The sushi industry has witnessed a remarkable surge in popularity worldwide, captivating the palates of millions with its unique flavors and convenience offerings. Originating from Japan, sushi has transcended cultural boundaries to become a beloved culinary delicacy enjoyed by consumers globally.

The sushi industry experienced a major surge in sales during and after the COVID-19 pandemic and is valued at over $10 billion annually, with over $3 billion from to-go sushi and $7 billion from restaurants as of 2023.¹ Sushi data is not frequently broken out in supermarkets, but is consolidated in the seafood department or prepared foods department sales. A more realistic industry estimate is that the supermarket sushi-to-go market alone is worth over $5 billion annually.

Americans purchased 43.7 million servings of sushi at grocery stores over the past year, mostly for quick lunches and dinners eaten soon after purchase. In addition, they bought 238.6 million servings from restaurants, including dining in and takeout.¹ The future for sushi is very bright. Its sales are forecast to increase by USD $3.81 billion, at a compound annual growth rate of 3.53 percent, between 2023 and 2028.²

Importance of Food Safety in the Sushi Industry

Ensuring food safety is a fundamental objective for all food suppliers, but it is even more important for suppliers of ready-to-eat sushi ingredients, including raw fish, cooked rice, nori, and vegetables.

With fish often sourced from international waters, the journey from farm or vessel to processing, transportation, distribution, and ultimately to consumers' plates involves numerous players, steps, and miles. Seafood served raw inherently carries risks associated with consuming raw or undercooked foods. Balancing the preservation of freshness with ensuring safety presents an ongoing challenge for suppliers, processors, sushi chefs, and retailers. Consequently, prioritizing food safety is an imperative, not a choice.

Whether domestic or international, suppliers must adhere to relevant laws and regulations and must obtain the necessary certifications to meet established food standards while maintaining constant scrutiny of suppliers.

Consumer Protection: Addressing the Lack of Standards in Sushi and Sashimi Safety

In many countries, including the U.S., formal standards or certifications for "sushi- or sashimi-grade" fish are absent. The absence of standardized criteria places the burden of ensuring quality and safety on individual suppliers and restaurants, resulting in variability in safety practices and consumer trust. Widespread abuse of those standards is occurring, with marketing serving as a driver for promoting sales over concern for consumer health. This scenario underscores the significance of initiatives like the National Fisheries Institute's (NFI's) newly formed Sushi Council, which seeks to establish and promote consistent food safety standards through industry collaboration.

Upholding stringent food safety and quality standards preserves consumer confidence in the sushi and sashimi industry, thereby supporting its long-term viability. Most importantly, it is important to combat fraudulent practices by remaining vigilant against fraudulent activities like mislabeling and adulteration of food ingredients that safeguard market integrity and ensure fair competition, benefiting both consumers and honest industry stakeholders. This protects consumers from potential allergy risks and other public health issues. By prioritizing these initiatives, the sushi and sashimi industry can protect consumer health, maintain product integrity, comply with regulations, educate the public, and uphold economic sustainability amid emerging challenges, including those posed by manipulated products.

Addressing Food Safety Concerns for Sushi

Sushi is classified as a high-risk product due to its primary ingredients—raw seafood and rice—and its ready-to-eat nature, which lacks a kill step to eliminate pathogens (Figure 1). This makes sushi particularly vulnerable to contamination by various pathogens and toxins that can pose serious health risks to consumers. Foodborne illnesses linked to sushi can arise from several factors, including improper storage and handling, temperature fluctuations, cross-contamination, and poor hygiene practices. Parasites, histamine, and bacterial contamination are among sushi's most common food safety risks. Ensuring rigorous food safety standards is essential to mitigate these risks and protect consumer health.

Parasites

Certain fish commonly used in sushi, such as tuna, hamachi, kanpachi, mackerel, and others may harbor parasites like Anisakis or Diphyllobothrium. Raw or undercooked seafood may harbor such parasites. Proper freezing for fish served raw is essential to mitigate the risk of parasite contamination.

Histamine

Histamine, or scombroid poisoning, can occur in sushi made with certain types of fish, such as tuna, mackerel, and mahi-mahi. Histamine poisoning accounts for about 40 percent³ of all seafood-related foodborne illnesses and comes from eating spoiled fish.⁴ When fish are not properly stored at the correct temperature after harvesting, histamine-producing bacteria can multiply, leading to elevated histamine levels in the fish tissue. Consumption can cause symptoms such as nausea, vomiting, headache, and skin flushing.

Bacterial Contamination

Raw seafood can become contaminated with bacteria like Salmonella, Escherichia coli, Vibrio spp., and Listeria monocytogenes during harvesting, processing, or handling. Consuming contaminated seafood can lead to foodborne illnesses such as salmonellosis, E. coli infection, vibriosis, or listeriosis.

Salmonella bacteria are a significant concern and can occur during harvesting, processing, or handling of the fish, leading to foodborne illness if raw or undercooked.⁵ One infamous Salmonella outbreak in sushi occurred in 2012 when it was found in raw tuna scrape. Salmonella from a recalled raw tuna product served in sushi, known as Nakaochi scrape, sickened at least 425 individuals in 28 states and the District of Columbia. Fifty-five people were hospitalized.⁶ The product was recalled in April 2012. However, individuals were still falling ill from this product until July of that year, highlighting the need for stricter recalls.

Listeria monocytogenes is a bacterium found in soil and water that can contaminate seafood during processing and handling. Consumption can cause listeriosis, a serious infection with potentially severe symptoms, especially in vulnerable populations such as pregnant women, the elderly, and individuals with weakened immune systems.⁷ There have been several foodborne illness outbreaks from sushi consumption caused by Listeria over the years.⁸

Case Study: Sushi Recall from Listeria Outbreak

The case study of Listeria contamination in sushi rolls in 2019⁹ illustrates the urgent need for rapid response protocols within the sushi industry. According to the U.S. Food and Drug Administration (FDA), the recall specifically encompassed the ready-to-eat sushi, salad, and spring roll products distributed and sold along the East Coast and Upper Midwest by Fuji Food Products Inc.¹⁰

Upon discovering a positive test result for Listeria contamination during routine testing, the company voluntarily initiated a rapid response recall protocol immediately. This decisive action was critical in averting serious risks and underscored the vital importance of swift responses to food safety incidents. Key steps in the rapid response process included immediate product quarantine, prompt notification to distributors and retailers, and issuing a public announcement to inform consumers about the recall and advise them to discard affected sushi rolls.

Prompt responses are crucial for minimizing consumer harm and mitigating damage to brand reputation. Prioritizing these protocols allows companies to manage food safety incidents effectively, protect consumer health, and maintain a brand reputation in the highly competitive sushi industry.

Global Food Safety Standards

Navigating diverse food safety regulations worldwide highlights the necessity for cohesive global standards. Disparities in standards can pose challenges for producers, exporters, and importers, potentially compromising consumer safety. Thus, a unified approach to food safety standards is imperative to uphold consistency and protect public health across international seafood supply chains.

The Global Food Safety Initiative (GFSI) sets a high-quality benchmark worldwide, guiding assessment frameworks and practices. Hazard Analysis and Critical Control Points (HACCP) and quantitative risk assessment are utilized to identify and manage potential hazards throughout production.

Government agencies, industry players, and consumers must work together to promote transparency and share best practices. By fostering open dialogue and information exchange, stakeholders can address emerging challenges and harmonize standards to ensure the safety and integrity of seafood products worldwide. This collaborative effort is essential for building consumer trust, facilitating international trade, and safeguarding public health in the seafood industry.

GFSI gives confidence anywhere in the world that a certified producer is adhering to a fully understood standard of production, whether in Japan or Vietnam. GFSI goes a long way toward creating a global understanding.

FSMA 204: A Game-Changer in Food Safety Regulation

In the U.S., recent focus on an updated section of the 2011 Food Safety Modernization Act (FSMA), which industry refers to as FSMA 204,¹¹ signifies a crucial step forward in bolstering food safety regulations, particularly within the sushi global supply chain. FSMA 204 mandates heightened, electronic traceability measures for entities involved in producing, processing, packaging, or storing foods susceptible to contamination risks, including the raw seafood commonly used in sushi. For the sushi industry, FSMA 204 necessitates comprehensive recordkeeping of Key Data Elements (KDEs) associated with Critical Tracking Events (CTEs), facilitating the rapid identification and removal of potentially compromised products from the market.

Under FSMA 204, CTEs related to raw seafood include:

• Harvesting
• Cooling
• Initial packing
• First land-based receiver
• Shipping
• Receiving
• Transformation.

This enhanced traceability framework empowers stakeholders to swiftly trace the origins and movement of sushi ingredients across international borders, thereby fortifying supply chain resilience and mitigating the risk of foodborne illness. By enforcing stringent traceability standards, FSMA 204 underscores FDA's commitment to advancing global food safety and consumer protection, ensuring that sushi aficionados can indulge in their favorite delicacy with confidence and peace of mind. A thorough understanding of how to execute traceability for seafood is needed in order to accomplish these goals.

Full-chain traceability for the global sushi supply chain involves tracking food products from origin to destination. Robust traceability systems enable sushi suppliers to immediately trace the origin and movement of ingredients, facilitating rapid response measures in the event of food safety incidents.

Traceability is crucial for verifying sustainability, and also for ensuring that seafood products are responsibly sourced and environmentally friendly. It might be said that traceability underpins every effort.

Technology to Achieve Traceability

Traceability is simply a record of “movement.” It already exists in all of those related documents and file folders in file drawers or on computers around the world. For a system to swiftly identify and subsequently manage potential contamination or outbreaks of foodborne illness, however, that information needs to be available or easily accessible instantly and without delay.

Various technology companies have been providing the tools to perform digital traceability for some time. As is common in any industry, these companies offer effective solutions, but they do so independently and without standardized collaboration.

Other impact technologies, such as blockchain and GS1 labeling guidance,¹² enhance these efforts by providing real-time data and insights into food product journeys, but they also have their limitations.

What was needed was to galvanize industry support for the development of an interoperable electronic traceability model that would allow every company to move its data easily among all of its suppliers, without delay. Thus, the Global Dialogue on Seafood Traceability (GDST)¹³ was born.

Global Dialogue on Seafood Traceability

GDST brings together companies and associations, and advocates for responsible business practices and seafood conservation, government organizations, and nongovernmental organizations. It has created such a standard: the GDST Standard Version 1.2.

Its origin came from concerns for sustainability—from centuries of over-fishing of some species to the effects of climate change—coupled with rigorous food safety measures governs responsible players in the industry. A “journey” from bait-to-plate, or hatchery-to-home, requires more than just the capture origin of the seafood itself; it also requires the data points that identify the "what, where, when, why, how, and who" of that meal.

Organizations such as the Marine Stewardship Council (MSC), Aquaculture Stewardship Council (ASC), and the Global Tuna Alliance (GTA) promote sustainable seafood practices and advocate for sustainability standards, responsible sourcing, and safe food.

Traceability is the element that brings it all together for them to be effective. By implementing robust traceability systems, seafood companies can enhance food safety, verify sustainability, improve operational efficiency, and build consumer trust.

National Fisheries Institute and the Sushi Council

In 2023, the National Fisheries Institute (NFI) inaugurated the Sushi Council, a pre-competitive, collaborative initiative focused on enhancing sushi product integrity and promoting industry-led food safety. NFI's Sushi Council is a platform for industry networking, collaboration, and innovation, representing the sushi supply chain community. By maintaining high sourcing and food safety standards, the Sushi Council acts as a central communication hub, sharing positive developments and addressing issues. With sushi's growing consumer base and established market presence, the Council supports continued expansion and economic integrity. The Council, made up of prominent companies in the sushi and sashimi supply chain, ensures the integrity and safety of raw seafood products from harvesters to end users. By uniting harvesters, importers, distributors, and end users, it establishes and promotes best practices for ready-to-eat fish products.

Led by the author, Founding Chairman Michael McNicholas of Culinary Collaborations LLC (Figure 2), the Sushi Council includes stakeholders across the sushi supply chain—from regulatory to academic to sushi operators to chain restaurants to ingredient manufacturers and suppliers to national retailers.

The Sushi Council aims to develop food safety guidance specific to the unique supply chain of sushi products, incorporating input from industry, government, and academia. The Council's inaugural meeting at Seafood Expo North America (SENA) in Boston in March 2024 focused on North American sushi market dynamics and food safety initiatives. The Council will establish crucial standards, such as defining "sushi-grade" and "sashimi-grade" fish, and aim to increase consumer confidence and elevate sushi's market presence through standardized seafood naming conventions and rigorous safety protocols.

It is an exciting time for collaboration and innovation in the sushi industry. The NFI Sushi Council looks forward to sharing updates on the development of future guidance and standards with the Food Safety Magazine audience.

References

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2. Technavio. "Sushi Restaurants Market Analysis APAC, North America, Europe, South America, Middle East and Africa—US, Japan, China, UK, France—Size and Forecast 2024–2028." February 2024. https://www.technavio.com/report/sushi-restaurants-market-industry-analysis.
3. Birkun, A. "Histamine Toxicity from Fish." Medscape. October 5, 2021. https://emedicine.medscape.com/article/1009464-overview?form=fpf.
4. Neogen. "Summer of sickness: Europe investigating histamine poisoning from tuna." NeoCenter Blog. August 29, 2017. https://www.neogen.com/neocenter/blog/summer-of-sickness-europe-investigating-histamine-poisoning-from-tuna/.
5. Marquis, G.E., S.M. Covaia, A.M. Tabb, C.J. Kitch, and R.S. Hellberg. "Microbiological safety and quality of ceviche, poke, and sushi dishes sold at retail outlets in Orange Country, CA." Heliyon 9, no. 6 (June 2023): e16862. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC10360930/.
6. Food Safety News. "Multistate Salmonella Outbreak Linked to Raw Tuna Grows to 425." July 26, 2012. https://www.foodsafetynews.com/2012/07/multistate-salmonella-outbreak-linked-to-raw-tuna-grows-to-425/.
7. Miya, S., H. Takahashi, T. Ishikawa, T. Fujii, and B. Kimura. "Risk of Listeria monocytogenes Contamination of Raw Ready-To-Eat Seafood Products Available at Retail Outlets in Japan." Applied and Environmental Microbiology 76, no. 10 (May 2010): 3383–3386. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC2869148/.
8. Whitworth, J. "Norwegian agency assess Listeria risk from sushi." Food Safety News. June 25, 2019. https://www.foodsafetynews.com/2019/06/norwegian-agency-assesses-listeria-risk-from-sushi/.
9. Lee, B.Y. "Another Listeria Outbreak Leads To Sushi, Salad And Spring Roll Recall." Forbes. December 5, 2019. https://www.forbes.com/sites/brucelee/2019/12/05/fda-listeria-yet-again-here-is-a-sushi-salad-and-spring-roll-recall/?sh=44a5e0e35549.
10. U.S. Food and Drug Administration (FDA). "Fuji Food Products, Inc. Voluntarily Recalls Ready-to-Eat Sushi, Salads and Spring Rolls Manufactured on the East Coast Due to Potential Listeria monocytogenes Contamination." Current as of November 27, 2019. https://www.fda.gov/safety/recalls-market-withdrawals-safety-alerts/fuji-food-products-inc-voluntarily-recalls-ready-eat-sushi-salads-and-spring-rolls-manufactured-east.
11. FDA. FSMA Final Rule on Requirements for Additional Traceability Records for Certain Foods. Current as of April 17, 2024. https://www.fda.gov/food/food-safety-modernization-act-fsma/fsma-final-rule-requirements-additional-traceability-records-certain-foods.
12. GS1. "GS1 Logistic Label Guidance: Scope of the Guidance." Release 1.3. July 2019. https://www.gs1.org/standards/gs1-logistic-label-guideline/1-3.
13. Global Dialogue on Seafood Traceability. 2024. https://thegdst.org/.

Michael McNicholas founded Culinary Collaborations LLC in 2019 with a mission to improve to-go sushi in North America. He leads a team of passionate specialists creating clean, all-natural, sustainable, and traceable ingredients for large sushi operators nationwide. A dedicated food safety advocate, he has led Culinary Collaborations to GFSI certification and MSC/ASC Chain Of Custody certification. A longtime advocate for electronic traceability, Mr. McNicholas serves as Chairman of the supervisory board of the Global Dialogue on Seafood Traceability (GDST). A proud member of the National Fisheries Institute (NFI), he is also the founding chairman of the NFI Sushi Council, launched in 2023.