Indonesian Seafood FDA Labeling: 2026 Complete Guide

A practical, step-by-step guide for Indonesian exporters on how to label net contents for ice-glazed seafood that pass FDA, CBP, NOAA, and state Weights & Measures checks in 2026. Covers what the law requires, how inspectors deglaze under NIST Handbook 133, sampling, tolerances, label examples, common mistakes, and the records to keep.

If you sell frozen, ice-glazed seafood into the US, the fastest way to lose trust is short-weight. We’ve seen clean shipments held at the port because the net weight didn’t exclude glaze, or the plant’s deglazing method didn’t match what inspectors use. The good news is there’s a straightforward system to get this right every time.

Below is the 2026 playbook we use for our own Indonesian lines and for partners shipping shrimp, tuna, snapper, grouper, and more into the US market.

What US law requires in 2026

• FDA: 21 CFR 101.105 governs the net quantity of contents statement. For solid foods, you must declare by weight in U.S. customary and metric. The net weight excludes packaging and any protective ice glaze.
• NIST Handbook 133: This is the test manual most US states, CBP labs, and many NOAA/USDC inspections follow to verify net contents. It defines how to sample, how to remove ice glaze, and how to judge compliance.
• Enforcement: FDA can mark product misbranded, CBP can detain or require relabeling, and NOAA/state Weights & Measures can pursue short-weight cases. In our experience, the quickest path to trouble is assuming your internal method equals theirs. Align to Handbook 133.

Practical takeaway: Your label must show only edible product weight, not glaze. Your QC lab must be able to reproduce the inspector’s deglazing result.

Net contents labeling that passes checks

• Use the standard format: Net Wt 16 oz (454 g). For multiunit retail packs, you can add a count statement, e.g., Net Wt 10 lb (4.54 kg) 10 × 1 lb pouches.
• Don’t put glaze inside the net weight. If you want to mention glaze, do it as a truthful, non-misleading claim elsewhere on pack, for example: Packed with approximately 10% protective ice glaze. The net weight statement still reflects deglazed weight only.
• You don’t need to print excludes glaze in the net weight line. It’s already required by law. Some buyers like the clarity; if you use it, keep it separate from the net contents line to avoid clutter.

Example applications from our lines: Our Grouper Fillet (IQF) and Frozen Shrimp (Black Tiger, Vannamei & Wild Caught) are labeled with net weights that exclude glaze, and our specs describe typical protective glaze ranges for handling and shelf-life.

How inspectors test ice-glazed seafood under NIST Handbook 133

Here’s the workflow we train plants on, using the same principles inspectors apply:

1. Select samples per the Handbook 133 sampling plan.
2. If testing retail packs: record gross package weight and identify packaging tare (film, tray, soaker pad, clips, labels). If testing bulk IWP/IVP/IQF pieces: record piece weights and any immediate wrap tare.
3. Remove only the ice glaze using the minimum amount of cold water needed. Keep product frozen or just at the surface thaw point. Don’t let the flesh absorb water or start to thaw through. Inspectors typically use a gentle cold-water rinse or spray until all visible surface ice is gone.
4. Immediately blot surface moisture with single-use, lint-free towels. Don’t squeeze. We use a consistent, timed blot to standardize results.
5. Weigh the deglazed edible product. Subtract tare if applicable. That’s the net weight for compliance.
6. Calculate glaze percentage if needed: glaze % = (glazed weight − deglazed weight) ÷ glazed weight × 100. Track this for process control, not for the net weight statement.

Two non-obvious tips that matter:

• Condition samples. Move test units to a controlled cold room before testing so the surface ice is stable. Wild swings in surface temperature cause inconsistent deglazing.
• Standardize blotting. A sloppy blot can add or remove several grams. We use the same paper type, same number of folds, and the same light pressure every time.

Sampling and tolerances: how many units, how much leeway?

Handbook 133 uses lot-based sampling and two key rules:

• The average net weight of the sample must meet or exceed the declared net weight.
• Individual packages may be slightly short by no more than the Maximum Allowable Variation (MAV). Packages below the MAV are automatic failures.

How many to sample? Many jurisdictions use the Category A plan. As a quick rule of thumb we see often: lots of 101–500 units sample around 13. Lots of 501–3200 units sample around 21. Larger lots may be 29. Always confirm the exact table in the current Handbook 133 or with your inspection authority, because plans can vary by state or program.

Practical takeaway: Build your internal QC plan to meet the same sampling and MAV logic, not just a couple of spot checks.

Straight answers to the questions we get most

Does net weight include or exclude ice glaze on frozen shrimp?

Exclude. The declared net weight is the weight of edible product only. Protective ice glaze is not part of the net contents.

What percentage of protective glaze is allowed in the US?

There’s no single federal limit for “how much glaze.” What’s required is that the product delivers the declared net weight after glaze removal. Many buyers specify 6–12% glaze for quality and shelf-life. More glaze is not illegal by itself, but labeling must still declare the deglazed weight and the product must meet it.

How do inspectors deglaze under Handbook 133?

They remove only visible surface ice with the minimum cold water needed, keep the product from thawing or absorbing water, blot quickly and consistently, then weigh. Your plant method should mirror this.

Do I need to print the glaze percentage or say excludes glaze on the label?

No. Net weight must exclude glaze whether or not you say it. Optional statements like Packed with approx. 10% protective glaze are fine if truthful and not misleading.

What are the penalties if my shipment tests short-weight?

Expect holds, relabeling or rework orders, potential refusals, and chargebacks. Agencies can pursue civil penalties for short-weight cases, and repeated issues can escalate. We’ve seen importers face costly delays and bond claims. The cheapest option is getting it right before loading.

Is drained weight the same as net weight for frozen fish and squid?

No. Drained weight applies to products packed in liquid media, like canned goods. Frozen, ice-glazed seafood uses net weight excluding ice glaze. Don’t use a drained-weight concept on frozen packs.

How many units should I sample to verify net contents for a glazed shrimp export lot?

Use the Handbook 133 lot-based plan as your benchmark. As a practical minimum for plant release, we rarely go below 12–13 units for retail lots and go higher with bigger lots or variable items. Align your n with the official table for your lot size to avoid surprises.

Common mistakes we see (and exactly how to avoid them)

• Counting glaze in the net weight. Train label and QC teams that net weight is after deglazing only.
• Letting product thaw during deglazing. Keep rinse water cold, use the minimum needed, and blot immediately.
• Wrong tare. Absorbent pads and liners are part of tare. If they’re inside the sealed pack, you must deduct them.
• Inconsistent glaze application. Brine tanks that drift in temperature or contact time lead to 3–5% swings. We use timed dips and hourly checks.
• Not matching the sampling plan. Spot checks miss tails of the distribution. Follow a lot plan and apply MAV logic.

If you’d like us to review your plant SOP and sampling plan against Handbook 133, Contact us on whatsapp. A 20-minute check has saved partners weeks of port delays.

Document what inspectors expect to see

We keep this package ready per SKU and lot:

• Deglazing SOP matching Handbook 133, with photos.
• Calibration logs for scales and thermometers.
• Sampling records showing lot size, sample count, individual deglazed weights, average, and MAV check.
• Tare verification sheet (film, pad, tray weights by code).
• Glaze percentage SPC chart by hour or batch.
• Label artwork with the net contents statement, plus any optional glaze claim.
• Training records for operators performing deglazing.

When records are tight, inspections are quick. When they aren’t, everything slows down.

Worked example: shrimp pouch, 2 lb declared net weight

• Declared: Net Wt 2 lb (907 g).
• QC test: After deglazing, five early-run pouches average 915 g. Individual lows are 902 g.
• Decision: Average meets or exceeds 907 g. Check the MAV table for 907 g packs to ensure 902 g is within the individual tolerance. If any pouch is below the MAV, stop and correct before continuing the run.
• Process action: Glaze measured at 10.5%. Within spec. Keep recording hourly.

We do the same math on fillets, steaks, and WGGS. For example, Snapper Fillet (Red Snapper) and Grouper WGGS (Whole Cleaned) follow identical net content logic. The form changes. The principle doesn’t.

Quick exporter checklist for 2026

• Net contents statement includes only edible product weight. No glaze.
• Dual declaration format used correctly, e.g., Net Wt 32 oz (2 lb) 907 g or Net Wt 16 oz (454 g). Keep units consistent and legible.
• Plant deglazing SOP aligns to Handbook 133. Operators trained and observed.
• Sampling follows a lot-based plan and checks both average and MAV.
• Tare materials identified and verified by code.
• Glaze application is controlled. Hourly checks logged.
• Release only lots that clear internal Handbook 133 criteria on paper.

Here’s the thing. Most short-weight headaches are process control problems dressed up as labeling issues. Nail the process and the label takes care of itself.

Questions about your current specs or a label panel you’re about to print? Call us. We’re happy to sanity-check against your buyer’s requirements and the latest Handbook 133 tables.