On March 11th, the Southern Shrimp Alliance submitted comments to the House Ways and Means Committee in regards to a February 25th hearing held by the Subcommittee on Trade on American Trade Enforcement Priorities. In its comments, the Southern Shrimp Alliance explained that our food supply is an issue of national security concern for the United States and that support for the production of food, including seafood, in America must be increased.
As noted in the March 11th comments, in a recent Presidential Proclamation regarding National Consumer Protection Week, 2025 (Proclamation No. 10901 of March 6, 2025), President Trump observed that “Consumers deserve honest and accurate information to make decisions.” In keeping with this view, the Southern Shrimp Alliance explained that the continued abuse of banned antibiotics in foreign shrimp aquaculture creates health risks that American consumers have repeatedly shown that they would prefer to avoid. However, the failure of the federal government to increase testing has meant that contaminated foreign shrimp is reaching American consumers. For the U.S. shrimp market, this means that meaningful traceability requirements and the disclosure of the source of shrimp offered for sale is of even greater importance than other consumer products. Unfortunately, limited enforcement of the Seafood Import Monitoring Program (SIMP) and large gaps in data reporting under SIMP have worked to obfuscate the ability to trace shrimp back to their originating ponds. For these reasons, NOAA Fisheries’ ongoing efforts to improve SIMP, including enhancing the agency’s collaboration of the U.S. Customs and Border Protection (CBP), remain of great interest to the U.S. shrimp industry.
The Southern Shrimp Alliance’s March 11th comments expressed support for: (1) the strengthening of Enforce and Protect Act (EAPA) proceedings to more effectively address fraud employed to evade trade regulations; (2) requiring CBP to publish data on the collection of antidumping and countervailing duties on an order-specific basis to facilitate monitoring the effectiveness of trade remedies; (3) improvement of the antidumping duty laws to better identify and quantify unfair trade practices; (4) the public release of bill of lading information for imports entering the United States through truck, rail, and air in line with the information publicly released regarding ocean-going freight; and (5) address the adverse impact that the de minimis loophole is having on enforcement of U.S. laws prohibiting the importation of goods produced through child and forced labor. The Southern Shrimp Alliance believes that each of these recommendations is consistent with the principles set forth in President Trump’s America First Trade Policy.
Separately, on March 17th, the Southern Shrimp Alliance submitted comments to CBP regarding the agency’s notice of proposed rulemaking pertaining to the entry of low-value shipments. These comments expanded upon how the de minimis loophole has severely undermined enforcement of the prohibition of importation of goods produced by child and forced labor, including the Uyghur Forced Labor Prevention Act (UFLPA). CBP’s UFLPA enforcement statistics show that the value of shipments denied entry in fiscal year 2025 has fallen significantly compared to the last two fiscal years, as the agency denied entry to imports worth $362.95 million in fiscal year 2023 and $230.61 million in fiscal year 2024 but is on track to impact imports of just $65.04 million in the current fiscal year. While this may indicate a severe reduction in the amount of goods produced by forced labor that are shipped to the United States, it is far more likely that abuse of the de minimis loophole by Chinese exporters has resulted in widespread evasion of the UFLPA and has placed undue stress on CBP’s enforcement capacity.
Because the U.S. shrimp industry continues to be forced to compete in the U.S. market with Argentine Red Shrimp shipped from Chinese processors associated with Uyghur labor programs, the Southern Shrimp Alliance supports reform of the de minimis loophole to enhance CBP’s ability to enforce the UFLPA.
“President Trump has announced an America First Trade Policy that focuses on creating effective responses to unfair trade practices that, for far too long, have been ignored,” said John Williams, the executive director of the Southern Shrimp Alliance. “The American shrimp industry strongly supports the reform of American trade policy to focus on supporting and enhancing domestic production and the Southern Shrimp Alliance is proud to assist President Trump’s efforts however we can.”
Read President Trump’s America First Trade Policy Memorandum (Jan. 20, 2025) here: https://www.whitehouse.gov/presidential-actions/2025/01/america-first-trade-policy/
Read the Southern Shrimp Alliance’s March 11, 2025 comments to the House Ways and Means Committee here: https://shrimpalliance.com/wp-content/uploads/2025/03/2025.03.11-SSA-Comments-on-American-Trade-Enforcement-Priorities-1.pdf
Watch the Trade Subcommittee Hearing on American Trade Enforcement Priorities here: https://waysandmeans.house.gov/event/trade-subcommittee-hearing-on-american-trade-enforcement-priorities/
Read the Southern Shrimp Alliance’s March 17, 2025 comments to CBP here: https://shrimpalliance.com/wp-content/uploads/2025/03/2025.03.17-SSA-Comments-on-ELVS-NPM.pdf
Access the full docket of the 95 comments filed regarding de minimis importation requirements with CBP here: https://www.regulations.gov/document/USCBP-2025-0002-0001/comment