Tell NOAA: The U.S. needs to expand the definition of IUU fishing

The National Oceanic and Atmospheric Administration (NOAA) has proposed a rule to expand the definition of IUU fishing to recognize the link between IUU fishing and forced labor. This is a huge opportunity for the United States, as the world’s largest seafood importing country, to take a stand. It is currently illegal to import products produced using forced labor. By expanding the definition, it ensures that the U.S. can take strong action against other countries engaged in IUU fishing – and ignoring human rights abuses in their fleets – which the current definition limits the agency’s abilities to do. That's why we need your help.

Urge NOAA to create a strong rule that addresses IUU fishing and put an end to forced labor in the seafood sector.

Petition Text

Dear Mr. Rogers,

I am writing to comment on the National Oceanic and Atmospheric Administration’s (NOAA) proposed rule to expand the definition of illegal, unreported, and unregulated (IUU) fishing and recognize the link between IUU fishing and forced labor. An expanded definition is important to ensure that the U.S. can take strong action against other countries engaged in IUU fishing. While the proposed rule does expand the definition of IUU fishing, it does not go far enough.

IUU fishing is a rampant problem across the world’s oceans because it is a low-risk, high-reward activity, especially on the high seas where a fragmented legal framework and lack of effective enforcement allow it to thrive. IUU fishing undermines honest fishers and responsible fisheries management. As a seafood consumer, I want to be assured that my seafood is safe, legally caught, responsibly sourced, and honestly labeled, without illegal activities and the use of forced labor. NOAA’s current IUU definition limits the agency’s ability to identify other nations for IUU fishing and subsequent trade restrictions. As unsustainable fishing practices make fish scarcer and vessels need to travel further, operators may try to maintain their profit margins through reducing their labor costs via forced labor. Workers on fishing vessels face threats of physical and sexual violence, far away from any authority to which they could report labor violations.

The definition of IUU fishing that NOAA uses for identification and certification under the High Seas Driftnet Fishing Moratorium Protection Act needs to be expanded and this proposed rule is a start by adding forced labor and management failures by the flag states. I strongly support the inclusion of forced labor and other human rights violations in the proposed definition to address the interconnected issues of IUU fishing and forced labor throughout the seafood supply chain. But identifying vessels participating in forced labor should not be limited to only “waters beyond any national jurisdiction,” as forced labor is widespread and often occurs in the EEZs of a country. NOAA should consider identifying a country for listing regardless of where the forced labor is occurring. NOAA should also consult with key agencies, especially the Bureau of International Affairs in the Department of Labor, the Trafficking in Persons Office at the Department of State, and Customs and Border Protection to better identify the use of forced labor in fisheries.

In addition to what is outlined in the proposed rule, I urge you to include all fishing activities that violate conservation and management measures required under international fishery management agreements, even if the United States is not a party to the agreement. If the ruling is limited by this requirement, then IUU activities in nearly 50% of the world’s Regional Fisheries Management Organizations (RFMOs) would be ignored. This would include integral RFMOs like the Indian Ocean Tuna Commission (IOTC) and the Commission for the Conservation of Southern Bluefin Tuna (CCSBT). The United States should continue to encourage RFMOs to publicly disclose information on reported violations. The new definition should be interpreted broadly to apply to all IUU fishing, regardless of where it occurs to allow the U.S. to address the most egregious actions of vessels from other countries.

Overall, I welcome NOAA’s proposed rule as the U.S. cannot remain complicit in the trade of seafood that destroys the oceans and victimizes vulnerable workers.


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