A practical, scenario-based playbook for getting Indonesian shrimp COOL labels right in US retail. Exact wording, commingled bins, third‑country processing, and the records you need to pass an AMS review.
We’ve spent the last decade helping buyers and retailers label Indonesian shrimp correctly in the US. The fastest wins happen when you stop debating wording and install a simple system. We’ve used the framework below to take teams from messy spreadsheets to audit‑ready in under 90 days.
Here’s the thing. COOL for fish and shellfish is administered by USDA AMS at US retail. It requires two bits of information on covered items: country of origin and production method (farm‑raised or wild‑caught). That’s it. The confusion creeps in with commingled bins, third‑country processing, and the difference between COOL and Customs origin marking. So let’s make this practical.
The 3 pillars of shrimp COOL compliance in 2025
- Say where it’s from and how it was produced.
- Farmed shrimp. Country where it was raised. Add “Farm‑Raised.”
- Wild shrimp. Country where it was harvested. Add “Wild‑Caught.”
- Use clear, plain wording consumers understand.
- “Product of Indonesia. Farm‑Raised.”
- “Product of Indonesia. Wild‑Caught.”
- For commingled bins, list all applicable countries and methods in one sign.
- Keep traceable records that match your label.
- Purchase docs, farm harvest logs, landing records, CBP entry, processor production codes, and internal lot linkage. Keep at least one year at retail. Suppliers keep source/recipient for one year from transaction.
In our experience, if you build these three into your intake and label SOPs, you’ll pass an AMS visit with minimal drama. Now let’s lay out the 90‑day build.
Weeks 1–2: Map your supply and validate claims
Start with one question: Is my item covered by COOL or is it a processed food item? Raw, peeled/deveined, shell‑on, IQF/block frozen shrimp are covered and need COOL. Cooked or breaded shrimp are generally processed food items and exempt from COOL at retail.
- Indonesian farmed vannamei, raw, IQF: covered. COOL required.
- Indonesian wild shrimp, raw, IQF: covered. COOL required.
- Cooked, breaded, or marinated shrimp: typically exempt from COOL. (You still must meet CBP origin marking and FDA rules.)
Confirm production method and origin with documents.
- Farm‑Raised: country where it was raised (e.g., Indonesia). Use farm harvest logs, processor intake records, and import entries.
- Wild‑Caught: country where harvested (e.g., Indonesia). Use landing docs, catch certificates, processor intake logs, import entries.
Third‑country processing doesn’t change COOL origin for shrimp.
- If Indonesian farmed shrimp are peeled/deveined in Vietnam or Thailand, COOL origin is still Indonesia. Your label can say “Product of Indonesia. Farm‑Raised.” You can optionally note “Processed in Vietnam,” but COOL doesn’t require it.
COOL vs CBP origin marking.
- CBP origin marking is a customs requirement for imported goods. It often, but not always, aligns with COOL. Simple peeling/packing usually doesn’t change the CBP origin from Indonesia. If a substantial transformation occurs, CBP origin could differ. Under COOL, you still declare country of raising/harvest. Both can appear on pack without conflict when phrased clearly.
Practical takeaway for this phase
- Build a one‑page “origin and method attestation” per SKU/lot. Attach source docs (farm/landing, processor COA, CBP entry). Decide your exact consumer‑facing wording now, not at print time.
Weeks 3–6: Build the labels and store signage
Prepacked retail packs
- Place COOL on the principal panel or adjacent info panel, near the price/identity statement. Keep it simple. Example for Indonesian farmed vannamei (raw, IQF): “Product of Indonesia. Farm‑Raised.” Example for Indonesian wild shrimp (raw, IQF): “Product of Indonesia. Wild‑Caught.”
Bulk service case or self‑serve bins
- Use a placard or sign immediately next to the product and price. Example for a single‑origin farmed bin: “Shrimp — Product of Indonesia. Farm‑Raised.”
Online listings
- The law targets point‑of‑sale at retail. Many retailers now mirror COOL online to avoid confusion. We recommend placing origin and method right with the product name or price online so the information travels with the order.
What exact words are compliant?
- “Product of Indonesia, Farm‑Raised” is compliant for Indonesian farmed shrimp.
- Avoid vague geography like “Pacific” alone. Use the country name and the method.
If you’re private‑labeling frozen shrimp with us, we can preprint the correct COOL on the master and inner packs. See our Frozen Shrimp (Black Tiger, Vannamei & Wild Caught) options if you want consistent wording across SKUs.
Practical takeaway for this phase
- Lock approved phrases in your artwork library and service‑case sign templates. Train counter staff to check that the origin/method sign is present whenever a tray rotates.
Weeks 7–12: Scale across commingled and multi‑origin lots
Commingled bins happen. The rule lets you list all applicable origins and methods when substantially similar shrimp are mixed.
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Farmed from multiple countries. Example sign: “Shrimp — Product of Indonesia and India. Farm‑Raised.” Alternative allowed phrasing at retail: “May contain shrimp from one or more of the following countries: Indonesia, India. Farm‑Raised.”
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Mixed farmed and wild. Example sign: “Shrimp — Product of Indonesia (Farm‑Raised) and USA (Wild‑Caught).” Or list on two lines under one price card.
Rotation SOP that works in real stores
- Before topping up a bin, check the incoming lot’s origin/method. If it differs, update the sign to include all origins/methods present in the bin after mixing.
- Keep a simple commingling log. Date, SKU, existing origin/method, added lot origin/method, new sign text, initials.
Does third‑country processing ever change COOL?
- Peeling, deveining, sorting, glazing, or freezing in another country doesn’t change COOL origin for shrimp. Still label by the country of raising/harvest. You can add “Processed in [Country]” if helpful to buyers.
Are cooked or breaded shrimp exempt from COOL?
- Yes. Cooked or breaded items are generally considered processed food items under the fish/shellfish COOL rule. Retail COOL isn’t required, but CBP origin marking and all FDA labeling still apply.
Practical takeaway for this phase
- Install the commingling log and pre‑approved multi‑origin sign templates. That’s what AMS reviewers often ask to see.
5 mistakes that trigger citations (and how to avoid them)
- Missing the method. Labels that say “Product of Indonesia” but omit “Farm‑Raised” or “Wild‑Caught.” Fix: Always include the method.
- Inconsistent signage on commingled bins. The bin contains two origins, but the sign shows one. Fix: Update signs as soon as lots are mixed.
- Assuming third‑country peeling changes COOL. It doesn’t. Fix: Keep the origin as Indonesia for Indonesian‑raised or harvested shrimp.
- Treating raw peeled shrimp as “processed” and skipping COOL. Fix: Raw peeled/deveined shrimp are still covered and need COOL at retail.
- Weak records. You need to prove origin and method. Fix: Keep farm or landing docs tied to lot codes, plus CBP entry docs. Retain a year at retail.
Quick answers to what buyers ask us most
What should the label say for Indonesian farmed shrimp at a US grocery store?
“Product of Indonesia. Farm‑Raised.” If it’s wild shrimp, use “Product of Indonesia. Wild‑Caught.”
Does peeling or deveining in Vietnam or Thailand change the COOL country for Indonesian shrimp?
No. COOL origin stays Indonesia. You can optionally say “Processed in Vietnam/Thailand,” but it’s not required by COOL.
How do I label a shrimp bin that mixes Indonesia with other origins like India or Vietnam?
List all countries and the method on one sign. For example, “Product of Indonesia and India. Farm‑Raised.” If methods differ, specify each: “Indonesia (Farm‑Raised) and USA (Wild‑Caught).”
Are breaded or cooked Indonesian shrimp exempt from US COOL?
Generally yes. Cooked or breaded shrimp are processed food items and not covered by retail COOL. Keep CBP marking and FDA labeling compliant.
What records prove “Product of Indonesia” and “Farm‑Raised” for shrimp?
Supplier attestations, farm harvest logs, processor intake/production records tying lots to farms, purchase orders, packing lists, and CBP entry documents. Keep them linked to the retail SKU/lot for one year.
Do restaurants have to provide COOL information for shrimp?
No. Restaurants and similar foodservice are exempt from COOL. The rule covers PACA‑licensed retail establishments.
Where should COOL information appear for bulk and packaged shrimp at retail?
- Packaged: on the package label near the identity/price info.
- Bulk: on a placard or sign immediately adjacent to the displayed shrimp and price.
Roles and 2025 context you should know
- USDA AMS. Oversees fish/shellfish COOL at retail and conducts reviews. No major rule changes have landed for 2025, but reviews remain active.
- CBP. Enforces country‑of‑origin marking for imports. Origin determinations can differ if there’s substantial transformation overseas.
- FDA. Oversees all other food labeling, identity, allergens, and seafood HACCP. COOL doesn’t replace FDA compliance.
- NOAA/SIMP. Import data on harvest, gear, and area. Not a retail label, but your SIMP docs often support your COOL records.
We recommend aligning your artwork, bin signs, and records so CBP origin, COOL phrases, and your FDA label don’t contradict each other. If you’re wrestling with a mixed‑origin or third‑country processing case, Contact us on whatsapp and we’ll map the exact wording and documents for your SKU.
Practical resources and next steps
- Create a one‑page COOL spec per SKU: species, method, origin phrase, example sign/artwork, required records.
- Train counter staff on commingled signage and keep a simple rotation log.
- Standardize pack copy now. If you need Indonesian shrimp that ships with compliant, pre‑approved wording, browse our View our products and we’ll build labels to your spec.
When the labels are precise and the paper trail is tight, AMS visits tend to be quick. And your customers get exactly what they want to know: where it’s from and how it was raised or caught.