NOAA Form 370 Dolphin-Safe: Indonesia 2025 Compliance Guide

A field-tested, step-by-step guide to completing NOAA Form 370 for Indonesian handline and pole-and-line tuna in 2025. Includes exact captain’s statement wording, ACE message-set mapping, common rejection fixes, and how to prove chain of custody for transshipped lots.

We’ve cleared hundreds of Indonesian tuna shipments into the U.S. The ones that fly through customs all use the same playbook. Below is exactly how we complete NOAA Form 370 for non-ETP Indonesian handline and pole-and-line tuna, what ACE actually checks, and the mistakes we see most often.

The 3 pillars of fast, low-friction NOAA 370 compliance

Clean vessel data. The vessel name and flag must match across fishing license, landing receipt, captain’s statement, and entry documents. Three out of five rejections we see are just a one-letter vessel mismatch.
Bulletproof captain’s statement. Right gear. Right trip dates. Right dolphin-safe wording. Signed by the actual skipper, not the owner at home.
Unbroken chain of custody. A clear path from vessel to factory to export. If there was a transshipment or consolidation, you need paper for every handoff.

Weeks 1–2: Map and validate your 370 requirements

Here’s the thing. If you set up the fields once, filing becomes routine. We recommend creating a single-page checklist with the exact data elements you’ll push to your broker’s ACE message set.

What boxes do I complete for Indonesian handline or pole-and-line tuna?

Think of the 370 in nine elements. Different 370 layouts exist, but ACE requires the same core data:

Shipment identifiers. Entry number, invoice number, bill of lading, container(s).
Product details. Species and form. Example: Yellowfin tuna loin, IQF, 10,000 kg.
HTS line(s). Use current U.S. HTS for tuna or tuna products. See quick reference below.
Trip category and area. Non-ETP trip for Indonesia. FAO 57 (Indian Ocean) or FAO 71 (Western-Central Pacific).
Gear type. Handline or pole-and-line for this guide.
Fishing trip dates. Departure and return dates for each vessel supplying the lot.
Vessel information. Name, flag, registration or IMO/UVI if available, captain’s name.
Transshipment/landing. Carrier vessel name and flag if used, port and date, or direct landing receipt.
Dolphin-safe certification. Captain’s statement for each contributing vessel and trip.

Do handline or pole-and-line tuna need an observer statement?

No, not for non-ETP trips. For Indonesian handline or pole-and-line harvested outside the Eastern Tropical Pacific, NOAA 370 requires a captain’s statement. Observer statements apply to specific purse-seine situations or ETP requirements, which we’re not covering here.

Exact captain’s statement wording we use in 2025

For Indonesian non-ETP handline or pole-and-line trips, this wording has passed ACE and audits for us: “I am the captain of the [vessel name, flag]. I certify that the tuna in this shipment were caught by [handline or pole-and-line] on a fishing trip from [start date] to [end date], and that no dolphins were intentionally chased, herded, or encircled with nets during the trip, no dolphins were killed or seriously injured in the sets or gear deployments, and no drift gillnets were used to catch the tuna.” Include captain’s name, signature, date signed, and contact. If the statement is bilingual, ensure the English version appears exactly as above.

Who can sign if the owner isn’t onboard?

The skipper or master who commanded the trip. For small vessels, the “person in charge” of the fishing operations can sign, but the name must match the license or trip log. We attach a copy of the Indonesian fishing license listing the skipper to avoid questions.

Practical takeaway. Build a one-page captain’s statement template in Bahasa and English with fillable fields for vessel name, flag, gear, trip dates, FAO area, and skipper signature.

Weeks 3–6: Build your MVP. Capture and map documents to ACE

In our experience, this is where most importers stumble. They have a signed 370 but the ACE data elements don’t match their documents. Fix that by mapping once and reusing.

ACE message-set mapping that actually works

Your broker files the NMFS Tuna Tracking and Verification Program (TTVP) message set against each HTS line. Map these fields to your document pack:

Species. YFT, BET, ALB, SKJ. Match species on invoices and production sheets.
Gear. HL for handline, PL for pole-and-line.
Trip area. Non-ETP. Provide FAO 57 or 71.
Vessel. Exact name and flag code. Use IDN for Indonesia.
Trip dates. From sailing to landing for each vessel that contributed fish.
Shipment linkers. Entry line number, invoice number, and B/L or container numbers.
Transshipment. Carrier vessel name and flag if any, transshipment date and position or port landing details.
Certification type. Captain’s statement for non-ETP.

Two actionable tips:

Lock vessel names as a controlled list. Copy-paste from the fishing license to avoid typos.
Use the exact same invoice number in ACE that appears on your commercial invoice. Tiny differences trigger holds.

Need a quick review of your ACE mapping or a bilingual captain’s statement template? You can Contact us on whatsapp. We’re happy to sanity-check your first filing.

Common rejection reasons and how to fix them fast

Vessel name mismatch. Correct the name in the ACE message set and refile. Attach the fishing license page showing the exact spelling.
Wrong flag or country spelling. Use ISO code IDN, not “Indonesia.”
Missing trip dates. Add the full trip window. Single-day gaps often mean ACE thinks dates are missing.
Gear code error. Use HL for handline and PL for pole-and-line.
Area not specified as non-ETP. Mark the FAO area and annotate “Non-ETP.”
Captain’s statement date after the U.S. entry date. Re-execute the statement with a correct sign date or explain a clerical error with a corrected statement.

Weeks 7–12: Scale and optimize across products and shipments

Once the core is running, standardize by product and buyer. For example, our tuna lines like Yellowfin Saku (Sushi Grade), Yellowfin Steak, Bigeye Loin, and Bigeye Steak each use a fixed, pre-approved 370 pack. Consistency shortens inspections.

Can one NOAA 370 cover multiple invoices or containers?

It can, if they’re part of the same entry and share the same species, gear, and source vessels and trips. But our best practice is one 370 per entry line per species and gear. The moment you mix vessels or trips, auditing gets messy and the risk of rejection rises.

How do I correct a rejected 370 for mismatched vessel details?

Ask your broker for the rejection code text from ACE.
Fix the underlying field in your master data. Do not just patch the PDF.
Refile the message set with corrected vessel name/flag and attach the revised captain’s statement if needed.
Keep a change log showing what you corrected and why. Auditors appreciate it.

What proof of chain of custody works if tuna was transshipped?

We maintain an unbroken paper trail:

Trip catch log and landing or transshipment declaration. If at sea, the relevant RFMO declaration for WCPFC or IOTC transshipments.
Carrier vessel B/L or transfer receipt. Include vessel name, flag, date, and position or port.
Cold storage in/out reports and weigh notes.
Factory receiving log that references the same lot IDs.
Production batch sheet linking those lot IDs to the export invoice and container. If anything was consolidated, the mass-balance must reconcile weights. ACE doesn’t calculate it for you, but auditors will.

Practical takeaway. Put a single lot code on every document from landing to export. When in doubt, add a cross-reference note on the document itself.

The 5 mistakes that kill dolphin-safe filings

Using a generic “no dolphins harmed” line without the full language. Include “no intentional encirclement,” “no dolphins killed or seriously injured,” and “no drift gillnets.”
Signing by the owner ashore. The captain or skipper must sign.
Mixing ETP and non-ETP assumptions. Indonesia trips are non-ETP. Don’t tick ETP boxes by accident.
Forgetting transshipment details. If a carrier vessel touched the lot, name and flag must appear.
Treating HTS codes loosely. If your HTS doesn’t match a tuna line, ACE won’t trigger the NOAA 370 message set correctly. Or a hold will come later.

Quick reference: Which HTS lines trigger NOAA 370 in 2025?

NOAA 370 applies to tuna and tuna products imported into the U.S. Typical HTS chapters include:

Prepared or preserved tuna. HTS heading 1604.14 and U.S. subheadings thereunder.
Fresh or frozen tuna and tuna meat. HS 2022 introduced specific tuna lines under Chapter 03. U.S. HTS subheadings covering whole, meat, or fillets of tuna, skipjack, and bonito commonly include 0304.87 and related U.S. breakouts. Because the HTSUS is updated, always confirm the exact subheading with your broker for the product form you ship. If the product is tuna or a tuna product entering the U.S., assume a NOAA 370 will be required and prepare the pack.

Resources and next steps

If you follow the 3 pillars, NOAA 370 becomes a repeatable workflow. Build your captain’s statement template. Lock your vessel master list. And keep a clean chain-of-custody binder per shipment. For buyers evaluating Indonesian tuna supply, our standardized documentation is the reason our shipments of Yellowfin Saku (Sushi Grade), Yellowfin Steak, Bigeye Loin, and Skipjack Cube (WGGS / IQF) clear smoothly. Want to see our documentation pack and QA checklist on a live PO? View our products and ask for a sample pack on the item you’re sourcing.

The reality is that a tight 370 process usually takes 2 to 3 weeks to set up across your fleet and factory. After that, it’s copy, paste, verify, and ship. Questions about your project or a tricky multi-vessel lot? Contact us on whatsapp.