Some details on the U.S. Seafood Import Monitoring Program / by Francisco Blaha

Last week I posted on the "new" U.S. Seafood Import Monitoring Program, and lamented that as the EU at the time, they put they coins in a unilateral CDS, instead of using their market strength to set up a multilateral one, (after all in between both they have the have at least 2/3 of the import trade... corral Japan and China into it, and the picture is complete. But yeah... truly international concerted action is always dreamland stuff unfortunately.

Who's your importer?

Who's your importer?

In any case here are some of the details:

As I presumed they kind of follow the model set originally up by the Seafood HACCP rule that kicked in around 1998, the responsibility is in the importer.  In most countries, importers must be registered for customs and tax purposes, hence these are identified and can be registered, licensed and "audited" by the authorities against defined responsibilities. That didn't work particularly well initially with the HACCP rule, but been refined since then

Those responsibilities over importers got bigger with the Bioterrorism Act 2002 and then the US Food Safety Modernization Act 2014, that includes specific provisions for a Voluntary Qualified Importer Program, Import Certifications for Food and Prior Notice of Food Shipments among others. Hence there is a solid base to add fisheries requirements on top. On a positive note, from scratch via the US Presidential Task Force, got the fisheries authority (NOAA) and Food Safety (FDA) under the same page, always a smart move as many of the traceability requirements are similar.

The information to be collected and is to be available by the importer at the moment of reception is the ABC of any basic (but well designed) CDS, namely: 

Harvesting or Producing Entity

  • Name and flag state of harvesting vessel(s)
  • Evidence of authorization to fish (permit or license number)
  • Unique vessel identifier (when available)
  • Type(s) of fishing gear.

Note: The fishing area and type of fishing gear should be specified per the reporting convention and codes used by the competent authority exercising jurisdiction over the wild capture operation. If no such reporting requirements exist, FAO fishing areas and gear codes should be used.

Fish – What, when and where?

  • Species of fish—Scientific/Acceptable market name (ASFIS three-alpha code)
  • Harvest date(s)
  • Product form(s) at time of landing - including quantity and weight of product
  • Area(s) of wild-capture or aquaculture harvest
  • Point(s) of first landing
  • Name of entity(ies) to which the fish was landed or delivered

Note: In cases where entries and products comprise more than one harvest event, each event that is relevant to a shipment must be reported but the importer does not need to link each event to a particular fish or portion of the shipment.

Importer of Record

  • Name, affiliation and contact information
  • NOAA Fisheries issued international fisheries trade permit (IFTP) number.
  • Importer of record is responsible for keeping records regarding the chain of custody detailed above.
  • Information on any transshipment of product (declarations by harvesting/carrier vessels, bills of lading)
  • Records on processing, re-processing, and commingling of product.

As I mention las week, the collection of catch and landing documentation for these the seafood species will be done through the International Trade Data System (ITDS), the U.S. government’s single data portal for all import and export reporting.

I think that in the Pacific (all tunas are in) we are ripe to set up a "multilateral CDS" that even if does not incorporate all the "end-markets", it can provide the requested set of data to the ITDS in centralised way. Otherwise we need to rely on individual exporters, which may be cheaper, but information has a massive value for decision making in the fishery. Furthermore is not yet clear for me how the importer knows that the information provided is true?  As I said, the most common sense solution is a multilateral CDS that can communicate with the ITDS, where the information is "real"