Indonesian Vegetables Traceability: Essential 2025 Guide

A 60-day, low-cost playbook to meet FSMA 204 for Indonesian vegetable exports. Exact KDEs/CTEs by step, how to assign Traceability Lot Codes, case labeling, co-mingled lots, and what to do in a recall.

If you export fresh vegetables from Indonesia to the U.S., 2025 is your build year. FSMA 204 goes live January 20, 2026, and the fastest way to get ready is to pilot a simple, low-cost system right now. We took packhouses from paper chaos to audit-ready in 60 days using this exact approach. Here’s the playbook we wish we had years ago.

The 3 pillars of FSMA 204 done right

1. Clear Traceability Lot Code (TLC) rules. One TLC per production lot at initial pack. Keep it simple and consistent, and link it to source farms and harvest dates.

2. KDEs at every CTE. Capture the exact Key Data Elements (KDEs) at each Critical Tracking Event (CTE). For FTL vegetables that means Harvest, Cooling (if not part of harvest), Initial Packing, Shipping, and Receiving.

3. Labels plus a sortable file in 24 hours. Put TLC on case and pallet labels and have a single spreadsheet you can export within 24 hours in a recall. That’s the real test.

Which Indonesian vegetables are actually on the Food Traceability List?

The Food Traceability List (FTL) includes fresh commodities linked to past outbreaks. For Indonesian exporters, the common FTL items are:

• Cucumbers. For example, our Japanese Cucumber (Kyuri).
• Tomatoes. See Tomatoes.
• Leafy greens. Romaine and red lettuce are covered, including Baby Romaine and Loloroso (Red Lettuce).
• Peppers. Hot and sweet types are in scope, such as Red Cayenne Pepper.

Not on the FTL: carrots, beetroot, onions, eggplant, radish, and most frozen vegetables. That includes Carrots, Beetroot, Onion, Purple Eggplant, Red Radish, and our frozen lines like Premium Frozen Edamame, Premium Frozen Sweet Corn, Frozen Mixed Vegetables, Premium Frozen Okra, Premium Frozen Potatoes, and Frozen Paprika (Bell Peppers). We still recommend baseline traceability for non-FTL lines because it strengthens supplier assurance and recall readiness.

Practical takeaway. If your U.S. program includes cucumbers, tomatoes, leafy greens, or peppers, you are in FSMA 204 scope.

Week 1–2: Map your chain and lock the TLC format

Start small with one FTL SKU. We often pick Japanese Cucumber (Kyuri) or Tomatoes.

• Map your CTEs. List the exact points where Harvest, Cooling, Initial Packing, and Shipping occur. Identify Receiving if you buy from other packers.
• Decide TLC format. Keep it human-readable and scannable.

Example TLC: IV-WJ-BOGOR-20250115-PKH01-L01

• IV = Indonesia-Vegetables

• WJ-BOGOR = region

• 20250115 = pack date

• PKH01 = packhouse ID

• L01 = line or batch number

• Create your master spreadsheet. Use Google Sheets. Tabs: Farms, Harvests, Cooling, Packing, Shipping, Receiving. Add data validation to keep entries consistent.

• Set up low-cost labels. A thermal printer, labels with a QR that encodes the TLC and the product name. Case and pallet labels only. Consumer packs are not required by FSMA 204 to carry TLC.

Need help validating your TLC logic or label layout for bilingual English/Bahasa? If you want a quick review of your draft, Contact us on whatsapp.

Week 3–6: Capture the KDEs at each CTE with low-cost tools

Here’s what to record. We keep it to the minimum FDA asks for. You can run this with Google Sheets, shared Drive folders, and WhatsApp photo evidence.

What records do I need at harvest and cooling for cucumbers or leafy greens?

Harvest KDEs

• Commodity and variety.
• Farm business name and location description. Use a plot ID and GPS if you have it.
• Harvest date.
• Quantity and unit. For example, 1,200 kg.
• Reference to the “lot code source.” This is how you will link harvests to your later TLC.

Cooling KDEs. If cooling occurs before initial pack.

• Product, quantity, and unit.
• Date and location of cooling.
• Reference to the same lot code source.

Pro tip. Create a WhatsApp group with farm supervisors. Ask for time-stamped harvest photos of field tags and filled bins. Save photos to a Drive folder named by date and plot ID. It is simple proof during audits.

How to assign a Traceability Lot Code if I combine produce from several smallholder farms?

You can co-mingle harvests from multiple farms into one production lot at initial packing. The rule is: one TLC per production lot, but your records must list every source farm and harvest date that fed that lot. Two practical options:

• Single-day blend. Combine only harvests from the same day and geographic cluster. Your Packing tab links TLC IV-WJ-BOGOR-20250115-PKH01-L01 to Farm IDs F01, F04, and F09, all harvested 15 Jan 2025.
• Rolling 48-hour blend. If your buyers need larger lots, you can blend two harvest days. Keep the date range tight and list both dates with their farm IDs in the lot record. Keep this policy written in your traceability plan.

KDEs at initial pack, shipping, and receiving

Initial packing KDEs

• TLC you assign.
• Product, variety, and pack date.
• Pack location.
• Quantity and unit per TLC.
• Complete list of source farms and harvest date range.

Shipping KDEs

• TLCs included in the shipment.
• Shipper name and location.
• Receiver name and location.
• Date shipped.
• Quantity and unit by TLC.
• Reference document. BOL or invoice number.

Receiving KDEs

• TLCs received.
• Receiver name and location.
• Shipper name and location.
• Date received.
• Quantity and unit by TLC.
• Reference document.

Do I need QR or barcodes on consumer packs, or just on cases and pallets?

FSMA 204 does not require consumer unit labels. Put the TLC on case labels, pallet tags, and your shipping documents or EDI. We prefer a QR or Code 128 with human-readable TLC. Include product name, grade, net weight, pack date, and TLC. Bilingual labels in English and Bahasa reduce errors at the dock.

Week 7–12: Pilot, stress-test, and scale across SKUs

Pick one leafy green like Baby Romaine or Loloroso and one fruiting veg like Red Cayenne Pepper. Run a 4-week pilot shipment to the U.S.

• Mock recall. Ask your team to pull all KDEs for one TLC within 2 hours. Then generate the full sortable spreadsheet for FDA within 24 hours. If you cannot do that yet, your data is scattered. Consolidate to a single master sheet.
• Spot-check labels. Scan case labels at random and verify the TLC matches the packing tab and shipping record. Photograph mismatches and fix the root cause.
• Buyer integration. Share TLC lists ahead of arrival. Many U.S. receivers now request TLCs by ASN or EDI. A clean CSV exports well from Google Sheets.

Scale to other FTL SKUs. Once cucumbers and tomatoes run smoothly, extend to leafy greens and peppers. For non-FTL lines like Carrots and Onion, keep a simpler version to drive consistency.

Common headaches we see, and how to avoid them

• Co-mingling without sources. Teams blend farms during packing but forget to list all farms and dates under the TLC. Fix it with a simple rule. No TLC assignment until the source farm list is complete.
• Too many TLC formats. One team codes by date, another by PO. Standardize to one format across all FTL items.
• Labels that do not survive condensation. Use thermal labels rated for cold-chain. Wipe case surfaces before application.
• Photos everywhere, records nowhere. WhatsApp photos are great, but always move them to the Drive folder linked in your Harvest row. Assign one person per shift to file them.
• Waiting for a software project. You don’t need one to comply. Start with Sheets and labels now. If you adopt a platform later, migrate cleanly.

Are small farms or traditional markets in Indonesia exempt from FSMA 204?

Exemptions are narrow. If your product enters U.S. commerce and you perform covered activities like initial packing or shipping for an FTL commodity, you should plan to comply regardless of grower size. Direct-to-consumer sales and certain small retail scenarios do not apply to exports. We recommend confirming your exact status with your U.S. importer, but in practice, Indonesian exporters of cucumbers, tomatoes, leafy greens, and peppers keep full FSMA 204 records.

How fast must I supply records to FDA during a recall?

The rule expects an electronic, sortable file within 24 hours of request. We aim for two hours internally. During drills we export a CSV with these columns for each TLC: product, variety, TLC, harvest date range, farms, pack date and location, quantities, shipper, receiver, ship and receive dates, and reference docs.

A simple starter template you can copy today

• Farms tab. Farm ID, farm name, contact, GPS, crop.
• Harvests tab. Farm ID, plot ID, crop, variety, harvest date, quantity, WhatsApp folder link.
• Cooling tab. Date, location, lot source reference, quantity.
• Packing tab. TLC, product, pack date, packhouse, line, source farm IDs, harvest date range, quantity per pack type.
• Shipping tab. BOL, ship date, shipper, receiver, each TLC and quantity.
• Receiving tab. Receive date, receiver, shipper, each TLC and quantity.

What’s interesting is how quickly teams improve once the TLC is locked and every CTE has a few mandatory fields. Most sites reach reliable performance within four to six weeks.

Resources and next steps

• Start with one SKU on the FTL. We recommend Japanese Cucumber (Kyuri) or Tomatoes to prove the workflow.
• Write a one-page TLC policy. Define when a lot starts and ends, and how you handle co-mingling.
• Run a mock recall by week six. You will learn more in two hours of practice than in two weeks of meetings.

Questions about your situation or buyer requirements in the U.S. market? If you want a quick sanity check on your plan or sample labels, Contact us on email. And if you are exploring product sourcing aligned with FSMA-ready programs, you can also View our products.

Our experience shows that simple beats perfect. If you can print a durable case label with a consistent TLC, capture KDEs at harvest, cooling, packing, and shipping, and export a clean CSV in 24 hours, you are ahead of most of the market heading into 2026. Build it in 2025 while you still have room to practice.