Upcoming Traceability Mandates Need to be Communicated to the Entire Supply Chain
This blog was written by Stephanie Pazzaglia, Outreach and Development Manager with J.J. McDonnell and Sea Pact Member Board representative.
As the seafood industry evolves, traceability and transparency have become increasingly important to customers and markets. In response, retailers are now requiring more sourcing information, while the FDA finalized the Food Traceability Rule under the Food Safety Modernization Act (FSMA 204) in 2022. This rule, which takes effect on January 20, 2026, will require the seafood supply chain to maintain detailed traceability records. These records will include Key Data Elements (KDEs) and Critical Tracking Events (CTEs), which will vary depending on a company's position in the supply chain—whether as a first receiver, shipper, processor, distributor, or other role. The traceability requirements will apply to both farmed and wild-caught seafood.
Many retailers will require additional KDEs beyond those mandated by FSMA 204. Companies that fail to adapt risk losing market access and facing regulatory non-compliance. To meet FSMA and retailer requirements, businesses may need to invest in new technology or traceability platforms. Sea Pact members recognize the need for industry-wide engagement to meet these evolving requirements and have been collaborating to share best practices and implementation strategies.
Shifting to a fully digitized supply chain aligns with regulatory frameworks such as FSMA 204 and supports the adoption of Global Dialogue on Seafood Traceability (GDST) and GS1 industry standards. Full-chain traceability is crucial for food safety compliance, operational efficiency, and consumer trust. However, this transition will require raising awareness across the entire supply chain, not just among mid-suppliers serving retailers and foodservice providers. A common challenge faced by many Sea Pact members is the lack of awareness and understanding of regulatory data-sharing requirements—such as FSMA 204—among first receivers in the supply chain, including packing houses, producers, and processors, both domestically and internationally.
Ensuring a Seamless Transition to Compliance
To meet regulatory compliance and facilitate a smooth transition, many seafood companies are implementing new data-sharing and labeling requirements. These updates are designed to improve supply chain interoperability, enhance product traceability, and ensure compliance, greater awareness among first-mile supply chain stakeholders is still needed.
The Role of Traceability Service Providers
To support compliance and operational efficiency, traceability service providers offer digital traceability and labeling solutions. Key benefits include:
User-friendly interfaces for seamless adoption.
Interoperability with existing traceability and ERP systems.
Automated data integration to reduce manual effort.
Critical event-based traceability in alignment with FSMA 204 requirements, GDST, and GS1 standards.
Integrated labeling solutions, including GS1-128 and GS1 DataMatrix barcodes.
While companies are free to choose any system, it is recommended that they align with GDST and GS1 standards to ensure compliance with new mandates and system interoperability.
Why This Matters for the Industry
The shift toward a fully traceable seafood supply chain is already underway, but additional efforts are needed to raise awareness among producers and harvesters. Over the coming months, Sea Pact members will continue providing data-sharing guidelines to their suppliers.
How can you and your company help spread awareness and prepare your supply chain for these requirements? By collaborating with stakeholders, implementing traceability solutions, and engaging supply chain partners, we can achieve regulatory compliance and build a responsible, transparent future for seafood.