downstream inherits this record's quality.
Chain the transformations
Map every cut, pack and repack as a transformation event with linked lot codes. This is where seafood traceability chains break.
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.
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.
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.
Know exactly where you stand — in 14 days.
A fixed-fee Aeroz audit maps your products against FSMA 204 requirements for seafood and returns a written readiness assessment, a data-mapping review, and a scoped pilot plan with cost and timeline.