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Traceability? Accountability? Not With Indian Shrimp

In stories published by SeafoodSource and Undercurrent News yesterday, Choice Canning argued that three shrimp entry lines refused by the U.S. Food and Drug Administration (FDA) in April were mistakenly attributed to the company. The company has contended that the FDA’s refusals naming Choice Canning as the manufacturer of shrimp contaminated with veterinary drug residues were actually processed and shipped by another Indian shrimp company, Alpha Marine, that was using a FDA facility registration number obtained by Choice Canning and used without the company’s knowledge.

Although the supporting documents have not been publicly released, the description provided by Choice Canning corresponds to a shipment of 18,000 kilograms of “frozen shrimps” associated with bill of lading number COSU6370612550, that arrived at the port of Los Angeles on January 19, 2024, shipped by Alpha Marine with Flegenheimer International Inc. identified as both the consignee and notify party.

Information available from the relevant ship manifest does not provide any indication of the FDA facility registration number used by Alpha Marine for this shipment. Moreover, the Southern Shrimp Alliance is unaware of any publicly available database maintained by the FDA of the numbers registered with the agency by food facilities. Nevertheless, a review of bill of lading information from other ship manifests where the FDA facility registration number has been disclosed raises additional questions regarding both Choice Canning’s and Alpha Marine’s shipments of shrimp.

Specifically, these data show that at least two shipments of shrimp reported to have been processed and packed by Choice Canning used an FDA registration number that has also been utilized by Alpha Marine for nearly eight years. Moreover, bill of lading information shows that Choice Canning sources shrimp from Alpha Marine and that shipments of shrimp from Alpha Marine to Choice Canning reference the same FDA registration number that was recently ascribed to shrimp purportedly processed and packed by Choice Canning.

Shrimp “Processed & Packed” by Choice Canning Has Used FDA Registration Number 15882740826

On February 14, 2024, a shipment of shrimp, associated with bill of lading number EGLV101300094626, arrived at the port of Los Angeles. The goods contained in the shipment were shipped on December 5, 2023 for purchase order 8566 and described as 1,500 master cartons of frozen IQF raw, peeled and deveined, tail-off vannamei shrimp packed in 6 x 4 lb. bags under the brand name “Sea 888,” with the shrimp “processed & packed by Choice Canning Company Unit – II (A Division of Choice Trading Corporation Private Limited), Dammanavaripalem Village & Post Karlapalem Mandal Guntur District – 522111, Andhra Pradesh, India.” The goods description ascribed both an Indian government Export Inspection Council approval number (CHE/FFP/02784) and an FDA registration number (15882740826) to the shipment.

Five days later, on February 19, 2024, another shipment of shrimp, this time associated with bill of lading number EGLV101300094642, arrived at the port of Oakland. This shrimp shipped on December 26, 2023 for purchase order 8718 and was also described as 1,500 master cartons of frozen IQF raw, peeled and deveined, tail-off vannamei shrimp packed in 6 x 4 lb. bags, but this time under the brand name “Star Bay.” As with the earlier shipment, this shrimp was “processed & packed by Choice Canning Company Unit – II (A Division of Choice Trading Corporation Private Limited), Dammanavaripalem Village & Post Karlapalem Mandal Guntur District – 522111, Andhra Pradesh, India.” And, again, the goods description ascribed both an Indian government Export Inspection Council approval number (CHE/FFP/02784) and an FDA registration number (15882740826) to the production of the shrimp.

The Same FDA Registration Number (15882740826) Has Been Used by Alpha Marine Since 2016

Outside of these shipments of shrimp “processed & packed” by Choice Canning, the FDA registration number used, 15882740826, has also been referenced in over 150 shipments of shrimp that identify Alpha Marine as the exporter since at least 2016, including the following sampling of bill of lading numbers (arrival date in parentheses): EGLV101400031952 (April 30, 2024); CMDUAIS0437769 (December 4, 2023); EGLV101300029442 (June 16, 2023); HLCUMA3230118620 (March 13, 2023); WHLC144CX12022 (November 26, 2022); HLCUEUR2112BLKX9 (March 9, 2022); HDMUINCA2002693 (January 27, 2021); APLUAQS0115520 (March 30, 2020); and SAFM769344293 (December 16, 2016).

In other words, the FDA registration number (15882740826) used for shipments described as “processed & packed” by the Choice Canning processing facility that was identified by the FDA in recent entry line refusals is the same FDA registration that has been used by Alpha Marine for its shrimp shipments for almost eight years.

Choice Canning Sources Shrimp from Alpha Marine, Including Shrimp Described as Packed in a Facility with FDA Registration Number 15882740826

In fact, the bill of lading data establish that three of Alpha Marine’s shipments of shrimp referencing FDA registration number 15882740826 were made to Choice Canning. Bill of lading numbers WHLC144CX13163 (December 17, 2022); HLCUMA3221013031 (December 21, 2022); and HLCUMA3221037638 (January 6, 2023) each reflect shrimp shipments from Alpha Marine to Choice Canning in the United States, with the first shrimp shipped in packaging labeled “Tastee Choice” and arriving at the port of New York, and the next two shipped in packaging branded “Great Catch” and arriving at the port of Houston.

Who Is Accountable?

On its own, Choice Canning’s claims appear to indicate that an Indian exporter falsely attributed the processing and packing of shrimp exported to the United States to another processor without any fear of consequences for running afoul of the FDA’s requirements or the traceability obligations imposed by NOAA Fisheries’ Seafood Import Monitoring Program. 

But a review of ship manifests and underlying bill of lading data indicates that conflation of FDA registration numbers is unlikely to have been limited to the shipment refused by the FDA, as Alpha Marine is one of Choice Canning’s suppliers and Alpha Marine has long been associated with an FDA registration number (15882740826) that was recently ascribed to shrimp purportedly “processed & packed” by Choice Canning. In its responses to a series of negative reports, Indian shrimp industry members have repeatedly claimed that any adverse findings were due to cases of mistaken identity. Yet investigations into the industry lead to the conclusion that the opacity of Indian shrimp supply chains is a feature, not a bug, of the industry’s structure. The reactions to documented instances of violations have shown that, to date, there is little to no reliable traceability within the Indian shrimp supply chain.

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