When you eat fish, are you absolutely sure you know what you’re eating? Perhaps surprisingly, as we discussed on CRIS Bits previously, lack of transparency in the seafood supply chain means that illegally caught or mislabeled seafood can enter the U.S. supply chain unnoticed and eventually end up on our dinner plates.
The good news is that you’ll soon be able to have more confidence in what you’re eating, as seafood traceability is becoming an established part of the U.S. seafood supply chain. In December, the final version of the Seafood Import Monitoring Program was released by the National Ocean Council (NOC) Committee on Illegal, Unreported, and Unregulated (IUU) Fishing and Seafood Fraud. This rule is the first step toward preventing IUU fishing and fraudulent seafood from entering U.S. commerce.
IUU fishing often results in seafood that is obtained unsustainably or illegally. These kinds of methods by some fishers make it difficult for honest fishers to make a living. Mislabeling of seafood also cheats consumers out of high quality products and hides health hazards such as contaminants or allergens.
Why was the rule written?
This NOC Committee was developed from a Presidential Task Force to address seafood fraud and IUU fishing in the U.S. supply chains. Using recommendations from the Task Force, as well as comments solicited from the public, the National Marine Fisheries Service (NMFS) released a proposed version of the rule in February 2016. This rule enables the National Oceanic and Atmospheric Administration (NOAA) to implement existing restrictions on illegally caught fish entering the U.S.
How will it work?
The importer is required to provide information on the producer (if aquaculture) or harvester (if wild caught), the seafood being imported, when and where the fish was caught or farmed, and the importer’s International Fisheries Trade Permit (IFTP) number. An IFTP is already required for some fisheries products subject to other trade or management programs. Importers are also required to retain this data and other documents that they already collect for at least two years. This is decreased from the five years of record keeping in the proposed version of the rule. Compliance with the final rule will not be required until January 1, 2018, allowing impacted suppliers time to adjust.
Seafood shipments are frequently co-mingled, meaning that products from multiple harvests are included in one shipment. To address this problem, documentation is required for every harvest that contributed to a shipment, without the importer needing to separate the fish from each harvest. This is different than an Aggregated Harvest Report, which is used to reduce the burden for small-scale fisheries. In this type of report, harvests from multiple small-scale vessels may be combined into one single report.
The proposed version of the rule stated that documentation would follow 13 “at-risk” (now referred to as “priority”) species and species groups until they were imported into the U.S., with the intention to include all seafood in the future. Despite public comments on the proposed rule calling for immediate coverage of all species or a timeline to expand to all species, the original plan was maintained in the final version. The reasoning behind this is to create a smooth transition and enable NMFS to determine how well the rule is working before expanding it to any other species.
One notable change between the proposed and final versions is the treatment of shrimp and abalone products. Though they remain on the list of priority seafood types, the traceability requirements for these products have been postponed until the requirements for U.S. produced shrimp and abalone are also enhanced.
How much will it cost?
The NOC Committee received comments voicing concern over the potential for increased burden on the seafood industry. The Committee explained that information collected to satisfy already existing requirements could also be used to satisfy the requirements of this rule to prevent paperwork redundancy.
The estimated cost associated with this regulation is $7.9 million, as determined by the NOC Committee. The National Fisheries Institute (a trade group that represents the seafood industry) presented its own estimation method, which predicts that costs could go up to $20.3 million. Though this seems like a lot of money, even the higher of the two estimates would be less than half a percent of the $9 billion value generated by imports of the priority seafood types.
NMFS is also developing a Commerce Trusted Trader Program by which qualified importers experience a simplified import process. Anyone who holds an IFTP may be eligible, though other criteria for qualification are still being determined.
What does this mean for consumers?
Because traceability stops at the point of import, there is still a chance for mislabeling to occur after seafood enters the U.S. There are many steps that may occur after import, such as processing, distribution, retail, or preparation at a restaurant, where seafood can be misidentified intentionally or accidentally. The current focus on only 13 priority seafood varieties also means that non-priority species are still susceptible to IUU or fraud. Now, however, some of the most commonly abused types of seafood are more likely to come from trustworthy sources.
After a report by the organization Oceana showed that a fifth of seafood is mislabeled globally, seafood traceability is clearly an important matter to address. In implementing this rule, the U.S. joins the European Union in working towards improved seafood traceability worldwide. Though it is not yet full-chain traceability for all seafood, it is a significant first step towards trusting that the fish on your plate is labeled correctly and caught legally.