Indonesian Vegetables: FSMA Sanitary Transport 2025 Guide

A practical, one-page agreement playbook and temperature-control record matrix for ocean reefer vegetables to the U.S. What to include, who the “shipper” is when you use a forwarder, which records FDA asks for, and how to handle temperature deviations—written by exporters who do this every week.

If you’re exporting Indonesian vegetables by ocean reefer to the U.S., you’ve probably asked the same questions we hear every month: Who is the “shipper” under FSMA when a forwarder books the container? What proof of cleaning or temperature control is enough for FDA and retail buyers? And do I really need real-time monitoring? Here’s the 2025 playbook we use on our own shipments.

The three pillars of a solid FSMA sanitary transport setup

In our experience, the exporters who breeze through audits do three things consistently:

Written responsibilities. A one-page shipper–carrier sanitary transport agreement that names roles, states the required temperatures, vent/airflow settings, cleaning expectations, and who keeps what records.
Temperature control plan. A simple matrix that covers pre-cooling, setpoints, vent settings, logger placement, and what to do if temperatures drift.
Evidence. Clean, retrievable records: container cleaning and prior cargo verification, pre-trip inspection (PTI), pre-cool documentation, continuous temperature data (logger or RCM), and handoff checks at loading/unloading.

That’s the backbone. Now, let’s make it practical.

Who is the “shipper” if I book through a freight forwarder?

Short answer. Under FDA’s Sanitary Transportation of Human and Animal Food rule (21 CFR Part 1 Subpart O), the “shipper” is the party who initiates the shipment by arranging the carrier and specifying sanitary requirements. If your forwarder acts on your instructions, you remain the shipper. If the importer or forwarder is the party setting temperatures and hiring the carrier, they might be the shipper.

Here’s the thing. The rule technically covers motor and rail transport within the U.S. Segments occurring entirely outside the U.S. (the ocean leg) aren’t legally covered. But U.S. buyers still expect FSMA-aligned controls end-to-end. We document the ocean leg anyway because importers will ask for it. Our rule of thumb: name the shipper in writing, even when a forwarder is in the middle. It removes doubt when there’s a claim.

Practical takeaway. Decide who is the shipper before booking. Put it in the agreement. If your forwarder sets the reefer and hires drayage in the U.S., list them as shipper for those legs or have them sign on as an agent for the named shipper.

A one-page sanitary transport agreement you can actually use

You don’t need six pages of legalese. We use a tight one-pager that covers what FDA and buyers care about.

Include these clauses:

Parties and roles. Identify Shipper, Carrier, Loader, and Receiver. If a forwarder is acting as agent, say so.
Product scope. E.g., fresh leafy vegetables, tomatoes, cucumbers. No incompatible mixed loads without written approval.
Temperature control. State setpoint, acceptable range, vent setting, and airflow requirements per commodity. Example: Baby romaine 0–1°C at supply air, vent 20–25 cbm/h, no ethylene exposure.
Pre-cooling. Shipper will pre-cool product to target pulp before stuffing. Carrier will pre-cool container to setpoint with PTI complete.
Equipment sanitation. Carrier provides clean, dry, odor-free reefer with intact gaskets and T-bar floor unobstructed. Provide evidence: latest washout/cleaning certificate and prior cargo report.
Prior cargo restrictions. Must not have transported chemicals, allergens in bulk, fishmeal, or cargo with strong odors in last 1–3 loads unless deep-cleaned and verified.
Temperature monitoring. Shipper to place calibrated data logger(s). Carrier to maintain setpoint and provide RCM data if available. Deviation notification within 2 hours of detection.
Loading practices. Use airflow-compatible pallets. Maintain floor and wall clearances. Record pulp temperatures at start/middle/end of stuffing.
Sealing and chain of custody. Seal number and time recorded. Handoffs must document seal checks.
Records and retention. Each party keeps their records. Minimum 12 months retention. Buyers may request 24 months; we recommend 24.
Training. Carrier confirms FSMA sanitary transportation training for U.S. motor carriers used on inland legs and can provide proof upon request.
Corrective actions. If deviation occurs, follow documented decision tree and inform all parties.

If you want a clean, editable one-page “sample FSMA sanitary transport agreement for vegetable exporters,” we’re happy to share our template and adapt it to your SKUs. Need help with your specific situation? Contact us on whatsapp.

Your temperature-control plan, by commodity

What FDA expects. You must show you specified the temperature and that the carrier maintained it. Continuous monitoring is best practice. Real-time monitoring isn’t required.

We set by product, not by habit. A few examples we actually use:

Leafy vegetables. For Baby Romaine (Baby Romaine Lettuce) and Loloroso (Red Lettuce): supply air 0–1°C, vent 20–25 cbm/h, high humidity via packaging, no ethylene exposure. Pre-cool product to ≤2°C before stuffing.
Cucumbers. For Japanese Cucumber (Kyuri): 10–12°C, vent 10–15 cbm/h. Avoid chilling below 10°C to prevent injury.
Tomatoes. For Tomatoes: 12–15°C for color and shelf life. Never below 10°C. Vent 10–15 cbm/h and separate from ethylene-sensitive items.

Airflow details that save loads:

Don’t block the T-bar floor. Maintain a 5–10 cm gap to doors and walls.
Align cartons to the air chute. No overhang that collapses the airflow.
Pallets with open bottom decks outperform closed decks for return air.

Cutaway view of a refrigerated container showing correct airflow around palletized vegetables: blue airflow streams moving evenly past cartons, clear gaps to walls and doors, open‑deck pallets over a T‑bar floor, and cartons aligned to the central air chute without overhang.

Data logger validation and setup:

Use calibrated devices (NIST-traceable or annual calibration). Set 10–15 minute intervals.
Place one logger near the return air mid-load and a second in the center of the pallet stack. Start logging before the doors close.
If your carrier offers Remote Container Management (RCM), request the voyage trace at destination. In 2024–2025, most major lines make this available on request.

Practical takeaway. Specify the setpoint and vent. Document pre-cool. Use at least one calibrated logger. Request RCM data as a backup.

What records will FDA or buyers ask for?

We’ve shipped enough reefer vegetables to know what gets requested most:

Container PTI and pre-cool evidence. Carrier PTI printout or digital record, plus photo of display showing setpoint before stuffing.
Product pre-cooling proof. Pulp temperature logs from start/middle/end of stuffing, with times and operator initials.
Cleaning and prior cargo verification. Washout or sanitation certificate and prior cargo history (last 1–3 loads). Visual inspection checklist with photos.
Continuous temperature records. Data logger download. RCM trace if available.
Seal records. Seal number, time applied, and each seal check at handoffs.
Training proof for U.S. inland carriers. FSMA sanitary transportation training confirmation for drivers handling port drayage or final delivery.

Record retention period. FSMA’s sanitary transportation rule requires keeping these records at least 12 months from the time they were in effect. Many importers expect 24 months to align with broader FSMA/FSVP file reviews. We keep 24 months.

“Do I need real-time temperature monitoring or just a data logger?”

FDA doesn’t require real-time tracking. A calibrated data logger is acceptable. Real-time helps you react mid-voyage, but it’s not mandatory. Our approach: use a logger on every container and request RCM data from the line. Real-time cellular devices are a value-add for riskier loads or peak heat seasons.

“What proof of container cleaning or prior cargo history is expected?”

We ask for three items every time:

Washout or sanitation certificate dated not more than 30 days prior or after prior load discharge if the line issues by voyage.
Prior cargo report for at least the last one to three loads. Reject reefers that previously carried chemicals, powders, fishmeal, or strong-odor cargo unless deep-cleaned and verified.
Visual inspection with photos. Check gaskets, drains, floor, ceiling, and smell. If in doubt, swap the container. Cheap insurance.

How to document pre-cooling and setpoints that withstand audits

Record product pulp temps. 3–5 samples per lot before stuffing, then again mid-stuffing and at the last pallet. Note carton position and time.
Record equipment setpoints. Photo the controller with date/time. Attach PTI.
Note vent settings. Most people forget this and lose claims. Write the cbm/h setting on the stuffing record.

What to do if a temperature deviation happens

Don’t ignore it. Document it.

Immediate actions. Notify carrier and consignee. Validate actual pulp temperature on arrival before breaking the seal if possible. Pull the logger data.
Risk assessment. Was supply air above spec? For how long? Example: Baby romaine above 5°C for more than 2 hours triggers a quality risk review. Tomatoes at 8°C? That’s chilling injury territory below 10°C, so note duration and batch exposure.
Corrective action examples (CAPA). Rework segregation, accelerated distribution, alternative processing, or destruction. Identify root cause: wrong setpoint at origin, blocked airflow, vent closed, equipment failure. Assign preventive steps: loader refresher training, revised stuffing SOP, mandatory double-check of vent setting, second logger placement.
Documentation. Create a deviation record with timestamps, data downloads, photos, and the final disposition. Buyers trust clean CAPA.

Common mistakes we still see (and how to avoid them)

Calling the forwarder the shipper without assigning responsibilities. Fix it in writing.
Mixing ethylene producers and sensitive items. Don’t load tomatoes with leafy greens.
Starting the data logger after the doors are sealed. Start before closing and confirm interval.
Ignoring vent settings. Write the setting on the stuffing checklist.
No photos. A two-minute photo set of the clean floor, gaskets, controller screen, and seal saves hours of arguing later.

When this advice applies (and when it doesn’t)

Applies to. Fresh vegetable reefers headed to the U.S., especially leafy vegetables, cucumbers, and tomatoes. Also relevant for quality-driven chilled exports where buyers impose FSMA-like requirements.

Doesn’t fully apply to. Frozen product where temperature control is about quality, not safety. That said, many buyers still require similar documentation for IQF lines like our Premium Frozen Edamame or Frozen Paprika (Bell Peppers) - Red, Yellow, Green & Mixed. Keep the same discipline. It pays off during claims.

Fast-start record matrix you can copy

Use this as your “sanitary transport records” checklist per reefer:

Before stuffing. Carrier PTI and pre-cool proof. Washout certificate. Prior cargo report. Visual inspection with photos. Agreement on setpoint, vent, airflow.
During stuffing. Pulp temperature logs (start/middle/end). Logger IDs and placement map. Controller photo with setpoint and vent. Seal number and time.
After stuffing. Bill of lading with commodity and temperature notation. Handover record to terminal with seal verification.
In voyage. Logger running. If available, RCM subscription and alerts.
On arrival. Seal check, logger retrieval, RCM trace request. Arrival pulp temperatures. Deviation assessment and CAPA if needed.

Questions about your project or need us to review your draft agreement and temperature plan? Call us. And if you’re evaluating suppliers, you can also View our products.