U.S. to tighten traceability rules on seafood imports, but is the industry ready?

As WeAreAquaculture reported in our Seafood Expo Global liveblog from Barcelona last week, traceability was top of the agenda in many discussions.

And, in the United States, it's no longer just a "nice to have": supply chain traceability will soon become an obligation for seafood imports into the U.S., as the country brings its new Food Safety Modernization Act (FSMA) into force by January 2026.

In the session, "Regulatory Pitfalls and Traceability Requirements for Exporting Seafood into the US Market: What You Need to Know", panellists Benjamin England (FDA Imports), Heath England (Trace Register), Domenic Veneziano (Veneziano Consulting) and moderator Sergio Lozano (Alpha Brokers Group) highlighted that not all seafood importers were sufficiently prepared for the new regulations.

The panel highlighted that the NOAA and FDA require different traceability records - and by January 2026, the FDA will implement stricter traceability requirements for all seafood imports, including processed seafood - the "FSMA" rule.

"Manufacturers sometimes don't even know they're on an import alert list," said FDA Regulatory and Strategic Consultant Domenic Veneziano. The import alert system prevents potential rule-violating products from distribution in the U.S., he explains.

Core to the new FSMA regulation is the need for seafood producers to maintain records of "Key Data Elements" (KDEs) associated with specific "Critical Tracking Events" (CTEs). Seafood importers need to be able to provide this information to the FDA within 24 hours if requested, the panellists explained.

Heath England, President of Trace Register, pointed out that the key information that has to be transmitted along the chain is the "TLC", the traceability lock code, that enables the US authorities to track the product back to its original producer.

"That traceability lock code has to stay with that product all the way to the consumer," he noted.

The panellists also highlighted two additional areas of concern for seafood importers to the US that have received significant media attention recently: the ban on Russian salmon, cod, pollock, and crab, and the worrying question of forced labour in seafood supply chains.

Benjamin England, CEO of FDAImports, said that if the US authorities find evidence of forced labour in the supply chain, the imported goods are automatically seized. Products originating in some provinces of China are automatically presumed under US law to involve forced labour, he added.

The panellists also noted that forced labour is also a problem for imports of aquaculture feed, but highlight the challenge of tracking the origins of the individual feed ingredients.

"Traceability is going to be a way to enforce regulations on forced labour," says moderator Sergio Lozano of Alpha Brokers Corp.

It's also a way for processors to protect themselves from importation pitfalls, added England: "Knowing your supply chain has become even more critical."

According to the U.S. Food and Drug Administration website, the FDA's Food Traceability Final Rule introduces new traceability recordkeeping requirements for entities involved in manufacturing, processing, packing, or holding foods listed on the Food Traceability List (FTL).

This rule is part of the FDA’s "New Era of Smarter Food Safety Blueprint" and enforces Section 204(d) of the FDA Food Safety Modernization Act (FSMA).

Its aim is to enhance the speed and efficiency of identifying and removing potentially contaminated foods from the market, thereby reducing the incidence of foodborne illnesses and deaths.

The rule mandates that relevant parties maintain records of Key Data Elements (KDEs) for specific Critical Tracking Events (CTEs). These records must be accessible to the FDA within 24 hours or a mutually agreed reasonable timeframe.

It applies to both domestic and international firms producing food for the U.S. market and aligns with current industry best practices. All affected entities must comply with these requirements by January 20, 2026.