Grocery Seafood Country of Origin Compliance Audit

Compliance verification that all seafood items in the grocery department carry accurate country-of-origin (COOL) labels and wild-caught/farm-raised disclosures per USDA Agricultural Marketing Act (7 U.S.C. § 1638) and FDA Food Code 2022 requirements.

Audit Setup and Inspector Information

• Audit date and time
  Record the date and time the audit begins.
• Inspector name and title
  Full name and job title of the person conducting this audit.
• Store number or location identifier
  Enter the store number, name, or address for traceability.
• Audit scope
  Select all seafood display areas included in this audit.

Supplier Documentation and Chain of Custody

• Supplier invoices or bills of lading on file for all seafood SKUs received in the past 30 days
  Records must identify country of origin and harvest method (wild-caught or farm-raised) for each species. USDA COOL 7 U.S.C. § 1638b(c).
• Supplier affidavits or certificates of origin available for all imported seafood species
  Imported seafood must have documentation traceable to the country of harvest or aquaculture origin. Verify at least one affidavit per imported species on hand.
• Documentation retention period meets minimum 2-year requirement
  USDA COOL requires covered commodity records to be retained for at least 2 years (7 CFR 60.400). Spot-check oldest records on file.
• Number of seafood SKUs with complete supplier documentation vs. total SKUs audited
  Record as a ratio (e.g., 18/20). Flag any SKUs lacking documentation for corrective action.

Point-of-Sale Label Accuracy — Country of Origin

• All full-service case items display a country-of-origin placard or label visible to the consumer
  Each species or lot in the full-service case must have a placard stating country of origin. Verify every tray or bin.
• All self-service and pre-packaged seafood items carry a country-of-origin statement on the package label
  Pre-packaged covered seafood must include country of origin on the principal display panel or information panel. Check a minimum of 10 SKUs or all SKUs if fewer than 10.
• Country-of-origin statements match the supplier documentation on file
  Cross-reference at least 5 displayed items against invoices or certificates of origin. A mismatch is a critical non-conformance.
• Number of items with accurate COOL labels vs. total items spot-checked
  Record as a ratio (e.g., 22/25). List any non-conforming items in the comments.
• Frozen seafood packages display country of origin on outer packaging
  Frozen covered seafood must be labeled at the retail level. Verify a minimum of 5 frozen SKUs.

Wild-Caught vs. Farm-Raised Disclosure

• All displayed seafood items carry a clear wild-caught or farm-raised disclosure
  Disclosure must appear on the label or placard adjacent to the country-of-origin statement. Verify every item in the full-service and self-service cases.
• Wild-caught disclosures are supported by supplier documentation identifying the harvest method
  For items labeled wild-caught, confirm that the corresponding invoice or affidavit specifies wild harvest. Farm-raised items should reference aquaculture origin.
• No items are labeled with both wild-caught and farm-raised without a permissible mixed-lot justification
  Mixed-lot labeling is only permissible when the retailer cannot segregate the lots and must disclose both methods. Verify any mixed-lot labels have written justification on file.
• Harvest method disclosure font size is legible and not obscured by price tags or packaging
  Disclosure must be clearly visible to the consumer at the point of sale. Inspect for stickers, overlapping labels, or faded print that obscures the disclosure.

Display Signage and Consumer Accessibility

• Placards and shelf tags are positioned at or directly adjacent to the product they describe
  A placard placed more than one product-width away from the item it describes creates ambiguity and is a labeling deficiency.
• Placard text is printed or typed — handwritten placards are legible and not faded
  Handwritten placards are permissible but must be clearly legible. Faded, smeared, or illegible placards must be replaced immediately.
• Species common name is displayed alongside country-of-origin and harvest method information
  FDA requires seafood sold at retail to display the market name (common name) of the species (FDA Food Code 2022 § 3-602.11). Verify common name is present on all labels.
• No COOL placards are missing, blank, or displaying a prior product's information
  Inspect for placards left in place after a product rotation that now describe a different item. This is a labeling non-conformance.

Corrective Actions and Audit Close-Out

• Total number of critical non-conformances identified during this audit
  Enter the count of items marked as critical failures. Zero is the target.
• All critical non-conformances have a corrective action assigned with a responsible party and due date
  For each critical deficiency, document: (1) description of the non-conformance, (2) corrective action required, (3) responsible employee, (4) target completion date.
• Seafood department manager notified of audit findings
  Confirm verbal or written notification was provided to the department manager or designee before the auditor leaves the store.
• Additional observations or notes
  Record any observations not captured in the sections above, including positive findings or systemic issues requiring escalation.
• Inspector signature
  Inspector signature confirms that all findings are accurate and complete to the best of their knowledge.