The Food Safety Modernization Act changed how the FDA approaches food safety — from reaction to prevention. For the seafood industry, that shift created new record-keeping requirements that fall on everyone from large processing plants to independent fishermen.
The regulations are complex. The plain-language version for independent harvesters is not.
What You Actually Need to Know
If you harvest seafood species on the FDA's Food Traceability List — which includes salmon, tuna, shrimp, crab, mahi-mahi, grouper, snapper, bivalve mollusks, and smoked fish — you need to keep certain records starting January 2026.
What to Record at Harvest (Critical Tracking Event #1)
For each lot of seafood you harvest:
1. Location — fishing area (ICES area, fishing zone, or coordinates)
2. Date — date of harvest
3. Species — common name and scientific name
4. Vessel — name and official number
5. Quantity — weight or count
6. Lot code — a unique identifier for this lot that you assign
That's the core. Write it down, keep the record for two years, and be able to produce it within 24 hours of an FDA request.
If You Process on Vessel
If you gut, head, fillet, or smoke fish on your vessel, you have additional records to keep for that processing step.
Exemptions
- Very small businesses: Less than $1M in annual sales averaged over three years. You still need to maintain some records but with reduced requirements.
- Direct to consumer: If you sell directly to consumers (farmers markets, CSF, restaurant owner who is the end consumer), those transactions are exempt.
- Restaurants: Restaurants are exempt from the rule but their suppliers are not.
The Practical Path
The simplest way to comply without drowning in paperwork:
1. Use a traceability app — Wholechain is designed for exactly this. Record your harvest on your phone, generate a lot code, and the records are stored and compliant.
2. Talk to your buyer — increasingly, buyers require GDST-compliant traceability as a condition of purchase. Getting ahead of this protects your market access.
3. Contact your extension agent — USDA and Sea Grant have compliance resources for small producers.
The Bigger Picture
FSMA compliance is the floor, not the ceiling. The producers who will thrive are not the ones who barely comply — they are the ones who use traceability as a marketing advantage, as a price premium justification, as proof of quality in a world where fraud is rampant.
Your records are your story. Tell it well.
