A practical, step‑by‑step playbook for Indonesian processors making FSMA 204–compliant breaded shrimp for the U.S. market. What to record at receiving, transformation, and shipping, how to assign a traceability lot code, and how to avoid the mistakes we see most often.
We’ve spent years helping Indonesian plants move shrimp into the U.S. with clean paperwork and calm audits. FSMA 204 raises the bar on traceability for foods on FDA’s Food Traceability List, and crustaceans (fresh and frozen) are on it. If you’re breading shrimp for the U.S., this guide shows exactly what to capture, when to assign a traceability lot code, and how to share data your importer can actually use.
Compliance date: January 20, 2026. The countdown has started.
Why FSMA 204 matters for breaded shrimp in 2026
Breaded shrimp is still “crustaceans (fresh and frozen).” So yes, your product remains on the Food Traceability List after breading and freezing. That means you’ll record Critical Tracking Events (CTEs) and Key Data Elements (KDEs) at receiving, transformation, and shipping. In our experience, once a team maps those three CTEs clearly and chooses a solid traceability lot code (TLC) method, 80% of the heavy lifting is done.
Practical payoff? Faster investigations, fewer claim disputes with importers, and less chaos if you ever face a recall.
Map your CTEs in a breaded shrimp line
Here’s the simple flow most Indonesian shrimp processors follow.
- Receiving CTE → raw shrimp in (HOSO, HLSO, peeled, etc.)
- Transformation CTE → breading and freezing (and any cooking if applicable)
- Shipping CTE → finished breaded shrimp to U.S. importer or consolidator
What exactly must I record when I receive raw shrimp for breading?
Record these Receiving KDEs for each incoming shrimp lot:
- Product description and lot ID from supplier (species, form, size grade). Include harvest source if available.
- Quantity and unit (e.g., 2,000 kg, 10x2 kg blocks).
- Date received and receiving location (GLN or full address works).
- Supplier name and location.
- Traceability lot code, if the supplier already assigned one. If not, you’ll carry forward their lot and assign your own TLC at transformation.
- Reference document type and number (PO, invoice, GRN).
If you buy directly from harvest or landing sites, add harvest vessel/farm identifiers when available. We see claims settle faster when farms and ponds are traceable on day one.
How do I create a traceability lot code and link all input shrimp lots to one breaded batch?
Breading is a Transformation CTE. You must create a new TLC for the output batch and link all input lots (and their TLCs, if any) to it.
What to capture at Transformation:
- Date of transformation and location (line/room is helpful).
- Output product description (e.g., Breaded Vannamei, 26/30, Panko, IQF) and output quantity.
- New traceability lot code you assign to the finished breaded batch.
- All input shrimp lots used with their quantities and TLCs (or supplier lot IDs if no TLC yet).
- Reference record (batch sheet, production order, QC log).
A workable TLC format for shrimp exporters
- Keep it human-readable and unique. Example: IDN-FHCI-BSHR-20260115-L2-B034
- IDN = Indonesia
- FHCI = facility code
- BSHR = breaded shrimp
- 20260115 = transformation date
- L2 = line 2
- B034 = daily batch counter
- Or use GS1 (GTIN + batch/lot) if you already run barcodes. Either way, the TLC must clearly link to who assigned it (the “traceability lot code source,” which is you at transformation) and let you retrieve all KDEs within 24 hours.
Can my existing production batch code serve as the FSMA traceability lot code?
- Yes, if it’s unique, persistent on labels/docs, and links to all required KDEs. Many plants simply rename the existing batch field “TLC” in forms and train staff to keep it identical on internal and export paperwork. That’s often the lowest-friction option.
Want a quick sanity check of your TLC design or batch-sheet layout? We can review a sample in a short chat. If that helps, just Contact us on whatsapp.
What has to appear on my export shipping documents for FSMA 204?
At Shipping CTE, include these KDEs for the breaded shrimp lot you ship:
- Traceability lot code for the finished product and the TLC source (your facility).
- Product description, pack, and size (match the COA/spec).
- Quantity and unit shipped.
- Date shipped, ship-from location, and ship-to party/location.
- Reference document number (invoice, packing list, BOL, ASN/EDI if used).
How to share KDEs with a U.S. importer
- Any “sortable” electronic format works. Most importers accept a CSV or Excel attachment in the document pack. Some larger buyers increasingly prefer GS1 EPCIS 2.0 events. In the last six months, we’ve seen more U.S. receivers ask for a simple CSV that mirrors FDA KDE fields plus TLC.
- Good practice: place the TLC on your commercial invoice or packing list line items so your importer never has to guess.
Practical answers to questions processors ask
Does breading shrimp count as a transformation under FSMA 204?
Yes. Adding breading, spices, or par-frying is a transformation event. You must create a new TLC for the finished breaded product and keep transformation KDEs. And because crustaceans remain on the Food Traceability List, you also keep shipping and receiving KDEs beyond transformation.
Do I need KDEs for breadcrumbs and spices?
No, not under FSMA 204. KDEs apply to foods on the Food Traceability List. Breadcrumbs and spices generally aren’t on the FTL. That said, maintain normal supplier lot trace for allergens and quality. We still link spice/breadcrumb lots to the batch internally so we can answer customer questions fast.
How should I record rework or partial re-breading in a shrimp batch?
Treat rework as an input shrimp lot at the next transformation.
- Give rework its own internal lot ID or TLC.
- Record the quantity of rework used and link it to the new batch’s TLC.
- If multiple TLCs are combined via rework, the output gets a new TLC. Your batch record must list all upstream TLCs and quantities.
- Keep rework segregated by product spec to avoid cross-batch confusion later.
Build a lean traceability plan that actually gets used
FDA requires a written traceability plan you can update and hand over quickly. We boil it down to five sections:
- Your FTL foods list and product codes that match labels and invoices.
- TLC assignment method and where/how TLC appears on labels and documents.
- CTE/KDE mapping with responsible roles and source documents (GRN, batch sheet, invoice, EDI).
- Record formats and systems used, plus retrieval time commitment (24 hours).
- Point of contact for FDA or customers.
A low-cost system that still works
You don’t need expensive software to comply. We’ve seen this work reliably:
- Controlled Excel/Google Sheets with locked dropdowns for species/forms and required KDE fields.
- Barcode or QR labels on WIP totes and cases that encode TLC and product code.
- A daily “Mix Map” on the wall for supervisors to confirm which input lots feed which batch.
- Weekly self-audits: pick one shipped lot and trace forward/back in under 30 minutes.
If you already run GS1, great. Encode GTIN + lot/TLC in a 2D code on the case. If not, start with human-readable TLC plus a simple QR pointing to your internal record. Several U.S. importers now accept EPCIS 2.0 files. Nice to have. Not mandatory.
Common mistakes we see and quick fixes
- Mixing tanks without lot boundaries. Fix: time-separate or physically separate lots and log start/stop times for each input TLC.
- TLC that changes mid-process. Fix: assign TLC at transformation start and keep it constant on every record and label.
- Missing quantities by input TLC. Fix: record input weights per TLC on the batch sheet, not just a total.
- TLC not visible on export docs. Fix: add a “TLC” column to invoices and packing lists. Your importer will thank you.
- Breadcrumb/spice treated like FTL. Fix: keep normal QC trace, but don’t overcomplicate FSMA 204 KDEs with non-FTL ingredients.
Where our team can help fast
We produce and export Indonesian shrimp in formats that align cleanly with FSMA 204 record-keeping, including IQF. If you need consistent raw material to feed a breading line, see our Frozen Shrimp (Black Tiger, Vannamei & Wild Caught). And if you want a quick check that your receiving, transformation, and shipping records cover all KDEs, Contact us on whatsapp.
Takeaways you can use today
- Decide whether your current batch code can serve as the TLC. If yes, lock it and train around it.
- Add explicit KDE fields to three documents: GRN (receiving), batch sheet (transformation), invoice/packing list (shipping).
- Run a mock trace: pick a shipped TLC and prove you can list inputs with quantities in under 30 minutes. If you can do that now, you’re on track for January 2026.