As you may know from my work, if by some obscure reason you have been reading my blogs for the last 12 years, Catch Documentation Schemes has been one of my main professional frustrations.
I started working on them back in 2009, while employed by FAO, following their mention in the PSMA, and continued through the frustrations of the EU CCS (2010) and the long, disappointing story of the never-to-be-advanced WCPFC CDS (2013). I was also the author of the initial draft and a later part of the secretariat for the FAO CDS technical consultation (2015) and the 2017 voluntary guidelines. Additionally, I co-wrote a seminal book on the subject with my friend Gillies, linking traceability to fisheries compliance, and peer-reviewed two other books he authored. Further frustrations arose with FFA CDS. Recently, I documented all the CTEs and KDEs for end-to-end traceability in both fisheries and aquaculture for FAO, which, to date, has not been used by any RFMO.
the way everything starts
The frustrations come primarily out of the unilateralism of those imposed by end markets (being quite critical of them for many technical reasons) and the lack of political will to set up fisheries forward ones out of RFMOs (especially the WCPFC)
This does not mean I don’t keep track of what is happening and being written, particularly when the authors are people I know, like the first 3 in this paper: Leslie Roberson, Gilles Hosch, and Chris Wilcox.
Their paper, A New Seafood Import Policy for Nations to Combat Illegal Fishing, while not explicitly written for the timid noises Australia has been making about setting up a unilateral one… I feel it was meant for Australia, and hence you can argue it's “new”
I like this paper because it summarises the shortcomings of unilateral CDS over the past 15 years. I can now send questions about the EU CCS, US SIMP, the Japanese one, and other unilateral initiatives to this document instead of coming over my blogs and books!
It is a good and informative paper. Below is a summary, but as always, I recommend you read the original!
The complexity and opacity of global supply chains make it difficult to trace the origins of seafood products. Compared to other agricultural commodities, seafood import controls are severely inadequate, leaving consumer countries vulnerable to the entry of illegal products into their markets.
Currently, only three major market regions—the European Union (EU), the United States, and Japan—have enacted legislation targeting IUU seafood imports. These systems, while important, are riddled with loopholes and do not fully guarantee the legality and traceability of seafood products. For example, the EU’s catch documentation scheme, introduced in 2010, is paper-based, which makes it vulnerable to fraud. Although updates are scheduled for 2026, the digitisation will only take place at the final point of trade, leaving earlier stages of the supply chain exposed. Similarly, the United States’ Seafood Import Monitoring Program depends on importers to gather and maintain supply chain documentation, but it lacks a centralised tracking system. Japan’s catch documentation scheme, implemented in 2022, covers only four species groups, limiting its scope.
The paper stresses the importance of wider adoption of import controls by more countries to strengthen global efforts against IUU fishing. Countries like Australia, which imports two-thirds of its seafood, have the chance to create leading systems that promote multilateral cooperation. Australia has been a regional leader in fighting IUU fishing through initiatives such as the Regional Plan of Action on IUU fishing. However, it currently lacks specific import controls to stop IUU seafood from entering its borders. The Australian government is working on a seafood import regulation policy aimed at IUU products, building on existing examples from RFMOs and other market states.
The authors identify two main types of trade measures used to track the origins and verify the legality of internationally traded seafood: catch documentation schemes and import monitoring programmes. Catch documentation schemes, as defined by the Food and Agriculture Organization (FAO), begin at the fishing vessel with the issuance of a catch certificate that links to subsequent trade documents throughout the supply chain. These schemes are either multilateral, carried out by RFMOs, or unilateral, implemented by market states. Import monitoring programmes, on the other hand, require trade documentation at the point of import but lack a traceability mechanism covering the entire supply chain.
The paper highlights key flaws in current systems, including limited control over complex supply chains and arbitrary enforcement mechanisms. Multilateral trade measures are preferred over unilateral systems, as they can prevent IUU fishing across entire species or stocks. However, the three existing RFMO catch documentation schemes only cover a few species, reducing their effectiveness. Diplomatic efforts to encourage more countries to adopt these measures are essential. Furthermore, enforcement triggers in current systems are often inconsistent and lack transparency, which diminishes their effectiveness.
To overcome these limitations, the authors suggest eight essential design standards for improved seafood import control systems.
Fully Electronic Catch Documentation System: A digital system for issuing and storing catch and trade certificates is crucial for effective traceability and preventing fraud.
Linked Certificates Along the Supply Chain: Certificates should be sequentially connected to ensure traceability from the fishing vessel to the final market.
Centralised Certificate Registry: A centralised electronic registry accessible to authorised parties can reduce fraud and encourage multilateral participation.
Automated mass balance monitoring: Automated systems should identify discrepancies in the supply chain, preventing unauthorised products from re-entering certified supply chains.
Official Validation Process: Public authorities should supervise the validation and certification procedures to ensure authenticity and compliance with regulations.
Integration With Trade System Infrastructure: The system should seamlessly integrate with existing trade and customs processes to streamline operations.
Minimum Key Data Elements and Unique IDs: A standardised set of essential data elements and unique identifiers can facilitate interoperability and effective tracking.
Broad Scope of Species Coverage: Trade measures should encompass a wide variety of species to prevent mislabelling and ensure thorough traceability.
The authors highlight the importance of designing systems that are flexible, automated, and self-enforcing. Countries like Australia can take the lead by adopting systems that complement and build upon existing frameworks in the EU, US, and Japan. A centralised and collaborative certification system would reduce compliance burdens and simplify the current patchwork of regulatory arrangements. Digital traceability systems, such as blockchain technology, can improve trust and transparency in seafood supply chains, making it easier for small-scale actors to participate.
In conclusion, the paper urges market states to take a leadership role in fighting IUU fishing by implementing effective import control measures. By adopting well-designed systems and supporting multilateral cooperation, consumer countries can play a crucial role in enhancing the sustainability of global fisheries and reducing the ecological and social harms related to IUU fishing.