As it approaches a decade in force, the overall impact of Seafood Import Monitoring Program (SIMP) on defeating illegal, unreported, and unregulated (IUU) fishing – and how its new update to cover all species will help – remains unclear.
It has been eight years since NOAA Fisheries first created SIMP under the administration of then-U.S. President Barack Obama, and the agency has now decided it needs an update.
NOAA’s SIMP program was first introduced as a means of imposing stricter monitoring standards on seafood imports coming into the U.S. and initially targeted at-risk seafood species. As it stands, the program requires detailed information on 13 species or species groups, covering roughly 1,100 individual species, according to the agency.
The stated goal of the program – which originated from work done by the Obama- authorized Presidential Task Force on Combating IUU Fishing and Seafood Fraud – was to block the import of select seafood products that had either been mislabeled or harvested via IUU fishing. The regulatory standards under SIMP were intended to be similar to the standards domestic U.S. fishermen face to create an even playing field between imports and domestic production.
Since being introduced, the program has remained relatively stagnant. In March 2022, NOAA Fisheries told U.S. Congress it was evaluating the program to determine if the species or species groups – abalone, Atlantic cod, Pacific cod, Atlantic blue crab, red king crab, dolphinfish, grouper, sea cucumber, northern red snapper, shark, shrimp, swordfish, and seven species of tuna – it covers were still at risk.
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That first expansion was met with extensive public feedback that ultimately led NOAA Fisheries to withdraw the proposal in November 2023 and instead start a broad review of SIMP.
Since that failure, NOAA said it gathered feedback from more than 7,000 stakeholders to redo and revamp SIMP. In November 2024, it unveiled an action plan containing a number of goals, including enabling pre-entry screening, developing a pilot government-to-government import data program, and expanding SIMP traceability requirements to all U.S. imports.
“Our goals are to strengthen the U.S. domestic seafood industry by promoting fair trade practices in the global seafood supply chain while building capacity to maintain and grow the program,” then-NOAA Administrator Richard Spinrad said.
Spinrad noted that the new updates are intended to deter and prevent IUU fish and seafood products from entering the U.S. supply chain – but whether it will manage to do so is still unclear.
Goldfish Co-Founder and CEO Celeste Leroux, who worked with NOAA and the White
“It reads to me as not that cohesive, not to say that these actions are unhelpful, but the fact that the sort of ‘next steps’ at the bottom of the report is just three sentences tells me that this wasn’t much of an action plan as an action statement,” she told SeafoodSource. “For example, they list these goals here in order, but I would say goal four, the last goal on the list, is the one about making the program work as intended. Are we going to be checking information at scale? Are we going to be making sure that it does what it was designed to do?”
Goal four in the action plan, “Improve NOAA Fisheries’ implementation of SIMP and build our capacity to maintain and grow the program,” is a key factor in whether SIMP works in the first place, Leroux said.
“To me, you would want to demonstrate capacity in that area first and use it to justify the types of changes they are recommending,” Leroux said. “I don’t want to say that these goals are unhelpful – they may be – but they don’t seem to be ordered in a logical way that makes me believe NOAA is going to do these things.”
The seafood industry in the U.S. has been critical of SIMP’s implementation in the past. The National Fisheries Institute (NFI) frequently criticized it as an expensive regulatory burden for seafood companies, with little in the way of progress on stopping IUU fishing. NFI has frequently pointed out that NOAA itself acknowledged in a 2022 report that SIMP didn’t stop illegal products from entering the U.S. market.
“Attempts to expand SIMP to other species, under the guise of a more-comprehensive program, undercut an actual focus on risk,” NFI Chief Strategy Officer Gavin Gibbons said soon after NOAA unveiled its first expansion proposal. “NFI is committed to sustainable seafood trade and will participate in the comment process as this proposal moves forward.”
Leroux said that before NOAA goes all-in on expanding SIMP, it should showcase how the existing program has helped.
“I remember from the earliest days being asked ‘well, what stories can you tell me about stopping illegal seafood imports based on the program’ and kind of tap dancing around not having those stories,” Leroux said.
More recently, SIMP has been successfully used to trigger larger investigations, often in other regulatory bodies. A NOAA report found SIMP applied to USD 6.4 billion (EUR 6.1 billion) worth of seafood imports from FY 2022 to FY 2023, and reported high rates of failure of SIMP audits.
However, there are still questions about how NOAA is utilizing the data it acquires via SIMP, Leroux said.
“It doesn’t describe all of the data that industry is meticulously collecting and submitting to the government being used to actually catch bad actors in real time – which would be the intended purpose of submitting all of this data as part of customs, rather than just having a paper-based auditing program,” Leroux said.
NOAA’s action plan to update SIMP will now need to be undertaken by new administrators appointed by the administration of current U.S. President Donald Trump – but Leroux said it’s likely little will change.
“I saw the original SIMP regulation come out in the very final months of the Obama administration, and it was immediately litigated and defended, I think wholeheartedly, by the incoming Trump administration,” Leroux said. “They could see the value of all this data in making granular trade actions, and I have no reason to believe that their view will have significantly changed between then and now.”
Not everyone is critical of NOAA’s proposal to revamp SIMP. Sally Yozell, the director of the environmental security program at the Stimson Center, a Washington D.C.-based think tank, has worked with NOAA on the new action plan and said the new pilot system will help go after IUU perpetrators like it was originally intended – while making it easier for the seafood industry to comply.
“It’s going to really help them be able to focus and go after the perpetrators, the bad guys, and try to put less burden on those who are actually following the rules,” she told SeafoodSource. “I think it will be helpful for industry up and down the seafood supply chain.”
The burden on the supply chain is another thing Leroux said she would like to see quantified by NOAA. She said on paper the rule appears to be a minimal burden on importers.
“But, I think we all collectively know that’s not true, and I personally believe that if that accounting were more accurate, then industry would have more grounds to get what they want out of the program,” Leroux said.
Leroux also said she would like to see the process of updating it refined to have more inter-agency review across multiple government departments due to its financial impacts.
“I hope that there will be successful advocacy to get this rule to be reviewed at a higher level, so that it doesn’t face the same type of criticism that NOAA had last time they tried to expand the program without going through interagency review,” she said.
Leroux added that while she is critical of SIMP as it exists, she is pulling for NOAA to reform it in a way that accomplishes its goal.
“Everybody hates the fact that SIMP isn’t achieving its initial goal. I would really like to see a concerted effort to improve the integrity of the program,” she said. “They’re doing the hard part already. They’re already providing all of the data. That data is just getting filed away in an electronic folder and not looked at. And that’s what has to change, and it could change any time NOAA decides to do better, and I would love to see something drive them to do that.”
