Guidance for Processing Sushi in Retail Operations1

W. Steve Otwell, Keith R. Schneider, Victor Garrido, and Ray Mobley 2

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This recommended guidance is for sushi and related products (raw or cooked) either in the form of individual slices or combined in rolls made with acidified rice, seafood and vegetables, or similar rolls with vegetables alone, prepared in the retail establishment by combining the necessary ingredients, and packaged for display in refrigerated cases for public sale.


This guidance has been prepared in response to a notable increase in on-site retail processing (manufacturing) of foods traditionally processed in controlled plant environments. Such retail processing can involve, but is not limited to acidifying, smoking, drying, fermenting, curing, reduced oxygen packaging, and other operations that are traditionally done at a food manufacturing plant level. The key distinction for processing as related to this guidance is that the processing occurs on-site in the retail setting. This guidance is intended for retailers and regulatory personnel to help understand the controls to implement in a retail operation in order to process and sell safe food products. It can be referenced in developing considerations for variances for any exception or special provision to state or local food safety or sanitary codes. It addresses those special variances required by the FDA Food Code which may require HACCP plans for those jurisdictions that have adopted those portions of the FDA Food Code. In addition, it also applies to regulatory oversight and/or approval for regulatory overlap that may occur between the states processing requirements and the state or local retail food safety and sanitary codes. This guidance assumes retail compliance with applicable retail food codes, prerequisite standard sanitary operations procedures, and labeling requirements specified in 21 CFR 101. This guidance is not intended to replace or duplicate existing regulations, but it does offer a reference for more uniform practices.


This guidance is not a binding set of requirements. The information provided in the guidance are recommendations based on current science, commercial experience and practical considerations as assembled by the assigned committees and reviewed by a variety of selected experts and the Project Steering Committee. Use of these recommendations would likely result in retail processing practices that are acceptable to the pertinent authorities for food safety. Retail compliance and enforcement will remain within the interpretations and decisions of the pertinent state and local regulatory authorities.


1. This document is FSHN0509, one of a series of the Food Science and Human Nutrition Department, UF/IFAS Extension. Original publication date February 2005. Reviewed February 2019. Visit the EDIS website at for the currently supported version of this publication.
2. W. Steve Otwell, professor, Keith R. Schneider, professor, and Victor Garrido, former research coordinator, Food Science and Human Nutrition Department; UF/IFAS Extension, Gainesville, FL 32611; and Ray Mobley, PhD, Florida A&M University.