TELL NOAA: WE WANT LEGALLY CAUGHT AND RESPONSIBLY SOURCED SEAFOOD

American voters agree that the government needs to do more to ensure that consumers are purchasing safe, honestly labeled, and responsibly sourced seafood. A recent Oceana poll found that 89% of voters say that imported seafood should be held to the same standards as U.S. caught seafood. Additionally, 81% of voters say they support policies that prevent seafood from being sold in the U.S. that was caught using human trafficking and slave labor. But the United States – a country that imports up to 85% of the seafood we consume – continues to bring in seafood tarnished by illegal, unreported, and unregulated fishing (IUU) and human rights abuses.

In 2019 alone, the U.S. imported $2.4 billion worth of seafood that were products of IUU fishing – an illicit activity that can include fishing without authorization, ignoring catch limits, operating in closed areas, targeting protected wildlife, fishing with prohibited gear while destroying important habitats, severely depleting fish populations, and threatening global security. IUU fishing is also often linked to forced labor and horrific human rights abuses at sea.

The National Marine Fisheries Service is considering expanding the Seafood Import Monitoring Program with additional species groups at risk of IUU fishing and seafood fraud. But this proposal does not go far enough and will continue to allow illegally caught seafood to enter the U.S. SIMP needs to be expanded to all seafood imports to ensure only safe, legally caught, responsibly sourced, and honestly labeled seafood is sold in the U.S.

Urge NOAA to act now to issue the final rule on the U.S. Seafood Import Monitoring Program and urge them to expand the program to all seafood. Doing so will protect our oceans and ensure that U.S. consumers are not unwittingly supporting illegal fishing and human rights violations when they sit down to a seafood dinner.

petition text

Greeting Ms. Cole,

I am writing to ask that the National Oceanic and Atmospheric Administration (NOAA) issue its final rule on the Seafood Import Monitoring Program (SIMP). I urge NOAA to expand SIMP to all seafood to ensure the United States is only importing seafood that is safe, legally caught, responsibly sourced, and honestly labeled. With the U.S. importing up to 85% of the seafood we consume, it is important that the federal government has robust import controls to ensure that the seafood products reaching our plates are not sourced from illegal, unreported, and unregulated (IUU) fishing or are products of forced labor. In 2019 alone, the U.S. imported $2.4 billion worth of seafood that were products of IUU fishing. Globally, IUU fishing is estimated to cause economic losses of $25 billion to $50 billion per year. IUU fishing is a threat to the health of the oceans and fisheries, the livelihoods of honest fishers, national security, and global food security.

NOAA’s proposed rule to expand and improve SIMP has the potential to improve catch documentation and traceability of our seafood through global supply chains and protect American consumers and fishers, but only if it is expanded further to include all seafood imports. NOAA must commit to a transparent timeline to expand SIMP to all seafood imports. Currently, SIMP applies only to 13 types of seafood deemed at risk of IUU fishing and seafood fraud, representing less than half of U.S. imports by value and volume. The proposed additional species and species groups would include additional tuna and snapper species, cuttlefish, squid, octopuses, eels, queen conch, and Caribbean spiny lobster, with the possibility of including all conch and spiny lobster species. However, this is less than a 4%-8% increase in the amount of seafood imports into the U.S. by volume, meaning more than 50% of seafood imports would still not be covered by these safeguards.

U.S. fishers are already required to report key information about their catch, and we should hold imported seafood to the same standard. On top of that, requiring catch documentation and traceability for all seafood imports is not a new idea. In fact, the European Union has required this information for all seafood imports for more than a decade. Not only should the federal government require imports to be held to the similar standard as U.S. caught seafood, but it should also work with international governments to standardize catch documentation requirements to provide more consistency to the global seafood industry.

IUU fishing is also linked to transnational crimes like human trafficking and forced labor. Lack of oversight and enforcement in the global seafood sector has fostered conditions in which crew members remain on vessels for prolonged periods of time and are subjected to debt bondage, inhumane working conditions, and severe abuse. Forced labor is also found in seafood processing facilities in a number of countries. While this rule recognizes that forced labor and human rights abuses are problematic in many seafood supply chains, it fails to use this information to expand SIMP to species at high risk of forced labor. Because IUU fishing and forced labor are inextricably linked, they must be tackled together, using a whole-of-government approach. NOAA should build mechanisms into SIMP to address forced labor and other human rights abuses.

The U.S.’s high demand for seafood, combined with SIMP’s limitations, allow seafood sourced from illegal activity to flood the U.S. market, driving economic and ecological loss around the world. The lack of visibility and traceability allows illegally sourced or mislabeled products to enter the legal supply chain. Requiring transparency and traceability at every step of the seafood supply chain provides NOAA and Customs with important tools toward combating these problems. This is essential to monitor fishing, identify suspicious activities, eliminate illegal fishing, and restore healthy fisheries.

As a seafood consumer, I want to be assured that my seafood is not sourced illegally or by utilizing forced labor. Requiring all seafood imports be subject to robust catch documentation and traceability from boat to plate would provide me with more confidence in the seafood I eat. I urge NOAA to implement its final rule and expand the Seafood Import Monitoring Program to cover all seafood.

Sincerely,

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