A new policy brief has found the majority of seafood coming into the U.S. continues to be outside of the oversight of the Seafood Import Monitoring Program (SIMP) and basic catch and traceability requirements.
The policy brief, commissioned by the U.S. Illegal, Unreported, and Unregulated (IUU) Fishing & Labor Rights Coalition and based on a technical report by John Simeone of Simeone Consulting, found that 60 percent of the value of imported seafood in 2024 entered U.S. markets without being subject to SIMP reporting requirements. The coalition, comprised of more than 20 civil society organizations including Oceana, Corporate Accountability Lab, Fish Wise, WWF, Global Labor Justice, and more aims to address IUU fishing and its intersection with labor rights abuses by leveraging the U.S. government to promote policy changes combating the practices.
SIMP, implemented by NOAA Fisheries nine years ago, was intended to impose stricter monitoring standards on seafood imports coming into the U.S., and requires detailed information on 13 species or species groups, covering roughly 1,100 individual species.
While NOAA designed SIMP in 2016 with the intention of expanding beyond the initial 13 species groups, no new species have been added in the program’s 10-year history. NOAA has proposed major SIMP expansion in the past, only to withdraw that proposal and restart the process after gathering feedback from stakeholders.
As a result of the lack of expansion, gaps in coverage allow bad actors to evade oversight by mislabeling seafood as visually similar, non-covered species, the report said.
According to the policy brief imports of non-SIMP-covered “close substitute” species far outweigh imports of the SIMP-regulated species they commonly replace in the market. The rate of import of substitute species is more than eight times higher than the imports of Atlantic blue crab. It also found similar gaps for other species, with substitutes for red king crab, northern red snapper, and others all outstripping imports of the SIMP-covered species.
While NOAA’s 2024 SIMP Action Plan outlined needed reforms – such as stronger data verification, prior notification requirements and labor data collection, these changes have yet to be fully implemented, Oceana said.
The IUU Fishing and Labor Rights Coalition said expanding SIMP to all imported species and fully implementing NOAA’s 2024 Action Plan would transform the program into a more effective tool to combat illegal fishing, seafood fraud, and forced labor, Oceana found. "Without these reforms, the U.S. risks remaining a major destination for illicit seafood products,” Oceana said.
“For too long, the U.S. has been a dumping ground for illicit seafood that undermines U.S. fishers and dupes consumers,” Oceana Vice President Beth Lowel said. “Strengthening and expanding the Seafood Import Monitoring Program to cover all seafood imports – as NOAA always intended – is essential to closing loopholes that allow illegal fishing and forced labor to persist.”
FIshWise Governance Reform Program Director Lindsay Ceron said the piecemeal approach of SIMP and the gaps in catch documentation and supply chain traceability in U.S. regulations has created a fragmented approach to preventing IUU that has only served as a ‘back door’ for illegal products.
“The time is now for the U.S. to show true leadership,” Ceron said. “By expanding SIMP into a comprehensive import control program, we can close these exploitable loopholes, level the playing field for honest actors, and finally secure our supply chains against IUU fishing.”
The coalition called for a strengthening of SIMP and for NOAA to implement its action plan to close those gaps.
The National Fisheries Institute (NFI), in contrast, has long opposed SIMP expansion as a means of tackling IUU. NFI Chief Strategy Officer Gavin Gibbons said environmental NGOs would be better served at abandoning SIMP for better programs, and said they should let go of SIMP instead of “holding it out as some sort of savior that would work so well if only x, y, or z were different.”
“The fact is SIMP is and always has been a failed program. NFI opposes any IUU fishing and supports responsible efforts to address the issue, such as the FISH (Fighting Illegal Seafood Harvests) Act,” NFI Chief Strategy Officer Gavin Gibbons said.
NFI has repeatedly pointed out that as far back as 2021, NOAA itself wrote that SIMP “does not prevent or stop IUU fish and fish products from entering U.S. commerce,” per Gibbons. "It is a flawed paperwork exercise that doesn’t do what policy makers hoped it would.”
NOAA found through examining its data that the majority of SIMP audits do not identify noncompliance, and “only a small number [of non-conformances] rise to the level that they warrant enforcement action,” the agency said.
