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Run: Grocery Seafood Country of Origin Compliance Audit

Audit seafood COOL labels, supplier records, and wild-caught/farm-raised disclosures in grocery cases and packages. Use it to catch label mismatches, missing...

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Audit Setup and Inspector Information

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

Supplier Documentation and Chain of Custody

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).
Imported seafood must have documentation traceable to the country of harvest or aquaculture origin. Verify at least one affidavit per imported species on hand.
USDA COOL requires covered commodity records to be retained for at least 2 years (7 CFR 60.400). Spot-check oldest records on file.
Record as a ratio (e.g., 18/20). Flag any SKUs lacking documentation for corrective action.

Point-of-Sale Label Accuracy — Country of Origin

Each species or lot in the full-service case must have a placard stating country of origin. Verify every tray or bin.
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.
Cross-reference at least 5 displayed items against invoices or certificates of origin. A mismatch is a critical non-conformance.
Record as a ratio (e.g., 22/25). List any non-conforming items in the comments.
Frozen covered seafood must be labeled at the retail level. Verify a minimum of 5 frozen SKUs.

Wild-Caught vs. 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.
For items labeled wild-caught, confirm that the corresponding invoice or affidavit specifies wild harvest. Farm-raised items should reference aquaculture origin.
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.
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

A placard placed more than one product-width away from the item it describes creates ambiguity and is a labeling deficiency.
Handwritten placards are permissible but must be clearly legible. Faded, smeared, or illegible placards must be replaced immediately.
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.
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

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

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