UFLPA for Indonesian Seafood: 2025 Compliance Guide

A step-by-step, CBP-ready traceability dossier for Indonesian farmed shrimp. Exactly what to collect, how to map hatchery-to-farm-to-processor, evidence hierarchy CBP accepts, and the first packet to send if your shipment is detained.

If you ship Indonesian shrimp to the U.S. in 2025, you don’t need a 60-page legal memo. You need a clean, CBP-ready dossier that proves your lot’s journey from hatchery to carton, with labor risk screened out and every kilo reconciled. Over the last year, we’ve seen that importers who can deliver this in 7–10 days clear detentions. Those who can’t, don’t.

Here’s the exact playbook we use for our own shrimp lines at Indonesia-Seafood. It’s built for practicality. It’s the packet we’d want on the desk when CBP calls.

The 3 pillars of a CBP-ready shrimp dossier

1. Provenance and chain mapping. Show the chain. Hatchery. Nursery (if any). Pond IDs. Harvest and transport. Processor intake and finished goods. One lot narrative, no gaps. We include a one-page flow diagram on top because reviewers read fast.

2. Forced labor risk screening and attestations. Screen every entity against the UFLPA Entity List and document negative hits. Collect signed no-forced-labor declarations from farms, middlemen, processors, and feed mills. Certifications help but don’t replace evidence.

3. Quantitative reconciliation. Tie weights and counts from pond harvest through finished cartons. Show normal yields, glaze, rework, and waste. Close the mass balance. In our experience, this is where 3 out of 5 packets fail.

Weeks 1–2: Map and validate the chain (tools + templates)

We front-load the mapping before production. That way the shipment leaves Indonesia with a complete dossier, not a scavenger hunt.

• Chain-of-custody map. One page: hatchery → farm/pond → transporter → processor → finished goods. Add legal entity names, addresses, license numbers.
• Entity List screening. Check all names against the latest UFLPA Entity List. We log date, source link, and screenshot. DHS has expanded this list several times in 2024–2025, so re-check per shipment.
• Pond and hatchery identifiers. Fix your master list. Pond code, GPS pin, farmer name, permit, pond area, aeration type. Hatchery lot and PL transfer paperwork matched to pond.

Practical takeaway: Create a standing “Shrimp UFLPA pack” per farm cluster. Updating it each shipment takes hours, not days.

Is a certificate of origin enough to satisfy UFLPA for shrimp?

No. A certificate of origin shows national origin. UFLPA is about forced labor risk and supply chain proof. CBP expects documentary evidence of the actual chain and labor risk controls, not just an Indonesian COO.

Weeks 3–6: Build the evidence set for each lot

This is your core packet. We keep it in four tabs: Production Origin, Transport & Intake, Processing & Reconciliation, Labor Risk & Declarations.

• Production Origin

  • Hatchery. PL production log with broodstock source, PL batch code, sanitary certificate, transfer invoice to farm, and chain-of-custody.
  • Farm. Pond-level grow-out log (stocking date and density, water quality checks, mortalities, medication log if any), feeding log with feed lot numbers, and harvest record. We time-stamp and geo-tag photos of the harvest (simple phone shots work).
  • Nursery or aggregator, if used. Transfer documents and lot integrity proof.

• Transport & Intake

  • Trip ticket from pond to processor with seal number (if sealed), vehicle plate, driver ID, ice and time-out/time-in.
  • Processor receiving log. Intake lot ID, gross/net weight, temperature on arrival, and pond/harvest link.

• Processing & Reconciliation

  • Batch traveler for each product form. Steps, yields, trimmings, rework.
  • Glaze percentage certification and moisture checks.
  • Final carton packing list, label sample, and pallet map. We include a high-res photo of the applied carton label.

• Labor Risk & Declarations

  • No-forced-labor affidavits from hatchery, farm, transporter, processor, and feed mill. Bahasa and English versions are fine. Make them shipment-specific.
  • Entity List screening log and results.
  • Any social audits or scheme certificates (ASC/BAP) as supportive evidence. CBP doesn’t accept certificates alone, but they help.

What documents does CBP accept to prove Indonesian shrimp isn’t linked to Xinjiang?

In our experience, CBP looks for: a complete chain-of-custody map; farm and harvest records tied to specific ponds; transport tickets; processor intake logs; processing batch records tying intake to finished lots; supplier declarations regarding no forced labor; and negative screening against the UFLPA Entity List. Photos, seals, and time stamps strengthen the case. Country of origin certificates and standard health docs are supportive but insufficient alone.

Do I have to trace shrimp feed ingredients for UFLPA, and to what level?

CBP has started asking for feed provenance more often since late 2024. We trace to the feed mill and first-tier ingredient sources that present UFLPA risk. Provide:

• Feed mill purchase invoice and delivery note to farm, with batch/lot.
• Feed formula summary and COOs for key ingredients like soy meal, wheat flour, fishmeal, vitamins/premix. You don’t need to trace soy back to farm plots, but you should show non-Xinjiang origin and identify the first processor.
• Feed supplier declaration that no raw materials or processing occurred in Xinjiang or by Entity List firms.

If you can’t get ingredient COOs, document brand, mill location, and mill supplier letter. It’s not perfect, but it’s far better than silence.

How can smallholder pond networks document UFLPA traceability effectively?

Keep it simple and standardized.

• Use QR pond cards. Each pond gets a laminated QR that links to a shared sheet with farmer ID, pond code, and current feed lots.
• Harvest slip with 8 fields. Pond code, date/time, estimated size, net weight, driver, vehicle, seal, and receiving processor. Farmers can fill this on paper; coordinators upload photos.
• Cluster ledger. A coordinator reconciles weekly feed in/out, mortalities, and expected biomass. It doesn’t have to be fancy. Consistency beats perfection.

We’ve cleared detentions with networks of 20+ small ponds using this method.

What does a shrimp processing batch reconciliation look like for CBP?

Think of a one-page mass balance per SKU:

• Intake: 10,000 kg head-on, shell-on (HOSO) from lots FJ-23-0715-A/B.
• Processing: Deheading 36.5%. Peeling 28.0%. Devein 1.5% trim. Glaze set at 10%.
• Outputs: 3,400 kg PD-Tail On 21/25 IQF, 5% rework, 300 kg trimmings to byproduct, 150 kg waste recorded.
• Variance: 0.3% within tolerance.

Attach the batch traveler, yield tables, QC checks, and carton list with lot codes that resolve back to FJ-23-0715-A/B. If you can’t close the loop, CBP will assume the worst.

Carton and lot labeling best practices for UFLPA

• Encode the pond/harvest lot in your finished lot. Example: IDSHR-250108-FJ23A.
• Print production date, processor plant code, and glaze % on the label.
• Keep a scannable code that resolves to the mass balance page. We assign each pallet a QR that links to the reconciliation PDF in a secure drive.

Weeks 7–12: Stress test and scale

Run a detention drill on a finished shipment. Time your team from request to complete packet. Seven days is a good benchmark. Also:

• Independent verification. Commission one unannounced internal trace test per quarter. For some lots, we add stable isotope analysis as supportive origin evidence. Not required, but a strong tie-breaker.
• Document control. Lock templates. Version control your affidavits and logs. Keep English translations ready.
• Retention. Keep all UFLPA traceability records for at least five years from entry date. That aligns with U.S. customs recordkeeping.

Is DNA or isotopic testing required for UFLPA compliance on shrimp?

No. DNA confirms species, not geography. Stable isotope testing can support geographic origin claims, but CBP still wants the documentary chain. We use testing selectively for high-value lots or when the farm cluster sits near complex trade routes.

How quickly must I respond to a CBP Notice of Detention and what should the initial packet include?

Detentions run on a 30-day clock, but most ports ask for your initial package within 7–10 days. We submit a “Day-3 packet” where possible: chain map, pond and harvest records, transport and intake logs, finished lot list with labels, mass balance summary, and signed no-forced-labor affidavits. Then we follow with feed ingredient COOs or extra audits if requested.

Screening suppliers against the UFLPA Entity List

Screen every legal entity name as written in local licenses and Romanizations. Save screenshots and URLs. Re-check before each shipment because the list is updated repeatedly. If a name is similar to a listed entity, explain the distinction up front.

The 5 mistakes that trigger shrimp detentions

1. Mixed-lot cartons. Combining multiple pond lots into one finished lot without a clean reconciliation is a fast track to trouble.
2. Missing feed provenance. A single page from the feed mill with non-Xinjiang declarations and key ingredient COOs often decides the outcome.
3. No transport seals or time stamps. A one-hour gap in your cold-chain timeline invites questions.
4. Certificates instead of evidence. COOs, ASC/BAP, and health certs are helpful, not decisive.
5. Sloppy translations. CBP reviewers can’t parse ambiguous Bahasa scrawls. Provide clean English translations alongside originals.

Quick answers buyers ask us

• Proof of non-Chinese origin for Indonesian shrimp. Provide the full chain dossier. Add Indonesian COO and, if helpful, stable isotope test. CBP decides on the chain, not just the certificate.
• CBP UFLPA questionnaire for seafood. Expect prompts on entity names and addresses, production dates, lot IDs, transport route, labor policies, feed suppliers and ingredient origins, and processing yields. We keep a standard response deck ready per customer.
• Retention period for UFLPA traceability records. Maintain for five years from entry.

Resources and next steps

We apply this system across our shrimp lines and can share the exact templates we use for pond logs, batch travelers, supplier affidavits (Bahasa and English), and mass-balance sheets. If you want the pack or a pre-shipment dossier review, Contact us on whatsapp. Prefer email? Send your current SOP and we’ll highlight gaps within two business days. Contact us on email.

For buyers who need U.S.-ready shrimp with this dossier already baked in, see our specification options here: Frozen Shrimp (Black Tiger, Vannamei & Wild Caught). You can also browse related species we export with the same traceability discipline. View our products.

One last thought. The reality is, UFLPA isn’t going away and the bar isn’t dropping. But a tight, repeatable dossier wins. Do the mapping once, lock your templates, and rehearse the handoff. When detention notices come, you’ll be ready to hit send instead of hit panic.