In written comments submitted on Tuesday to the Interagency Seafood Trade Task Force, the Southern Shrimp Alliance emphasized the need for any comprehensive interagency seafood trade strategy to address seafood imports into the United States.
NOAA Fisheries reports that the United States ran a $16.8 billion trade deficit in edible seafood in 2018. This trade deficit in seafood has grown massively over the last decade, as the value of seafood imports has increased by $7.3 billion since 2010 while the value of our country’s exports of seafood has remained flat over the last decade. These data demonstrate that the single biggest growth market available for the U.S. commercial fishing industry is the U.S. domestic market.
The single biggest contributor to our trade deficit has been the importation of shrimp. NOAA Fisheries reports that the United States imported $6.2 billion in fresh and frozen shrimp in 2018, meaning that the country runs a trade deficit by virtue of its shrimp imports alone.
The massive growth in shrimp imports has been facilitated by lax regulation of contaminated imports. The United States, through the U.S. Food and Drug Administration (FDA), administers a food regulatory system that is principally reliant upon importers to assure the safety and wholesomeness of seafood imported into the United States. This approach has not changed even where a foreign supplier, such as the Indian shrimp industry, has repeatedly demonstrated an inability to prevent banned and harmful antibiotics from being utilized in their aquaculture.
In stark contrast to the FDA’s approach, other major seafood importing markets, like the European Union and Japan, have subjected Indian shrimp to requirements that between thirty and one hundred percent of shipments be tested for antibiotics. The impact on India’s shrimp exports has been staggering. Although the volume of India’s shrimp exports to all three of these markets was roughly the same in 2010, with India’s government implementing extensive subsidy programs to encourage aquaculture production and exports, the United States has become the dumping ground for cheap, contaminated Indian shrimp.
As a result of these trends, in 2018, shrimp imports from India, on their own, comprised over thirteen percent of the country’s trade deficit in edible seafood.
For these reasons, any comprehensive federal interagency seafood trade strategy must address imported seafood. By simply addressing the incredible imbalance in trade of a single seafood product – shrimp – the Administration could make significant inroads in reversing the trend of growing trade deficits in edible seafood.
The Southern Shrimp Alliance’s comments also raised concerns regarding the U.S. seafood industry’s reliance on China as an export market. Although China’s share of this country’s seafood import value has declined significantly over the last decade, China has continued to account for between one-sixth and one-fifth of the United States’ annual seafood export value.
Beyond the continuing tensions between the two nations in our general trade relationship, China’s recent actions to curtail shipments of Ecuadorian shrimp based on unsubstantiated concerns regarding risks of the spread of COVID-19 through frozen food packaging should act as strong caution against dependence on the Chinese market.
Several other seafood firms and industry organizations have also submitted comments to the Interagency Seafood Trade Task Force.
- One fish processor, Acari Fish, emphasized the difference in the FDA’s approach to the regulation of seafood versus the U.S. Department of Agriculture’s (USDA) approach to the regulation of siluriformes (catfish), explaining that the company is unable to import product from Mexico because it has not yet been able to demonstrate that they operate an equivalent food safety program to that of the USDA. As there is no equivalency requirement for seafood products governed by the FDA, Acari Fish would have no problems importing from Mexico under the FDA regulatory system even if Mexico could not demonstrate that its food safety system was equivalent to that of the United States.
- The Western Pacific Regional Fishery Management Council has submitted a list of notable needs to be considered by the Interagency Seafood Trade Task Force, including: (1) country-of-origin labeling requirements for seafood on restaurant menus and in seafood retail markets; (2) enhanced recognition of NOAA FishWatch as a third-party certification of fishery sustainability; (3) increased FDA testing of seafood imports; (4) a cessation of further fishery area closures and consideration of re-opening of areas previously closed; (5) prevention of the importation of seafood harvested through illegal, unreported, and unregulated (IUU) fishing; (6) development of young fishermen programs; and (7) the introduction of a greater variety of domestic seafood products in school food lunch programs administered by the USDA.
- Norpac Fisheries Export submitted comments noting that unfettered access to the U.S. market has allowed foreign seafood producers to establish a presence in the United States, “replac[ing] US owned and operated seafood companies through strategic marketing and pricing, and using the leverage this creates to outmaneuver and underprice US owned companies.” Through these advantages, foreign companies can “buy out US companies at discounted prices, further consolidating their control of the US food supply, and of course [the] US seafood industry.”
- The Blue Water Fishermen’s Association submitted comments explaining that “[w]e do not think it is possible for the Task Force to develop a truly comprehensive interagency seafood trade strategy without also addressing U.S. seafood imports,” explaining that “our continued overwhelming dependence on imports to meet our seafood consumptive demand presents a significant threat to the food security of the Nation.” The Association also raised concerns regarding China’s recent actions taken against Ecuadorian shrimp shipments.
- The Louisiana Shrimp Association submitted comments explaining that “[o]ur number one issue is seafood imports.” The Association called for greater inspections of imported seafood, noting that “we feel that this is the time to step up and do more thorough inspections.”
Read the Southern Shrimp Alliance’s July 27, 2020 comments to the Interagency Seafood Trade Task Force: https://shrimpalliance.com/wp-content/uploads/2020/07/SSA-Comments-to-Interagency-Seafood-Trade-Task-Force-7-27-2020.pdf
Read Acari Fish’s July 27, 2020 comments to the Interagency Seafood Trade Task Force: https://www.noaa.gov/sites/default/files/atoms/files/Acarifish.pdf
Read the Western Pacific Regional Fishery Management Council’s July 10, 2020 comments to the Interagency Seafood Trade Task Force: https://www.noaa.gov/sites/default/files/atoms/files/Notable%20Needs%20for%20Seafood%20Trade%20Task%20Force.pdf
Read the Norpac Fisheries Export’s July 26, 2020 comments to the Interagency Seafood Trade Task Force: https://www.noaa.gov/sites/default/files/atoms/files/Norpac%20Fisheries%20Exports.pdf
Read the Blue Water Fishermen’s Association’s July 27, 2020 comments to the Interagency Seafood Trade Task Force: https://www.noaa.gov/sites/default/files/atoms/files/BWFA%20comments%20on%20Interagency%20seafood%20trade%20Task%20Force%20f%207-27-20.pdf
Read the Louisiana Shrimp Association’s July 28, 2020 comments to the Interagency Seafood Trade Task Force: https://www.noaa.gov/sites/default/files/atoms/files/Louisiana%20Shrimp%20Association.pdf
Review all other comments submitted to the Interagency Seafood Trade Task Force: https://www.noaa.gov/interagency-us-seafood-trade-task-force