I am writing to support the Food and Drug Administration’s (FDA) proposed rule for traceability for certain foods, including seafood. As a seafood consumer, I want to know that the seafood I purchase is safe, legally caught and honestly labeled. Boat to plate traceability would provide me with more confidence in the seafood I eat and bring integrity to the full supply chain. I also urge the FDA to expand the rule to cover all seafood, link to the existing requirements under the Seafood Import Monitoring Program (SIMP) and pair the program with expanded labeling requirements so consumers can know more about the seafood they purchase like what fish it is, where it was caught and how it was caught.
Seafood fraud and illegal fishing are significant threats to the health of our oceans. With millions of people depending on seafood for nutritional and economic benefits, responsibly managed fisheries are critical. Seafood fraud undermines honest fishermen and businesses that play by the rules, rips off consumers and can even impact our health. Seafood fraud can also provide illegally caught fish with a new legal identity, hampering efforts to stop illegal fishing.
Illegal, unreported and unregulated (IUU) fishing is a low-risk, high-reward activity, especially on the high seas where a fragmented legal framework and lack of effective enforcement allows it to thrive. It is off the books, ignores domestic and international fisheries laws and amounts to estimated losses of $25 billion to $50 billion per year. IUU fishing has even been linked to transnational crimes like human trafficking and forced labor. Transparency at sea and traceability of seafood are essential to monitor fishing, identify suspicious activities, eliminate illegal fishing and restore healthy fisheries.
This proposed rule can help stop seafood fraud, keep illegally caught fish out of the U.S. market and protect consumers from food safety concerns. While this program applies to most seafood, it excludes scallops and catfish. To simplify compliance and traceability, this rule should be expanded to cover all seafood.
The FDA traceability rule should not be developed in a vacuum. The FDA should align key data elements (KDE) and critical tracking events (CTE) (where appropriate) with SIMP. The FDA should also look to international best practices to align and harmonize these KDEs and CTEs across programs. The traceability program should require electronic recordkeeping and information to allow these separate but related systems to share data and information across the federal government.
Finally, as a seafood consumer, I have a right to know more about the seafood I eat. Since the information will already be required to travel throughout the supply chain, the FDA should require that more information is provided directly to consumers, including what specific fish it is, where it was caught, how it was caught, and whether it was farmed or wild-caught.
Overall, I welcome the FDA’s proposed rule as seafood traceability is needed to ensure that all seafood sold in the US is safe, legally caught and honestly labeled.