An action-first, document-by-document playbook to clear Indonesian farmed shrimp under UFLPA in 2026. What to include, how deep to trace, how to answer CBP, and the pitfalls we see every week.
If you want your Indonesian shrimp to clear CBP under UFLPA in 2026, build the packet before you book the container. In our experience, the importers who sail through are the ones who can hand CBP a traceability and rebuttal file that maps every tier. Hatchery to feed to farm to processor to exporter. Here’s the exact structure we use, the evidence CBP typically accepts, and how to respond when a detention notice lands in your inbox.
The 3 pillars of a clearance-ready UFLPA file for shrimp
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Traceability you can reconcile. Every lot must connect across documents without gaps. If your PL batch at the hatchery is 24 million, show how many were stocked by pond, how many harvested by date, and how those kilograms became finished cartons. The math needs to close.
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Non‑Xinjiang evidence. UFLPA is a rebuttable presumption. You must prove your shrimp was not produced in whole or in part in Xinjiang and not touched by a listed entity. For shrimp, the pressure points are feed ingredients and any China-exposed intermediaries. Show the origin of high‑risk feed inputs and screen every supplier against the UFLPA Entity List.
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Labor and operations records. CBP still asks for worker recruitment, wage and hours proof from Indonesian plants and farms. They want to see real operating records, not policy PDFs. Think rosters, payroll stubs, timesheets, contracts, and grievance logs that match production dates.
Practical takeaway: Build a standing “seafood traceability packet” template and keep it hot. Update it every shipment with the specific lots and dates. Do not start from zero after a detention letter.
What documents does CBP actually want to see to clear Indonesian shrimp?
Here’s the core bundle we provide for farmed Black Tiger or Vannamei. This is your starting checklist.
- Corporate and supply map: Legal names, addresses, and role for hatchery, feed mill, farms, processor, exporter, broker, and the importer of record. Include a one‑page flow with dates and GPS for farms.
- Entity List screening: Screenshots or reports showing all parties checked against the CBP UFLPA Entity List on or near the shipment date. Repeat the check before each shipment.
- Contracts and POs: Between importer and exporter, plus upstream purchase contracts that align with shipment quantities.
- Bills of lading and transport records: International B/L, truck waybills from farm to plant, cold‑storage receipts, and temperature logs if available.
- Lot and reconciliation: Intake registers at the processor, production orders, yield sheets, and finished goods lot mapping. CBP likes to see a bill of materials style reconciliation linking ponds to cartons.
- Hatchery to pond: Broodstock origin statements, post‑larvae batch certificates, PL transfer notes to nursery and grow‑out ponds, and pond stocking logs with stocking density and survival assumptions.
- Farm operations: Pond IDs, GPS or shapefile map, daily logs for feed, water, treatments, and harvest records with weights and dates. Photos with timestamps help.
- Feed and ingredients: Feed invoices by lot, feed mill certificates of analysis, and supplier declarations for key inputs like fishmeal and soy. Include country of origin for those inputs and purchase records. More on depth below.
- Processor compliance: Factory licenses, HACCP plans, shift rosters and wage records that match production windows, and recruitment and overtime policies with anonymized payroll proof.
- Export docs: Commercial invoice, packing list, health certificate, certificate of origin if available, and label proofs with lot codes.
If CBP issues a detention, add a cover letter that walks them through this packet in the same order. Make their review easy.
Do I need to trace shrimp feed ingredients back to the original mills?
Short answer. Yes, to the feed mill and the mill’s suppliers for high‑risk inputs. CBP wants to understand where fishmeal and soy came from and to see they are not from or routed through Xinjiang or a listed entity.
What works in practice:
- Feed mill affidavit naming the ingredient suppliers and the country of origin for each key component during the farming window.
- Invoices and delivery notes for fishmeal and soy to the mill tied to the feed lot numbers sold to your farms.
- For fishmeal, list of fishmeal plants used and their country. Vessel lists are a plus but not always requested for farmed shrimp. For soymeal, certificates of origin or supplier statements that identify producing country and mill.
How do I prove my shrimp wasn’t processed by a company on the UFLPA Entity List?
- Run an “UFLPA entity list check” on your processor, cold store, logistics firms, brokers, and any Chinese‑based vendors that touched the feed or packaging. Keep pdf or screenshots with dates.
- Cross‑check legal names in English and local script, plus former names. CBP flags simple name mismatches.
- Add an attestation from each tier that they do not source from or transact with listed entities for the relevant goods and period. Support it with upstream invoices and transport documents.
Trend to watch. As of early 2026, CBP continues to update the Entity List. We re‑screen before every booking and again at sailing. You should too.
Are BAP or ASC certifications enough for UFLPA?
No. They help, and we include them, but they are not a substitute for documentary traceability and non‑Xinjiang evidence. Use certifications as supporting context only. CBP wants contemporaneous records that prove the actual shrimp in the container were produced outside Xinjiang and outside listed entities’ control.
What chain‑of‑custody records link hatchery, farm, processor, and exporter?
Think of it as a chain of custody for seafood with lot continuity at every handoff.
- Hatchery to farm: PL batch certificate and transfer note. Dates, quantities, tank or pond IDs.
- Farm to processor: Harvest log, truck waybill, intake receipt at plant with pond ID carried into the plant lot code.
- Inside the plant: Production order, yield sheet, QC records, freezing logs, and carton labels with the originating pond and harvest date embedded in the lot code.
- Export: Packing list mapping those lots to pallet IDs and container.
If a lot splits or merges, document the split and reconcile weights. If you cannot reconcile, CBP will not either.
Do I need lab testing for shrimp under UFLPA?
We have not seen CBP accept lab testing as a replacement for documents. DNA confirms species. Isotope work can hint at region for wild catch. For farmed shrimp it is rarely decisive. If you submit testing, frame it as a supplement, never as your primary rebuttal.
Responding to a CBP UFLPA detention in 2026
Timeline. You generally have 30 days from the detention notice to submit evidence. Extensions are sometimes granted but not guaranteed. Miss the deadline and you risk exclusion and re‑export. If CBP concludes you did not overcome the presumption, you can face exclusion or seizure depending on the case.
File structure. Keep it simple and pre‑indexed.
- Cover letter. One to two pages. State that you are rebutting the UFLPA presumption for farmed shrimp. List the attached exhibits by tier.
- Exhibits A–F. A: supply map and Entity List screens. B: hatchery. C: feed and ingredient origins. D: farm logs. E: processing and labor records. F: export chain of custody.
- Reconciliation table. A single page that shows quantities flowing from PL to kilograms shipped.
What CBP often pushes back on:
- Gaps between feed lot numbers and farm feed consumption logs.
- Pond GPS missing or inconsistent with the farm’s legal address.
- Payroll records that do not align with the nights your lot was processed.
Need a second set of eyes on your packet or a sample structure we use for our shrimp exports? Reach out and we’ll share a redacted template. If your situation is time sensitive, Contact us on whatsapp.
Common mistakes we see and how to avoid them
- Treating affidavits as enough. Affidavits help, but without invoices and transport records, CBP treats them as assertions. Pair every affidavit with source documents.
- Ignoring China exposure in packaging or additives. If any input came from China, document its manufacturer and prove it is not on the Entity List and not Xinjiang‑origin. Or change the supplier.
- Photo evidence with stripped metadata. Send original files when possible. Include device time settings if site photos are key to your case.
- Overlooking brokers and consolidators. Screen them too. A broker on the Entity List can sink a clean supply chain.
- Waiting for detention to assemble records. Build once, reuse. We keep living files for our farms and plants so shipment‑specific work takes days, not weeks.
Fast setup: build your packet in 10 days
Day 1–2. Supplier mapping and screening. Get full legal names, addresses, and government IDs. Screen against the UFLPA Entity List. Save dated screenshots.
Day 3–5. Traceability spine. Create the lot reconciliation table. Pull hatchery PL docs, farm logs, and processor production records for the exact harvest windows.
Day 6–8. Feed origins. Collect feed invoices, mill attestations, and ingredient origin statements. Highlight fishmeal and soy sources and countries.
Day 9. Labor and wages. Pull anonymized payroll and timesheets for the processing dates. Include recruitment and grievance procedures.
Day 10. Final compile. Index the packet, draft the two‑page cover letter, and export to a single bookmarked PDF.
If you want to see how we package this for our Frozen Shrimp (Black Tiger, Vannamei & Wild Caught) shipments, we can share a sample index and reconciliation format on request. Questions on a live entry? Contact us on email.
Quick answers to the questions we get most
- How many supplier tiers to trace for shrimp under UFLPA. At least to hatchery, feed mill and their key ingredient suppliers, farm, processor, exporter, and brokers. Trace any tier that materially changes the product or contributes high‑risk inputs.
- CBP acceptable evidence for farmed shrimp UFLPA. Chain‑of‑custody documents, invoices, transport records, lot reconciliation, feed origin proofs, labor and wage records tied to production, and Entity List screens with dates.
- Recordkeeping. Maintain your UFLPA file for at least 5 years after entry by the importer of record. Organize it so you can re‑submit within 48 hours if asked.
- Importer of record responsibilities. Exercise reasonable care, pre‑screen suppliers, keep records, and be able to furnish them promptly. CBP will expect the importer to own the rebuttal, even if the supplier prepares the packet.
The reality is that well‑prepared shrimp files get cleared faster. Build a repeatable dossier, screen relentlessly, and reconcile your lots like a manufacturer. Do that, and UFLPA stops being a fire drill and becomes another box you can confidently check.