The objective of this study was to investigate the performance of a photochromic time–temperature indicator (TTI) under dynamic temperature conditions simulating real fresh fish distribution chain scenarios. The work aimed at testing the possibility of extending the application of the TTI kinetic model, developed for specific temperature range of isothermal conditions, at low temperatures. The results showed that the TTI presented reproducible responses after being charged and during the discolouration process under different conditions, which revealed the reliability of the indicator. The TTI reflected well the temperature conditions of the studied scenarios, which indicates its potential application to continuously monitor the temperature history of the fresh fish supply chain. The kinetic model gave good fits in non-abused scenarios at temperatures below 2 °C, presenting the potential for application of the model in determining the right charging level to suit a product’s shelf life at low temperatures.