Southern Shrimp Alliance Submits Comments Supporting the Recommendations Proposed by the President’s Task Force on IUU Fishing and Seafood Fraud

In December, the President’s Task Force on Combating Illegal, Unreported, and Unregulated Fishing and Seafood Fraud issued fifteen (15) recommendations “for the implementation of a comprehensive framework of integrated programs to combat IUU fishing and seafood fraud that emphasizes areas of greatest need.”

The Task Force invited the public to provide comments regarding the proposed recommendations.  In response to this request, the Southern Shrimp Alliance submitted comments yesterday.  The Southern Shrimp Alliance’s comments covered a wide variety of issues, advocating for:

  • Legislative language that would harmonize the U.S. definition of Illegal, Unreported and Unregulated (IUU) Fishing with the definition set forth by the Food and Agricultural Organization of the United Nations’ (FAO) International Plan of Action (IPOA) to Prevent, Deter, and Eliminate IUU Fishing.  Making these definitions consistent would allow the U.S. government to address human trafficking and forced labor in seafood industries abroad through access to the U.S. seafood market.


  • The recognition of the importance of U.S. bycatch reduction policies, adopted by the domestic seafood industry, in meeting the goals and objectives of eliminating IUU fishing.


  •  The identification by the U.S. Trade Representative (USTR) of how current Free Trade Agreements (FTAs) are being used to combat IUU fishing and seafood fraud.  To the extent that current FTAs are not being utilized for these purposes, the USTR should be asked to propose obligations reasonably designed to address IUU fishing and seafood fraud.


  • The Task Force to not only seek to eliminate subsidies granted to the fishing sector but also seek to eliminate subsidies given to the aquaculture sector.  Commercial aquaculture, as currently constituted, depends upon the harvest of massive volumes of wild fish to produce fishmeal for farms, thereby substantially contributing to overfishing.


  • The recognition of the vital role trade arrangements and access to the U.S. market play in obtaining the support of foreign government officials to address IUU fishing and seafood fraud.


  • The compilation, dissemination, and publication of information currently submitted to the U.S. government through the U.S. Department of State’s “Shrimp Exporter’s/Importer’s Declaration,” DS-2031 – a form that must accompany all imports of shrimp and shrimp products into the U.S. market.


  • Educational efforts aimed at individual U.S. Attorney offices and the federal courts to increase understanding of the gravity of the threat posed by IUU fishing and seafood.  Misconceptions that these are merely victimless economic crimes should be directly addressed.


  • The identification by U.S. Customs and Border Protection (CBP) of how current Customs Mutual Assistance Agreements (CMAAs) have been used to combat IUU fishing and seafood fraud.


  • Prioritization of the clarification of species and common name of shrimp products sold in the U.S. market to facilitate consumers’ ability to distinguish between farmed shrimp and domestic wild-caught shrimp.


  • Revisions to the Harmonized Tariff Schedule of the United States (HTSUS) – in addition to those already adopted distinguishing between coldwater and warmwater shrimp imports – resulting in the collection of information of imports of wild-caught shrimp from imports of farm-raised shrimp products.  Such a distinction would be more consistent with federal regulation of shrimp in the marketplace, which often distinguishes between aquacultured and wild shrimp.


  • The collection of data and dissemination of information by appropriate federal officials of enforcement activities undertaken by state and local government officials to address IUU fishing and seafood fraud.  Recognition of the important work done by state and local governments to keep merchandise produced through IUU fishing and/or seafood fraud will encourage greater cooperation and create more opportunities for information sharing between federal and local government officials.


  • Legislative language augmenting CBP’s authority to address import fraud as set forth in the “Preventing Recurring Trade Evasion and Circumvention Act” (PROTECT Act) as developed and proposed by Rep. Charles Boustany (LA) and the “Customs Trade Facilitation and Enforcement Act of 2012” as introduced by Rep. Kevin Brady (TX).


  • The development of traceability systems that are individualized to the specific type of seafood product covered.  Approaching traceability protocols as a regime, rather than a single program, will assist in the implementation of systems that are effective and useful.


  • The identification and evaluation of the marking technologies that might be used to accomplish an effective and meaningful traceability regime with regard to seafood products.

In its comments, the Southern Shrimp Alliance also expressed support for the development of a regular forum “to enhance collaboration” from all parties interested in the elimination of IUU fishing and seafood fraud and committed to participating fully in whatever formal process is ultimately adopted by the Task Force.


The Southern Shrimp Alliance’s comments also drew attention to specific shrimp-related concerns that should be accounted for in the Task Force’s future work.  For example, the submitted comments discussed recent studies regarding the threat placed on wild fisheries from the significant expansion of aquaculture and China and, separately, the prevalence of misrepresentation of shrimp products in the U.S. retail and restaurant market.  Further, the comments emphasized the numerous problems evidenced by shrimp shipped from Malaysia to this market – observing that these problems have increased despite the existence of a CMAA between the Malaysian government and our own and despite continuing negotiations with Malaysia regarding the formation of a Trans Pacific Partnership (TPP).


Read SSA’s previous submission to the Task Force in September 2014:


Read the Task Force’s Recommendations as published in the Federal Register (Dec. 18, 2014):


Read SSA’s comments regarding the Task Force’s Recommendation (Jan. 20, 2015):

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