NOAA Fisheries has unveiled an action plan for its Seafood Import Monitoring Program (SIMP) that the agency said has a renewed focus on combating illegal, unreported, and unregulated (IUU) fishing, enhancing seafood traceability, and expanding traceability requirements to all U.S. seafood imports.
NOAA first created SIMP in 2016 under the administration of U.S. President Barack Obama as a means of imposing stricter monitoring of seafood imports, requiring at-risk seafood species to be tracked to its source and properly labeled. NOAA announced a major proposal on 28 December 2022 that would have doubled the species the program targets – a push that ultimately failed after NOAA decided to withdraw the additional rules in November 2023.
NOAA said since that time, it has gathered feedback from more than 7,000 stakeholders to create the recently unveiled action plan, which it said will help make the program more effective while also supporting the seafood industry by minimizing disruptions to trade.
“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,” NOAA Administrator and Undersecretary of Commerce for Oceans and Atmosphere Richard Spinrad said in a release. “Once implemented, the changes to our Seafood Import Monitoring Program that we are announcing will fundamentally improve our ability to prevent and deter IUU fish and fish products from entering our market and will contribute to U.S. government efforts to address labor abuses in the seafood supply chain.”
SIMP has been criticized in the past by members of the seafood industry and even people who worked on it for not living up to its objective of adequately screening seafood or preventing IUU-sourced seafood from entering the country. Celeste Leroux, who worked with NOAA and the White House to implement SIMP and is the co-founder and CEO of traceability firm Goldfish, told SeafoodSource in October 2023 that the program wasn’t functioning as intended.
“This was a program I was involved with setting up, and you would be hard-pressed to find someone more critical of it,” she said at the time.
NOAA said the new action plan will address some of those criticisms by expanding SIMP to all species and enabling pre-entry screening of SIMP imports. NOAA is also working on a pilot program to create a voluntary government-to-government import data program and is planning to modify the current key data elements (KDEs) required under SIMP to harmonize its requirement with other domestic and international traceability schemes.
NOAA said it is also improving SIMP compliance materials and is planning to introduce a new rule to clarify SIMP’s permits and reporting procedures to make it more user-friendly.
Part of that push will include a modernized national permit system and more digitization of the program.
Sally Yozell, the director of the environmental security program at the Stimson Center, a Washington D.C.-based think tank, told SeafoodSource that based on NOAA’s announcement, it has taken the criticisms to heart.
“We were all pleased when they withdrew the rule because the rule just didn’t go far enough, and it didn’t address many of the issues that we had been talking to NOAA Fisheries about,” Yozell said. “So, I give them credit for withdrawing that rule and taking on this public engagement, really trying to dig deep to try to figure out what needed to be done to make the program more efficient and more effective. Because that was really the problem; it was a burden, and it was not doing much to prevent IUU fish and fraudulent fish from entering the U.S.”
Yozell said the new system differs from how the old SIMP worked in multiple key ways, including a shift in focus away from a species-specific viewpoint in what she called an “old, outdated system.”
“Now, they’re going to try to really do more risk targeting,” Yozell said.
The pilot data system NOAA announced in its new action plan is part of the method it plans to use to enhance risk targeting so that it can place more scrutiny on risky seafood while easing the burden on members of the seafood industry that follow the rules. Yozell said the Stimson Center has pushed for NOAA to utilize tools like AI to help enhance its ability to analyze data and focus in on the flag states, vessels, countries, or products that are at a higher risk of being made via IUU or forced labor.
“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,” Yozell said. “I think it will be helpful for industry up and down the seafood supply chain.”
Yozell said the addition of new KDEs will also help prevent seafood being produced with the use of forced labor from making its way into the U.S. – a key goal for the industry.
“U.S. consumers do not want to be eating seafood that is caught through forced labor or human rights violations,” she said. “That’s the big issue that has caught a lot of attention.”
Another key element of the new SIMP action plan is to require harvest data alongside product, which will help increase traceability – and enhance NOAA’s ability to prevent imports from banned countries like Russia from entering the U.S.
“What has been occurring is seafood say for example from Russia goes to China for processing, and can be intermingled with U.S. product that also gone to China for processing,” Yozell said. “That is then comingled and re-imported back into the U.S.”
Executive Assistant Commissioner of U.S. Customs and Border Protection’s Office of Trade AnnMarie R. Highsmith said that improved data sharing between NOAA and U.S. Customs and Border Protection will also help screen and prevent products made with forced labor from entering the U.S.
“With improved data sharing, transparency, and traceability, SIMP will elevate U.S. Customs and Border Protection’s ability to protect the U.S. economy, global food security, and the sustainability of our shared ocean resources to a new level,” Highsmith said. “Having more information about seafood shipments earlier in the process will also strengthen our efforts to combat forced labor in the global seafood supply chain.”
Yet another goal of the action plan is to strengthen the fairness of seafood supply chains – including leveling the playing field for U.S.-based fishermen.
NOAA’s proposal will now be before public comment before a final rule follows. Then, much of the work relies on the future administration of Donald Trump following through with implementation.
Yozell said that during Trump’s previous administration, progress continued forward on the issue, and the hope is that it will receive the funding it needs to move forward to enhance SIMP.
“We have the strongest fisheries management regime of any country in the world. If our guys have to follow the rules and work within that system, it’s only fair that any other seafood coming into the U.S. should have to follow the same categories and rules,” Yozell said.
Environmental nonprofit Oceana said it is also supporting the new SIMP proposal and that the U.S. government should follow through to enhance the country’s seafood monitoring.
“NOAA’s action plan outlines important steps to improve the United States’ ability to fight illegal fishing and seafood fraud,” Oceana Campaign Director Max Valentine said. “Much of the plan relies on President Trump proposing these new rules that will level the playing field for U.S. fishermen while protecting American consumers and the oceans. These proposed actions, combined with the additional improvements to the program, will help to ensure that more seafood is safe, legally caught, and honestly labeled.”
