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Southern Shrimp Alliance Submits Comments Regarding Secure Food Supply Chains to U.S. Department of Agriculture

On Friday, the Southern Shrimp Alliance submitted comments to the U.S. Department of Agriculture (USDA) regarding how stimulus relief programs and spending related to food supply chain resilience can help to increase the durability and resilience of U.S. seafood supply. The USDA’s request for comments was an outgrowth of an Executive Order issued in February (Executive Order 14017) regarding America’s Supply Chains that emphasized the need for resilient, diverse, and secure supply chains to ensure U.S. economic prosperity and national security.

The due date for comments to the USDA was extended last week until June 21, 2021. As such, other members of the shrimp industry, as well as anyone concerned about food production and supply in the U.S. market, are encouraged to provide their views to the agency.

In its extensive comments, the Southern Shrimp Alliance observed that shorter food supply chains are far more secure than long and complex food supply chains. Nevertheless, over the last thirty years, federal policies have substantially favored imported seafood over domestically produced seafood. As a result, imported seafood, with long, complex, and opaque supply chains, now dominates the U.S. seafood market. While the total value of domestically-produced seafood was roughly two-thirds that of imported seafood in 2000, as of 2019, NOAA Fisheries reported that the total value of domestically-produced seafood was only slightly more than half the total value of imported seafood.

The Southern Shrimp Alliance’s comments explained that the development of a market that is overwhelmingly tilted towards imports came about through differential treatment of foreign production of seafood as compared to domestic production of seafood. Unilateral approaches by federal regulatory agencies to address food safety, environmental impact, and working conditions for operations in the United States have meant that the U.S. commercial fishing industry and domestic seafood processors are subject to ever-increasing regulatory controls while, at the same time, they are forced to compete for sales against foreign seafood industries that operate under no similar restrictions. The adverse impact on the domestic seafood industry is compounded by the fact that other major seafood importing markets have sought to apply stronger standards to imports, diverting seafood to the U.S. market, and the fact that foreign governments heavily subsidize and support their seafood export industries.

The Southern Shrimp Alliance’s comments further explained that strict regulatory structures have inhibited innovation within U.S. commercial fishing industries and have constrained the ability of these industries to adapt and respond to environmental changes. Moreover, any possible benefit obtained in the marketplace by the domestic industry’s adherence to stricter regulations has been undermined by weak country-of-origin labeling (COOL) rules. Consumers are not informed about the source of seafood purchased at restaurants and the USDA’s implementation of COOL regulations regarding retail facilities has created large loopholes where these rules do not apply.

The cost of decades of privileging imported seafood over domestic seafood production has led to the graying of commercial fishing fleets. Recruitment of a new generation of fishermen and women has become increasingly difficult as imports have established near total dominance in the U.S. seafood market. Accordingly, programs to assist in the development of young fishermen, as well as the enhancement of the professionalization of the commercial fishing industry are vital to the long-term viability of the commercial fishing industry. In the absence of such measures, the supply of seafood to the U.S. market will become exclusively reliant on long, complex, and opaque supply chains that make all Americans more vulnerable and less secure.

Read the Southern Shrimp Alliance’s May 21, 2021 Comments to the U.S. Department of Agriculture, Comments Regarding Supply Chains for the Production of Agricultural Commodities and Food Products:   https://shrimpalliance.com/wp-content/uploads/2021/05/SSA-Comments-to-USDA-on-Supply-Chains-Executive-Order.pdf

Read Executive Order 14017, Executive Order on America’s Supply Chains (Feb. 24, 2021): https://www.whitehouse.gov/briefing-room/presidential-actions/2021/02/24/executive-order-on-americas-supply-chains/

Read the U.S. Department of Agriculture’s Federal Register notice requesting comments regarding Supply Chains for the Production of Agricultural Commodities and Food Products (April 21, 2021):  https://shrimpalliance.com/wp-content/uploads/2021/05/Federal-Register-Requesting-Comments-on-Food-Supply-Chains.pdf

Read the U.S. Department of Agriculture’s Federal Register notice extending the deadline for comments regarding Supply Chains for the Production of Agricultural Commodities and Food Products to June 21, 2021 (May 17, 2021):  https://shrimpalliance.com/wp-content/uploads/2021/05/Extension-Notice-for-Comments.pdf

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