A practical, Indonesia-specific playbook for assigning and linking FSMA 204 Traceability Lot Codes through receiving, commingling, and processing—so your plant is buyer-ready in 2025 and fully compliant by the 2026 deadline.
If you export seafood to the U.S., 2025 is your readiness year. The FSMA 204 compliance date is January 20, 2026, but the reality is buyers are already asking for Traceability Lot Codes (TLCs) and sortable records. We’ve helped Indonesian processors put this in place on busy floors with mixed wild-caught and farmed supply. Here’s the exact playbook we’d use in your plant.
The three pillars of fast FSMA 204 readiness
- Clear TLC rules at each event. Decide who assigns the Traceability Lot Code, when to create a new one, and how to link parent-child lots. Don’t leave this to “the QC team will handle it later.”
- Minimal, consistent KDE capture. Record only the Key Data Elements you must capture at each Critical Tracking Event, and make sure they’re structured for a 24-hour FDA request.
- Simple tools that fit your floor. Start with a spreadsheet template and printed labels. Add GS1 barcodes or software when your team is ready.
Practical takeaway: Standardize TLC assignment and parent-child linking before you digitize. A messy process + software still equals mess.
Weeks 1–2: Map your flows and lock TLC rules
Start with how fish actually moves in your facility, not how an SOP says it should.
- Identify CTEs you control: First Receiver from vessels, Receiving from farms/collectors, Transformation (filleting, skinning, trimming, portioning, freezing, rework), and Shipping. If you produce Grouper Fillet (IQF), Yellowfin Saku (Sushi Grade), or Frozen Shrimp (Black Tiger, Vannamei & Wild Caught), you’re doing multiple transformation events.
- Define who assigns TLC at each step. We usually set Receiving to assign the first TLC for wild-caught (as First Receiver) and Production to assign a new TLC at each transformation.
- Choose a TLC format you’ll never regret. Keep it short, unique, and machine-friendly:
TLC format example: IDN-FHI01-20250115-YFT-0007
- Company/site: IDN-FHI01
- Date: 20250115 (YYYYMMDD)
- Species code: YFT (Yellowfin Tuna) or LJV (Vannamei), GRP (Grouper), etc.
- Sequence: 0007 for the day at that site
Two rules that save headaches:
- Never reuse TLCs for at least two years. FSMA 204 record retention is two years, so keep codes unique for that window.
- Don’t stuff too much meaning into the TLC. Store details like pond, vessel, and FAO area in your records, not inside the code.
Weeks 3–6: Capture KDEs with a spreadsheet + labels
You don’t need an ERP to start. We’ve seen teams succeed with a shared spreadsheet and printed labels.
A. First Receiver from fishing vessel (wild-caught)
- TLC assigned. You’re the TLC source.
- KDEs to capture and link to TLC:
- Vessel name and unique ID (license number or national ID)
- Harvest area (FAO 57/71 details), gear type, harvest start/end dates if available
- Landing port and date
- Species, quantity, unit, and unit of measure
- Your receiving location ID and date
B. Receiving from farm or pond (farmed shrimp/fish)
- If you’re the first packer, you assign the first TLC. If upstream packers assign a TLC, keep it and link it.
- KDEs:
- Farm/pond ID and harvest date
- Species, quantity, size grade
- Source company and location ID
- Your receiving location ID and date
C. Transformation (filleting, trimming, portioning, glazing, IQF, rework, repack)
- Create a new TLC.
- KDEs:
- Input TLCs and quantities consumed
- Transformation date and activity (e.g., fillet + IQF)
- Output TLC, product description, yield/quantity, unit
- Location ID (processing line or plant)
D. Shipping
- KDEs:
- Destination company and location ID
- Ship date
- Product description, quantity, unit
- All TLCs included on the shipment
Spreadsheet columns we use across events
- TLC, TLC Source, Event Type, Event Date, Company ID, Location ID, Product Description, Species Code, Quantity, Unit, Parent TLC(s), Child TLC, Vessel/Farm ID, Harvest Area, Harvest/Harvest End Date, Landing Port/Date, Transformation Type, Destination Company/Location, Ship Date, Reference Docs (invoice/packing list/GRN).
Pro tip: Keep Parent TLC and Child TLC columns side by side. Auditors and buyers love seeing the immediate link.
Need help mapping your specific flows or adapting the template to Grouper Bites (Portion Cut) vs tuna loins? We’re happy to share a working template and sample labels. If that’s useful, reach out via WhatsApp.
Weeks 7–12: Stress-test with commingling, rework, and a mock FDA request
Run a one-day simulation. Pick a busy production day and prove you can answer “where did this come from?” and “where did it go?” within 24 hours.
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Commingling test: Combine three vessel lots into one Red Snapper Portion (WGGS / Fillet) run. Create a new TLC for the output and list all input TLCs with consumed weights. That’s your parent-child link.
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Rework test: If you rework glaze or trim into Yellowfin Ground Meat (IQF), create yet another TLC and link it back to the reworked lot.
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Mock 24-hour request: Export your records to a single sortable file (CSV or Excel). The FDA accepts “electronic sortable spreadsheets.” XML or JSON are fine if your importer can use them, but a clean CSV usually solves 90% of cases.
Practical takeaway: The mock request is where weak links show up. If you can’t tie specific input TLCs to a finished Mahi Mahi Portion (IQF) lot, tighten your floor discipline before you buy new software.
Common questions we get from Indonesian processors
Who assigns the TLC in our supply chain?
- Wild-caught: The First Receiver on land assigns the first TLC. In Indonesia, that’s often the processor that buys from multiple handline boats.
- Farmed: The first packer can assign the TLC. If the farm or collector already assigned one, keep it and link forward. If not, assign at receiving.
How do we create a new TLC when we combine raw from multiple boats or ponds?
Create a fresh TLC at the transformation event. Record all input TLCs and quantities. Think of it as a parent-to-child relationship. One output TLC with multiple parents is normal in commingling.
Which KDEs must be linked to the new TLC during transformation?
- Input TLCs and consumed quantity per input
- Transformation date and activity
- Output product description and quantity
- Output TLC and location ID
- TLC Source for the new TLC (your company)
Can our production lot number serve as the FSMA 204 TLC?
Usually yes, if it’s unique for two years, never reused, and always referenced on documents. Many plants add a prefix so it’s clearly a TLC (e.g., TLC-IDN-FHI01-20250115-0007) and map legacy lot numbers in a column called “Internal Lot.”
Do we need GS1 barcodes to comply?
FSMA 204 doesn’t mandate GS1. But we recommend GS1-128 or GS1 DataMatrix with GTIN (AI 01) and Lot (AI 10) for cases and pallets. It makes scans reliable and cuts manual errors. Start on shipping labels first, then work back to WIP.
What records should we send to the U.S. importer so they can respond within 24 hours?
- Shipment-level TLC list with quantities and case/pallet mapping
- Transformation records showing parent TLCs to child TLCs
- First Receiver records from vessels or farm receiving details Send as a single CSV/Excel per shipment pack, or give importer portal access. Include TLC Source, Event Dates, Company/Location IDs, Vessel/Farm IDs, and FAO area when wild-caught.
How do we handle rework or repacking?
Treat each rework or repack as a transformation. New TLC created. Link the input TLC(s) to the new output TLC. If you break bulk cases into IVP/IWP formats like Cobia Fillet (IVP / IQF), create a new TLC for the repack batch.
Two non-obvious insights from the floor
- Pre-assign “receiving pre-lots” per vessel or pond before the truck arrives. We’ve found that this small step prevents ad-hoc mixing at the scale room, which is the number-one source of broken traceability.
- Keep TLC on every document the product touches: GRNs, WIP travelers, production sheets, CoAs, packing lists, and invoices. The FDA will accept electronic files, but your buyers audit paperwork trail too.
Five mistakes that kill seafood traceability (and how to avoid them)
- One TLC per day. It’s tempting, but it destroys linkages. Use multiple TLCs per species per day.
- Encoding pond or FAO into the TLC. Use records for attributes. Keep TLC simple and unique.
- Skipping parent-child in commingling. Always list each input TLC with quantities.
- Waiting for software to fix process. Nail your spreadsheet and labels first.
- Not preparing a one-page Traceability Plan. Buyers ask for it before they ask for data.
Your one-page Traceability Plan (template you can adopt now)
- Scope: Products on the Foods Traceability List you handle (e.g., tuna, snapper, shrimp).
- Roles: Who assigns TLC at receiving and transformations. Who validates KDEs. Who responds to FDA/importer requests.
- TLC format and uniqueness policy.
- CTE/KDE list: First Receiver, Receiving from farms, Transformation, Shipping.
- Record retention: Two years minimum. Sortable format within 24 hours.
- Technology: Spreadsheet first, GS1 labels on cases/pallets, optional system integration later.
If you’d like us to sanity-check your plan against your product mix, just give us a call. We can tailor the template to mixed lines like Goldband Snapper Fillet and Kingfish Fillet (Portion Cut / IQF) without slowing production.
Bottom line
FSMA 204 isn’t a paperwork exercise. It’s a production discipline. Assign TLCs where they make sense, link parents to children at every transformation, and keep KDEs in a clean, sortable file. Do that in 2025 and you’ll be audit-ready before most of the market. And your buyers will notice.