FSSC 22000 for Indonesian Seafood: 2026 Essential Guide

A practical, step-by-step playbook to run and pass a time‑bound seafood mock recall and mass balance drill under FSSC 22000 v6. Built from our on‑the‑floor experience in Indonesian tuna, shrimp, and reef fish plants.

If you process or export seafood from Indonesia, your FSSC 22000 v6 audit will include a traceability test and a recall drill. The difference between a smooth two‑hour exercise and a painful all‑day scramble usually comes down to preparation. We’ve run dozens of drills across tuna, shrimp, and reef fish lines. The system below is what we use to consistently hit 100 percent mass balance inside a tight timeframe.

What FSSC 22000 v6 expects in a seafood mock recall

Auditors want to see that you can trace back to origin and trace forward to all destinations for a defined product and lot. They expect a time‑bound objective you set. Most plants target two to four hours. They also look for mass balance. That is proof that the quantity received equals the quantity produced, in inventory, sold, reworked, or scrapped. The drill must include suppliers, internal processes, outsourced steps like third‑party cold storage, and customers.

In practice, the seafood traceability test under FSSC 22000 v6 checks three things.

Can you retrieve the right records quickly and completely.
Do your lot and batch codes link correctly from catch or health certificate to finished packs and shipments.
Can you demonstrate 100 percent mass balance within your defined time window.

Takeaway. Define a two‑hour target. Build your trace‑back and trace‑forward pathways before audit day. Practice.

The three pillars that make a recall drill pass every time

Our experience shows you only need three pillars to make the recall drill repeatable.

Lot architecture that never breaks Use a lot code pattern that embeds the receiving date and source. For example: Species code + supplier code + receiving date + sequence. Keep it simple and readable. If you export EU tuna or shrimp, add a cross reference to the Health Certificate or Catch Certificate in your ERP or a controlled register. For product lines like Grouper Fillet (IQF) or Yellowfin Saku (Sushi Grade), ensure the same parent lot appears on both carton and IVP labels, and that any repack creates a new child lot with a clear link.
A records map you can pull in minutes Create a one‑page “Records Map” from receiving to shipping. List exact record names, where they live, and who owns them. Example sections: receiving weigh tickets and supplier tags. EU or KKP Health Certificate and Catch Certificate references. production batch sheets. thawing logs. trimming and yield sheets. rework logs. metal detector and CCP records. WIP and cold store movement. finished goods stock. pick lists and loading tallies. invoices, packing lists, and BOL. When you must run a recall drill, you are not hunting. You are following the map.
A mass balance engine you trust Build a simple spreadsheet with inputs and assumptions agreed in your HACCP system. Inputs come straight from your production records. For shrimp, include glaze and drip. For tuna, include trim, blood meat, and recovered rework. Decide up front which yields and allowances you will accept. Lock formulas and version‑control the file.

Takeaway. Design your lot code. Finish a one‑page Records Map. Prepare the mass balance calculator. Then train supervisors to use all three.

A two‑hour recall drill playbook that works

Here is a practical recall drill procedure we use for mixed species plants.

T‑0 to 30 minutes. Define the scope

Pick one SKU and one lot that actually shipped. Examples. Frozen Shrimp (Black Tiger, Vannamei & Wild Caught) HLSO 21/25, or Mahi Mahi Fillet skinless IQF.
State time goal. Two hours. State objective. 100 percent mass balance.
Assign roles. Trace‑back lead. Production records lead. Warehouse and dispatch lead. QA controller for evidence.

T‑30 to 75 minutes. Trace back and trace forward

Trace‑back. Pull receiving ticket, supplier CoA, landing note, KKP Health Certificate, Catch Certificate if the market requires it, and assign the internal lot. Snap photos of labels used at receiving. For tuna, collect SIMP data if exporting to the US. For reef fish like Grouper WGGS (Whole Cleaned), include vessel and area.
Internal mapping. Retrieve batch sheets, WIP movements, trimming yields, rework declarations, CCP logs. Note all child lots. Confirm segregation when multiple lots share a line.
Trace‑forward. List all cartons in stock and all shipments. Pull pick lists, loading tallies, invoices, and BOL. Verify customer names and quantities.

T‑75 to 105 minutes. Mass balance

Input received net weight by lot.
Subtract declared waste streams and by‑products. Examples. heads and frames for Red Snapper Head (IQF). belly trim used for Yellowfin Ground Meat (IQF).
Add or subtract moisture where applicable. For shrimp, apply glaze percent and actual drip loss from QA checks.
Reconcile finished goods. On hand. Shipped. At third‑party cold store.
Rework. Allocate proportionally if mixed into new lots.

T‑105 to 120 minutes. Evidence pack and debrief

Compile an “evidence pack” PDF. Scope and objective page. Trace‑back set. Internal manufacturing set. Trace‑forward set. Mass balance sheet with sign‑off. Corrective actions if gaps were found.
Debrief in five minutes. Note what slowed you down and fix it this week.

Takeaway. Timebox each phase. Do not chase perfection during the drill. Capture gaps. Close them after.

How do I prove mass balance for tuna or shrimp products?

Keep it arithmetic and transparent. Here is a simplified example.

Tuna loin lot received. 10,000 kg net.
Waste and by‑products. 1,200 kg heads and bones. 600 kg trim to ground meat. 100 kg sanitation loss.
Finished goods. 7,700 kg Yellowfin Steak and Yellowfin Saku (Sushi Grade).
Inventory split. 2,200 kg shipped. 5,100 kg in cold store. 400 kg at third‑party. If those numbers tie to physical and paperwork, and all child lots are linked, you have 100 percent mass balance.

For shrimp, include glaze. If you produced 5,000 kg IQF 20 percent glaze, auditors will expect you to show both net and gross and how QA verified glaze and drip.

Which records should I prepare for a trace‑back and trace‑forward drill in Indonesia?

We recommend a pre‑built evidence pack template that lists the exact documents and owners.

Origin. Supplier delivery note. receiving weight ticket. supplier lot. KKP Health Certificate number. Catch Certificate or SIMP data if applicable.
Production. batch sheets. thawing logs. yield and trim sheets. rework declarations. CCP monitoring. sanitation release. metal detector checks.
Storage. WIP and cold store movement logs. finished goods inventory reports. third‑party cold store confirmations.
Dispatch. pick list. pallet map. loading tally. invoice and packing list. Bill of Lading or airway bill.
QA. label proofs, carton and IVP labels. test results. deviation and corrective actions.

How do I link EU or KKP certificates to my internal lot codes?

In my experience, a simple cross‑reference table prevents most headaches.

At receiving, record Health Certificate and Catch Certificate numbers against your internal lot in a controlled register. Attach scanned PDFs and photos of pallet labels.
Print a short reference on pallet cards or use a QR code that points to the register entry.
If lots are split or merged, maintain a child‑parent mapping with certificate numbers inherited. Never lose the chain at repack. This makes the auditor’s traceability test a straight line from EU CATCH or KKP certificate to your cartons.

Can I pass the FSSC traceability test with manual logs instead of barcodes?

Yes. We have seen SMEs pass with clean manual logs. The keys are legibility, unique identifiers, and control of corrections. Use permanent ink. No blank spaces. Initial and date corrections. Keep registers bound or controlled electronically. If you can, print simple carton labels with lot and time codes. Barcodes speed you up, but completeness wins audits.

How do I handle mixed lots or rework in a seafood recall drill?

Two rules. Declare and allocate.

Declare. Every time rework is created or used, a supervisor signs a rework log that states source lot, weight, date, and destination batch.
Allocate. If mixed lots feed a batch, allocate finished cartons proportionally back to each source lot. Your mass balance sheet should show the math. For example, 60 percent Lot A and 40 percent Lot B into a Cobia Fillet (IVP / IQF) run means cartons inherit that split for trace‑forward.

Who must be notified in Indonesia during a real seafood recall?

Start with your customers and importers immediately. Internally, activate your recall team. For domestic distribution, coordinate with BPOM for recall classification and public notification. For export consignments, notify your importers and the competent authority of the importing country. Coordinate with the relevant Indonesian competent authority for fishery products, typically the fish quarantine and quality units under KKP, to address Health Certificate implications for affected lots. If the product entered the US, contact your importer for FDA reporting. For the EU, your importer will interact through the competent authority and RASFF if required. Keep your regulator contact list up to date in the recall SOP.

Note. This is operational guidance, not legal advice. Always follow your customers’ and authorities’ instructions.

Common mistakes that kill a recall drill

Missing child‑parent links after repack or portioning. Example. Splitting Goldband Snapper Portion cartons into mixed pallets without updating the lot map.
No proof of segregation when two receiving lots run on one line. Use start and stop times and documented line clearance.
Glaze and moisture assumptions that do not match QA checks for shrimp.
Third‑party cold store not integrated. Get their stock report signed with your lot codes, not just their internal IDs.
Overcomplicated lot codes. If supervisors cannot decode it, it will break under pressure.

Fix these now and your next seafood mock recall will feel routine.

Quick wins you can implement this week

Build a one‑page Records Map and post it in QA, production, and warehouse.
Lock a mass balance worksheet with agreed yields for your top five SKUs. If you want a simple template, need help with mixed‑lot allocation, or want to sanity‑check your glaze math, reach out via WhatsApp. We can share what we use on our lines.
Update your recall SOP with regulator contacts per market and a two‑hour drill target. Then schedule a drill for a product that actually shipped, like Red Snapper Portion (WGGS / Fillet) or Skipjack Cube (WGGS / IQF).

If you are a buyer assessing Indonesian supply and you care about traceability under FSSC 22000 v6, browse a few of our export‑ready SKUs and see how we carry lot integrity from vessel to carton. View our products.

Practical takeaway. Set a two‑hour objective, map your records, and pre‑build mass balance. Do a real drill before the audit. You’ll be surprised how quickly the chaos disappears when the system is this simple.