Making Seafood Imports Safer by Reducing Illegal Fishing

Making Seafood Imports Safer by Reducing Illegal Fishing

0:00:00.4 John Sheehan: The global seafood trade is complex, far reaching and in many cases opaque. And unfortunately, these conditions can mask international cases of illegal unreported and unregulated fishing and even labor abuses. Because of this, it is vital that the United States stay vigilant on what it's importing and monitor those seafood imports carefully. This is Dive in with NOAA Fisheries, I'm John Sheehan, and today we'll hear about the Seafood Import Monitoring Program.

0:00:28.6 Alexa Cole: It's a reporting and record keeping program designed for us to gather information about certain seafood imports to be able to combat illegal unreported and unregulated fishing and seafood fraud.

0:00:41.1 JS: This is Alexa Cole, Director of NOAA Fisheries, Office of International Affairs, Trade, and Commerce, and she's leading the charge to update the Seafood Import Monitoring Program because for reasons that we'll hear about.

0:00:53.2 AC: From its inception, it hasn't been that popular. Stakeholders on all sides have been frustrated by it.

0:01:01.1 JS: But let's back up a second. The program was set up about five years ago.

0:01:04.8 AC: It came about as part of a presidential task force at the end of the Obama administration. There are 13 species or species groups that comprise over about 1100 individual species. Some of the big species that we import, such as tuna and shrimp, as well as abalone and some of the cods.

0:01:25.2 JS: But also important to note that while NOAA Fisheries was assigned this role, imports are not strictly speaking this agency's bag.

0:01:33.4 AC: Customs and Border Protection is actually the agency responsible for handling all imports of all products into the United States. There are a number of different agencies that have a role in monitoring seafood imports. We are the agency tasked with monitoring them for the purpose of combating IU fishing and seafood fraud in particular. It is a really big task that we're sort of asking this program to accomplish and we realized it didn't make good sense to expand this program in its current form and that we were at a stage where it made really good sense to do a comprehensive review of the program.

0:02:10.3 JS: Which brings us to today.

0:02:12.4 AC: Part of why there was so much frustration with the program was that there were expectations for it that it couldn't meet, right? This is a system that is at the moment, a reporting and record keeping system. The information about those imports has to simply come to us at the point of entry. So, anything that we are gonna do about that is going to be after it's already come into the United States. And some of the people who had, you know, advocated for this as part, this kind of program, as part of that presidential task force, were really hoping it was gonna be, you know, a door at the, at the front door of the United States and nothing's coming through until we can say this is, this product is fine, but that's simply not achievable. To give a sense of it, in the United States annually, and these are numbers from 2023, we import 2.4 billion kilograms of seafood.

0:03:12.2 AC: That's a value of about $21.7 billion and that constitutes about 377,000 individual entries into the, you know, import entries into the United States, each of which might involve dozens if not hundreds of harvest events. So, really being able to look at all that and say this is good, this is bad, is just not possible. So, we had to develop new tools to be able to do that, but that's what people had hoped for. And one of the things that's really different about fisheries imports than some other imports, which is that you can't look at a fish fillet and know that there was illegal unreported or unregulated fishing in its catching. You don't know that unless it's simply a species that's 100%, you know, prohibited from catching, otherwise, there's a dozens of dozens of reasons why that fish could have not been caught fully lawfully or didn't have the right paperwork with it, but you just won't know that when it comes into a container into the United States.

0:04:15.2 JS: And, and so, what did the review entail?

0:04:17.5 AC: So we launched it last October and we started out really by reaching out to all of the stakeholders that used the program. And so, it was over 7,000 different stakeholders that we reached out to. Our goal for the review was to hear from as many stakeholders as possible. And so, we began with that outreach. We did a few webinars, a couple of stakeholders pulled together three different workshops. So, we got to meet with folks from 80 different companies or areas that were interested in it. We did a number of things at the Boston Seafood Show, we had a round table, we had one-on-one meetings with companies. We pulled together an informal inter-agency working group because other government agencies, as you already mentioned, are relevant to this work. And then, the last piece that was really very interesting was we met with representatives from other governments. Some of them were ones that have programs like this, such as the EU and Japan. Some of them were governments that are thinking about developing programs like this, like Canada and Australia, and others of them were countries that export a lot of products to the United States. And so their industry uses our program and is subject to its requirement. And those conversations were really very interesting and helpful to us as well.

0:05:36.5 JS: Yeah, no doubt. So what, what kind of feedback were you collecting?

0:05:40.0 AC: So we were hearing things in a couple of themes. There were a lot of people who wanted to see the program expanded to all seafood species. As I mentioned, the volume of that is enormous. The species that are in the program at the moment constitute it ranges and changes from year to year, but about 35% or so by value and volume of seafood imports to the United States. Pre-COVID, it was a little higher, closer to 45%, but it goes up and down a little bit. So that was one common theme. There are those who would like to see the program go away entirely or be narrowed, so it wasn't a uniform view. Uh, there were definitely a lot of folks who wanted to see better inter-agency coordination and data sharing so that we avoid duplication, so that you know, we don't have to ask the same things that the food and drug administration is asking for. One of the bigger things that people wanted to see was an ability for us to take greater action when we know information about the imports coming into the country, if we think that there's a problem. The fact that all of it was happening after the fact was frustrating. There were a lot of folks who liked the EU system and they liked some of those elements of having governments having to certify as to umm, the legality of an import. And so, those were some of the, some of the common themes that we heard.

0:07:08.7 JS: So let's talk about some of these updates. What are some of the proposed changes?

0:07:14.0 AC: Yeah, so one of the biggest changes is we are planning to expand the program to all species, but we're going to do it a little bit differently than other people. Perhaps we're imagining it, which is that we're creating two Tiers. Tier One is gonna continue to be all the species that are in the program now and any additional species that we deem to be at high risk. And then Tier Two will be all other seafood species. And the difference between the Tiers is going to be Tier One, the higher risk group will continue to have all of the data elements required that are required of the program now, as well as a few additional data elements. And Tier Two will have a smaller subset of data elements that are gonna be mostly sort of the fundamental, like what is it, where is it from? And that's gonna, one of the important ones that it will include is not just country of origin, which can be where seafood was processed, but also the original country of harvest where that fish was caught. So that's gonna be information that's useful. So that's a big major change to the program that's gonna fundamentally expand it quite significantly.

0:08:19.8 AC: The other big change is going to be that we are going to move back the time for which information has to be provided. You know, 72-96 hours is what we're thinking about right now in advance of entry into the United States. And that again will set us up for a situation where when we know information about those imports, we could actually do something prior to them entering into the United States and into our marketplace. But all of this, these two big changes wouldn't have been possible five years ago. We were not in a place to do that back when we just got the program going. Our team has developed something called the Global Seafood Data System or GSDS, and it really is a bit of a game changer for us because it is now uh, a program that is set up to be able to help us do a risk targeting of shipments. And it includes some of the AI machine learning tools that, uh, are being developed. And so it allows us to say, uh, identify risk scores for different kinds of shipments, whether it's by species, by company, by supply chain, by importer, whatever those factors are, we can sort of dial up or down and get higher or lower risk scores so that we're getting to a point and it's gonna take time 'cause these systems are based on learning of, from what they get. But what, be in a point where we could say "CBP, check this container", and we'd have some high degree of confidence that there was some area of concern in that shipment.

0:09:55.8 JS: That's incredible. Umm, it seems like both those changes will also mean by necessity, uh, increasing capacity for data. Is that part of the program?

0:10:04.9 AC: It is. You caught that and that's one of the big things, which is that, you know, that is a lot more data coming in. And so some of the front facing things that will be in rule makings are things like this, changes to the species and you know, changes to the timing. What's gonna have to happen behind the scene is we are gonna have put a lot of time, energy and resources into upgrading some of our data systems so that they are able to take in all that data and be able to still function and not just sort of slow to a crawl. It also will require some work with CBP because we use their system to collect the data initially and when we have new data elements, we have to work with them to get them added into their system. And it is also going to take some building of our team. You know, we're gonna need to hire some new staff, we are gonna need to convert some contractors to full-time staff members. So there's a lot behind the scenes that has to happen to make these changes actually have the impact that we think they can have.

0:11:09.4 JS: And uh, what's the timeline like? Are you at the beginning of this process or are you, are you in the middle of it?

0:11:17.7 AC: Well, we're at the end of the comprehensive review, but we're at the beginning of the implementation of the outcome. So, uh, now that we have rolled this out into the world, as I say, we've sort of gone out of our more public louder phase about this work and we'll go a little bit quiet to start doing the work. So some of these changes are gonna require rulemaking and so, uh, the team is going to start that work now. Uh, some of the changes are things that don't require rulemaking. They're, you know, internal like working on the databases and doing staffing, and we will begin implementing those immediately. All of it is obviously, you know, dependent on time and resources as everything is in the government, but we are now moving into that active implementation phase at this moment.

0:12:02.5 JS: And this has all been done in concert with stakeholders. You've been collecting this feedback to inform these changes. I'm wondering, when you were gathering this feedback, were there misconceptions floating around either about the program or about the program's intentions that you've had to sort of combat or are any of these changes meant to sort of correct those misperceptions?

0:12:25.2 AC: So I think it's yes to all of that, which is yes, there absolutely have been misperceptions about the program and what it could accomplish throughout its history. I mean, that's been one of our biggest challenges, which is we were failing to meet expectations that we could never have met, that we were gonna be able to stop and take a look at every single piece of fish before it entered the United States and it would only enter once we were confident in its legality, that, that was never gonna be feasible and it's not feasible now. What we are now hoping to do though is get closer to meeting the more realistic expectation of being able to do better risk targeting, have better information and be able to start to actually identify risky shipments and stop them before they come through our borders. But that's still never gonna mean that we're stopping and looking at every single piece of fish. But I do think that the new system that we've created along with some of these changes is gonna put us in a position to really, really have this program be an impactful, meaningful program. And I think it will just continue to become even more so with each passing year.

0:13:35.0 JS: Alexa, do you see some of these updates having a positive impact on preventing labor abuses?

0:13:40.6 AC: So we do, labor is not the focus in the mandate of NOAA, but we do think that there are ways this program can be helpful in the US government's efforts to address those issues. We are planning to add some new key data elements that we think will have a dual purpose, that they're gonna be related to providing information that will be useful for us in combating IUU fishing, but that also will be useful information in addressing labor abuses. Some of them are focused on more details related to transshipment events. Areas of transshipment, which is where fish is transferred at sea from vessel to vessel are often known as higher risk for illegal fishing, but also as where there can be issues related to labor abuses. Also looking to expand our data elements to capture the length of a fishing trip, which can also be another indicator that there could be labor abuses.

0:14:34.5 AC: If a fishing vessel is at sea for six months and doesn't come into port, there are some issues there. So we think some of that will be useful. Also, some of the work that we plan to do to do more analysis about our supply chain with some of our broader data that we've been collecting. Right now, we focus what we look at on the shipments that we audit or investigate, but there's a lot of other data of shipments that we don't audit and investigate, but we are looking to do a deep dive into that past data as well as build our capacity to analyze data into the future. And we think we will likely find some information in there that will also be relevant to the issues related to labor abuses that we will then be able to share with our sister agencies who have a mandate to actually take action on those things.

0:15:22.8 JS: Yeah, it seems like these updates are really geared towards, umm, making the monitoring aspect [chuckle] of the program much more robust.

0:15:31.7 AC: That's right. We're really looking to build that capacity and so, uh, being able to have more data is gonna tell us more about seafood imports through the United States. Being able to analyze that data and a better, more near real time basis is going to give us more information about what are risky areas. You have to imagine all of this goes back to was something caught properly thousands of miles away. And so, we need to be able to learn, is it, you know, is this country not catch this fish? Does this supply chain always have a lot of transshipment events that makes it higher risk? Does it move through countries that don't have good fishing regulations in place or don't have good labor protections in place? Right? All of these are the indicators that we'd have to look at and our system is getting ready to be able to really be able to be used in that way as we bring more data into the system, and that will give us the tools to be able to identify those shipments and those products that we really don't wanna allow into the US market, which will, you know, the goal is being able to use the power of the US market to try to influence what's happening in the world.

0:16:43.3 AC: We're one of the world's biggest markets and this is not gonna do it single-handedly, but we think that this is gonna be an important piece in that effort and we're really excited about being able to implement these changes.

0:16:55.0 JS: Can I ask you what you would hope to see from the program in, in the next two years? What does success look like?

0:17:02.5 AC: Well, so success is a couple of different things, right? First of all, as I said, we're gonna get to work on doing this rulemaking, get the proposed rule out in 2025, and then be able to move quickly to a final rule. But handing glove with that is going to have to be working on the internal systems that let us do that. And the other key piece of it is that we have a really strong, effective, capable team working on it. I'm really, it's a great team that's been doing all this work, but they've been doing a lot of work with few hands and I'd like to give them a few more hands to do this work so they, you know, could take a little rest every once in a while. [chuckle]

0:17:43.6 JS: Well, Alexa Cole, thanks so much.

0:17:45.4 AC: Thanks very much John, I appreciate it.

0:17:47.3 JS: Alexa Cole is the director of of NOAA Fisheries Office of International Affairs Trade and Commerce. To learn more or keep up with the updates to the Seafood Import Monitoring Program, visit fisheries.noaa.gov. I'm John Sheehan, and this has been Dive in with NOAA Fisheries.