The United States seafood industry is bracing for the implementation of stringent traceability requirements under the Food Safety Modernization Act (FSMA), set to take effect in 2026. Despite the impending deadline, concerns linger regarding the industry's preparedness to comply with the new regulations.

Enacted in 2011, the FSMA marked a significant overhaul of the nation's food safety laws, empowering regulatory agencies with enhanced tools and authority to ensure adherence to rigorous standards. Of particular concern for the seafood sector, heavily reliant on imports, is Rule 204, which imposes heightened traceability requirements.

Trade experts, convening at the 2024 Seafood Expo Global in Barcelona, Spain, from April 23 to 25, underscored the industry's lack of readiness for the impending regulatory changes. Many industry stakeholders, despite guidance from the Food and Drug Administration (FDA), remain unconvinced that the legislation will come into full force, according to remarks made by Trace Register President Heath England during the "Regulatory Pitfalls and Traceability Requirements for Exporting Seafood Into the U.S. Market" panel.

England highlighted a prevailing sentiment within the industry, noting that some entities hold onto hopes of legislative repeal or modification. However, he cautioned against complacency, emphasizing that the law is already in effect and urging stakeholders to take proactive measures to ensure compliance.

One major challenge cited by England is the misconception among seafood producers who expect intermediaries to handle compliance. He clarified that under FSMA, manufacturers and producers bear the responsibility of generating and maintaining requisite traceability information to conduct business in the U.S.

Central to FSMA compliance is the assignment of traceability lock codes (TLCs) to seafood products at the point of initial harvest, effectively documenting their origins. These codes undergo modification only during product transformation, enabling swift traceback to the producer.

The possession-based nature of FSMA, as opposed to ownership-based frameworks, further complicates compliance efforts. England noted that traceability information must emanate from wherever the physical product is located, potentially posing challenges for logistics services.

In response to the impending regulatory landscape, Trace Register announced a strategic partnership with ReposiTrak in mid-April 2024 to facilitate compliance with Rule 204 traceability requirements. This collaboration enables the seamless exchange of data between the two entities, empowering seafood suppliers to effortlessly transmit FDA-mandated information to retailers and wholesalers.

ReposiTrak Chairman and CEO Randy Fields emphasized the feasibility of FSMA 204 compliance within existing supply chains, minimizing the need for additional burdensome efforts. The ReposiTrak traceability network promises standardized data organization across various FSMA 204 categories, ensuring uniform transparency for seafood, produce, and deli products alike.