U.S. suppliers are scrambling to figure out how the nuances of an expanded U.S. ban on Russian seafood might impact their trading in Alaska pollock.
On 22 December 2023, U.S. President Joe Biden signed an executive order expanding the U.S. ban on Russian seafood to include imports of Russia-originated seafood processed in third countries, including China. The expanded ban entered into immediate effect, with import contracts signed before that permitted to be carried out through 21 February 2024, according to the department.
The ban explicitly targets salmon, cod, pollock, and crab harvested in Russian waters or by Russian vessels, and processed in another country, preventing it from entering the U.S. When it comes to pollock, the vast majority of the world’s supply is fished in Russia and the U.S. state of Alaska. Pollock is generally sold in two forms: once-frozen blocks of fillets or surimi caught by U.S. trawlers and processed in the United States, and Russian product that is frozen at sea then shipped to China where it is thawed, reprocessed into various product forms, then refrozen and distributed in the United States and other countries – mainly in Europe.
Digging into the individual harmonized tariff schedule (HTS) category codes restricted under the executive order, most categories of salmon, cod, and crab are included in guidance issued by the U.S. Treasury Department Office of Foreign Assets Control. But only three pollock HTS codes are included in the ban – 0304.53.0025 (pollock meat fresh), 1604.19.1000 (pollock canned not in oil), 1604.19.2500 (pollock canned not in oil) – which together accounted for 15,486 metric tons of imports valued at USD 45.4 million (EUR 41.4 million) in U.S. imports in 2022.
Left off the list were a handful of other pollock HTS categories, including:
- 0304.75.1000 (frozen blocks larger than 4.5 kilograms), of which the U.S. imported 10,222 MT worth USD 35.5 million (EUR 32.4 million) in 2022
- 0304.79.1010 (frozen pollock blocks larger than 4.5 kilograms) 3,834 MT imported, worth USD 10.8 million (EUR 9.9 million)
- 0304.73.5000 (frozen fillets), 176 MT imported, worth USD 1 million (EUR 911,000)
- 0302.59.5010 (fresh pollock), 592 MT imported, worth USD 1.6 million (EUR 1.5 million)
- 0303.67.0000 (frozen Alaska pollock), 573 MT imported, worth USD 1.6 million (EUR 1.5 million)
- 0304.44.0025 (fresh pollock fillets), 55 MT imported, worth USD 360,000 (EUR 328,000)
- 0304.95.1030 (frozen pollock meat weighing more than 6.8 kilograms), 219 MT imported, worth USD 823,000 (EUR 750,000)
- 0305.69.1022 (salted whole/dressed pollock), 825 MT imported, worth USD 4.7 million (EUR 4.3 million)
- 0305.69.1042 (salted pollock fillet) 2,093 MT imported, worth USD 12.3 million (EUR 11.2 million)
Genuine Alaska Pollock Producers CEO Craig Morris told SeafoodSource in an email he believes the omissions were accidental.
“We are aware of and are working on the issue,” he told SeafoodSource in an email. “We believe it to be an oversight that will be corrected.”
In the interim, Morris said the OFAC guidance listing the HTS codes “does not have any legal status” and that a subsequent rulemaking will formally define the relevant HTS codes subject to the executive order.
According to GAPP, a Seattle, Washington, U.S.A.-based organization representing the Bering Sea pollock fleet, twice-frozen and reprocessed pollock comprise around 40 percent of the pollock products in the world market. In terms of volume, the United States imported 33,400 metric tons (MT) of fillets and fillet blocks from China in 2022, up from 27,600 MT of 2021. The European Union imported 120,750 MT in 2022. The total U.S. production in 2023 through October stood at 156,068 MT.
Morris said Alaska-caught pollock stands to see gains in demand because the ban will reduce volumes of lower-quality, lower-priced products currently flooding global markets.
“What’s happened with this unbelievable growth in their exports to China, and then China’s exports of that product around the world, is that consumers are just getting more and more of this low-quality product,” Morris said.
There’s a danger in that, as the twice-frozen pollock could turn off first-time consumers from Alaska pollock if they don’t realize there’s a difference in quality and taste between once- and twice-frozen product.
“That twice-frozen product, by carrying the same name, really confuses consumers, because if you have a bad experience with a pollock product, you don’t think that it was because it was twice-frozen,” Morris said. “You just think pollock is inconsistent.”
Several years ago, Alaska and Russia worked as allies in the expansion of once-frozen product into the global market, according to Morris.
“From the outset we – I’m not going to say we celebrated – but we were certainly not opposed to the modernization of the Russian fleet because United States and Russia are basically the only two countries that catch any Alaska pollock or pollock to any scale,” Morris said. “So when they were modernizing their fleet, moving toward once-frozen product, we actually were very supportive of that because that would mean that the global supply of product would be of higher quality.”
That all changed with the Russian invasion of Ukraine in February 2022.
“The Russian once-frozen product we really saw as constructive for the global market, but with the war now in Ukraine we obviously have to temper that because we don’t want U.S. dollars, or frankly global dollars, going basically to fund this war,” Morris said.
In the meantime, GAPP retained third-party analysts to conduct marketing studies that measure the relationship between purchasing habits and country of origin among consumers in the United States and in Europe. In a study focused on the domestic market, millennials emerged as the predominant demographic among consumers, and sustainability was the key factor for that demographic. Country of origin ranked strongly as well, with consumers showing an overall preference for seafood sourced from Alaska or Canada. The study found participants would feel “confused, misled, and annoyed” to find that their Alaska pollock actually came from Russia via reprocessing and importation to the United States from China.
Another study, released in October 2023, surveyed 1,600 consumers in the United Kingdom, France, Germany, and Spain, and found that the majority of whitefish consumers care about country of origin and that they tend to avoid fish sourced from Russia or China. The study found that European buyers, mostly in the U.K. and Spain, inherently believe that when they purchase pollock products, the pollock has been caught in Alaska. Survey participants also reported that they would feel misled to find out that the pollock they’re eating came ultimately from Russia.
In France, 80 percent of those interviewed said country of origin drives their purchases of pollock products, and 70 percent said they actively seek out country-of-origin information in their purchases. Fifty percent of consumers in France, Spain, and Germany actively avoid purchasing fish sourced from China with around 40 percent avoiding fish sourced from Russia.
Around 30 percent of those surveyed ranked their opposition to the invasion of Ukraine as their top reason for avoiding fish from Russia, but distrust in quality standards pertaining to chemicals and other quality controls were also a factor. Pollution concerns over food transportation distances, meanwhile, weighed in among top concerns to avoid fish sourced from China.
Overall, European consumers believe that Alaska pollock comes from Alaska, like its name implies, and 82 percent of the 1,600 survey participants said they preferred to source their pollock from Alaska.
The popularity of Alaska pollock in global markets will likely continue to grow as the United States and other countries band together to ascertain that the fish have been caught and processed by U.S. vessels in the Bering Sea, according to Morris.
“It’s an opportunity that’s been handed to us, and we have to do our best to use this opportunity to convey the superior attributes of once-frozen Alaska pollock,” Morris said.
Additional reporting by Charlie Ess/National Fisherman
Photo courtesy of Michael Nelson/NationalFisherman
