Import chain of custody

Seafood traceability software that carries the harvest event through to the entry filing

Seafood traceability is the ability to follow a fish or fishery product from the harvesting or production event, through every transfer, to the point it enters commerce. The federal Seafood Traceability Program at 50 CFR 300.324 requires harvest and landing data at entry for 13 species groups covering more than 1,100 species, and chain of custody records retained for two years at the importer's place of business. Neurobird holds the lot, its harvest event and every link behind it.

1,100unique species inside the programme
13species groups requiring harvest data at entry
2 yearshow long the records must stay retrievable
Seafood processing worker labelling a chilled tuna lot while the harvest certificate and landing record sit beside the scale
The harvest happened months ago on somebody else's vessel. You still have to prove it.

Neurobird Seafood Traceability in short

  • Hold the harvest or production event per lot: vessel, flag state, gear, authorisation, farm or facility
  • Record every transfer, combination and split so the chain back to harvest survives processing
  • Assemble the data set required at entry and keep a copy of what was actually filed
  • 1,100 The programme covers more than 1,100 unique species grouped into 13 species groups identified as particularly vulnerable to illegal fishing, seafood fraud, or both, and reaches about half of all seafood imported into the United States. NOAA Fisheries, SIMP
  • 2 years A paper or electronic copy of all documentation and data sets, and all supporting records the entry filing was based on, must be kept at the importer's place of business for two years from the date of import, export or re-export. eCFR, 50 CFR 300.323
  • Pricing runs 220 to 880 US dollars per month across 3 tiers. Early access is free.
The daily reality

What seafood importers, processors and distributors actually deal with

The harvest event happened on a vessel on the other side of the world, and the evidence of it arrives as a scanned certificate weeks after the container sails.
Records have to be produced at the importer's own place of business for two years, so a request about last season is a search through email rather than a query.
Lots get combined, split and relabelled through processing, and the link back to the harvesting event survives only if somebody wrote it down at each step.

Why it stays broken

The harvest event happens on a vessel or a farm outside your control, and the evidence of it travels as scanned paper through several intermediaries before it reaches the filer. Enterprise traceability platforms assume everybody in the chain adopts them. They do not. So importers rebuild the chain by email each time, and the two year retention obligation becomes a mailbox search rather than a lookup.

Chain of custody records must stay retrievable at your own place of business for 2 years from the date of import, which is well after everyone who touched the lot has moved on.

Other records that must be retained include any time the product changes custody, such as processing and shipping.

NOAA SIMP compliance guide, source
Interactive preview

The chain, lot by lot

A working preview. Tick a lot to move it through the chain.

neurobird / seafood traceability
3 / 5
requirements current
RequirementStatusNext due
Audit request, 14 lots, prior seasoncurrentin 42d
Chain of custody gap, processor to exporterdue soonin 9d
Lot 8841, yellowfin, harvest event missingcurrentin 120d
Aggregated harvest, 6 small vesselsoverdue3d late
Entry filing due, container MSKU 4471currentin 64d

Tick a requirement to file evidence against it.

What it does

Neurobird Seafood Traceability Compliance Platform

Make the lot the record. The harvest event goes in once, every transfer links onto it, and the data set filed at entry is stored against the same lot.

  • 1Hold the harvest or production event per lot: vessel, flag state, gear, authorisation, farm or facility
  • 2Record every transfer, combination and split so the chain back to harvest survives processing
  • 3Assemble the data set required at entry and keep a copy of what was actually filed
  • 4Keep documentation retrievable at your place of business for the full two year retention period

What changes with Neurobird Seafood Traceability?

The same work, read left to right: how it runs today, and how it runs once the record is in one place.

Seafood traceability: current practice compared with Neurobird Seafood Traceability
TodayWith Neurobird Seafood Traceability
The harvest event happened on a vessel on the other side of the world, and the evidence of it arrives as a scanned certificate weeks after the container sailsHold the harvest or production event per lot: vessel, flag state, gear, authorisation, farm or facility
Records have to be produced at the importer's own place of business for two years, so a request about last season is a search through email rather than a queryRecord every transfer, combination and split so the chain back to harvest survives processing
Lots get combined, split and relabelled through processing, and the link back to the harvesting event survives only if somebody wrote it down at each stepAssemble the data set required at entry and keep a copy of what was actually filed

Who is this for?

Same lot record, three positions in the chain.

Importer of record

You file the entry

You carry the reporting and recordkeeping obligation. You need the harvest data set complete before the container arrives and the supporting records held for two years.

Processor

You transform the lot

Fish comes in as one lot and leaves as several. You need combinations and splits recorded so the link back to the harvest event is not broken by your own production.

Distributor

You move product on

You sell to retail and food service who increasingly ask for traceability data. You need to answer a lot question in minutes rather than by calling your supplier.

How does Neurobird Seafood Traceability work?

  1. Every lot is a record

    Species, harvest or production event, landing, and the identifiers that connect the two, held from the first supplier document onward.

  2. Transfers are links

    Each change of hands, combination or split is an event on the lot, so the chain of custody assembles itself rather than being reconstructed on demand.

  3. Entry data is kept, not just sent

    The data set reported at entry is stored against the lot alongside the supporting records, which is what an audit actually asks for.

What the numbers say about seafood traceability

Useful if you are preparing for an audit or tightening supplier documentation. Each source links out.

1,100

The programme covers more than 1,100 unique species grouped into 13 species groups identified as particularly vulnerable to illegal fishing, seafood fraud, or both, and reaches about half of all seafood imported into the United States.

NOAA Fisheries, SIMP
2 years

A paper or electronic copy of all documentation and data sets, and all supporting records the entry filing was based on, must be kept at the importer's place of business for two years from the date of import, export or re-export.

eCFR, 50 CFR 300.323
2018

Compliance began on 1 January 2018 for the first eleven species groups, with shrimp and abalone becoming effective on 31 December 2018, so the retention obligation has now outlived several supplier relationships.

NOAA Fisheries, SIMP
30 days

An International Fisheries Trade Permit application must be submitted electronically with the permit fee at least 30 days before the date the applicant wants the permit to take effect, and only United States residents may apply.

eCFR, 50 CFR 300.322
123.9

Seafood HACCP records must be retained at the processing facility or importer's place of business for at least 1 year for refrigerated products and at least 2 years for frozen, preserved or shelf stable products.

eCFR, 21 CFR 123.9

Seafood traceability software questions, answered

Key terms

What is seafood traceability?
Seafood traceability is the ability to follow a fish or fishery product from the harvesting or production event through every transfer to the point it enters commerce. In the United States the federal Seafood Traceability Program at 50 CFR 300.324 requires harvest and landing data to be reported at entry for species groups identified as vulnerable to illegal fishing or fraud, plus chain of custody records back to the harvest.
What are the species covered by the programme?
Thirteen species groups covering more than 1,100 unique species: abalone, Atlantic cod, Pacific cod, Atlantic blue crab, red king crab, dolphinfish, grouper, red snapper, sea cucumber, sharks, shrimp, swordfish and tunas. Compliance began on 1 January 2018 for the first eleven groups, and on 31 December 2018 for shrimp and abalone.

How long do the records have to be kept?

Section 300.323(b) requires a paper or electronic copy of all documentation and data sets, plus the supporting records the entry filing was made on, to be kept at the importer's place of business and available for inspection for two years from the date of import, export or re-export.

Does this replace the entry filing itself?

No. The filing goes through your broker and the trade data system as it does now. What lives here is the lot: the harvest event, the chain of custody, and a copy of what was filed, held where an audit can reach it.

What about seafood HACCP records?

They run alongside. Under 21 CFR 123.9 records are retained at least one year for refrigerated product and two years for frozen, preserved or shelf stable product, and records about equipment or process adequacy for two years.

Can it handle aggregated harvests?

Yes. Small scale wild capture and small scale aquaculture are reported as aggregated harvest events, and the lot record carries the aggregation rather than pretending each fish came from one vessel.

Why we are building this

Traceability sounds like a technology problem and is actually a documents problem. The harvest event is real, it was recorded by somebody on a vessel, and the evidence of it then passes through several hands before it reaches the person who has to file it.

Every platform that tried to fix this asked the whole chain to adopt the same system. The chain did not. So the importer, who carries the legal obligation and none of the bargaining power, ends up rebuilding the chain from email each time somebody asks.

We would rather build this with people who file entries than with people who design standards. Tell us where your chain actually breaks, and where we have got it wrong.

Neurobird Team neurobird.com

Where the requirement comes from

The federal programmes a seafood chain of custody answers to.

How much does Neurobird Seafood Traceability cost?

Priced per importing entity because permits, filings and retention obligations sit at that level. Lots, suppliers and users are unlimited on every tier.

Single entity
$220
per entity, per month
  • Lot records
  • Harvest event capture
  • Supplier document store
  • Two year retention
  • Email support
Request access
Importer
$440
per entity, per month
  • Everything in Single entity
  • Chain of custody assembly
  • Entry data set copies
  • Audit response packs
  • Named contact
Request access
Group
$880
per entity, per month
  • Everything in Importer
  • Multiple entities in one view
  • Processor splits and combinations
  • Supplier scorecards
  • Onboarding included
Talk to us
First 15 importers get early access pricing locked for three years

Get free early access

If you import or process seafood, tell us where your chain of custody breaks and how long an audit request takes to answer.

Straight answer on where this is: In development. Early access gets the working preview, a say in what ships first, and early access pricing. It does not get you a login today.

Prefer email? Write to office@neurobird.com and a person will reply. No autoresponder.