On behalf of the public health organizations and individuals signed below, we are pleased to submit the following comment on combating illegal, unreported, and unregulated (IUU) fishing, seafood fraud, and human rights abuses. As professionals dedicated to protecting public health, we urge the federal government to take action against these intertwined issues and pass the Illegal Fishing and Forced Labor Protection Act to ensure that all seafood sold in the United States is safe, legally caught, responsibly sourced and honestly labeled. 

Widespread illegal, unreported, and unregulated (IUU) fishing and seafood fraud threatens public health and the future availability of seafood. IUU fishing is off the books, a low-risk, high-reward activity, and is thus not a small problem. Of the annual global seafood catch, an estimated one-third—as much as 56 billion pounds— is illegally fished. Seafood fraud ultimately deceives consumers who fall victim to a bait and switch, disguises conservation and health risks, and hurts honest fishermen and seafood businesses. An international conservation organization, Oceana, released a report in 2019 where they found that 21% of the 400 fish samples tested were mislabeled.

Furthermore, a lack of transparency and supply chain traceability in the seafood industry allows seafood tied to human rights violations to slip into the U.S. market. By requiring information about the origins of seafood and its supply chains, tracking seafood from boat to plate, and expanding transparency, the United States could lead in the fight against IUU fishing, seafood fraud, forced labor, and other human rights abuses for the future benefit of public health and ocean ecosystems.

The U.S. government has taken some steps to combat IUU fishing and seafood fraud, including establishing the Seafood Import Monitoring Program (SIMP). SIMP requires some imported seafood at risk of IUU fishing and seafood fraud to be accompanied by catch documentation about where and how it was caught, and requires those products to be traced from the fishing boat or farm to the U.S. border. While SIMP is a good step forward, these rules currently only apply to 40% of the value and volume of U.S. imports, and products are no longer traced once they have entered the country. This is a glaring loophole that IUU fishing operations exploit by deliberately misreporting species to escape regulation. If the federal government expands the SIMP to require reporting for imports of all species, it would close the U.S. market for the remaining 60% of seafood that could be caught illegally or unregulated, unreported, or produced by forced labor. 

The Food and Drug Administration proposed a new rule under the Food Safety Modernization Act that would require traceability for certain food products at every step in the supply chain. The FDA should be encouraged to work with NOAA and other partner government agencies to make the Act more effective by applying it to all seafood products and aligning it’s standards with relevant programs, like SIMP. There is a need to ensure that seafood does not remain subject to a set of standards and controls that are in any way weaker from those applying to other food categories. Interagency cooperation is key in utilizing the potential behind the FDA’s rule to help stop seafood fraud, keep illegally caught fish out of the U.S. market, and protect consumers from food safety concerns.

We urge the federal government to include the following in their recommendations to the President: 

1. Require full chain traceability for all seafood sold in the U.S. in order to reduce seafood fraud, safeguard consumer health and safety, ensure ethical fishing practices, and protect our oceans from further exploitation. SIMP must be expanded to all seafood, and traceability requirements should be extended through the full supply chain from boat to plate. Traceability information should be required for all seafood sold in the U.S. that provides location of catch or harvest, species-specific names for seafood, and information about how it was caught or farmed. This will help ensure that seafood sold in the U.S. is safe from human rights abuses, legally caught, and truthfully labeled, while providing consumers with accurate information needed to make healthy and sustainable seafood choices. 

2. Recommend the FDA to work alongside other agencies like NOAA to improve seafood traceability within the Food Safety Modernization Act and keep misbranded and illegally sourced products out of the supply chain. The FDA should also expand the rule to all seafood products; aligning with other federal seafood programs like the Seafood Import Monitoring Program; require electronic recordkeeping and reporting; and provide consumers and seafood buyers with more information at the final point of sale. These measures would give U.S. consumers the confidence they need to ensure that the seafood they buy is safe, legally and ethically caught, and honestly labeled.

Thank you for your consideration. Join other organizations in standing up for safe, legally caught, responsibly sourced, and honestly labeled seafood today. Complete the form below to sign our letter in support to urge the federal government to take action against illegal, unreported, and unregulated (IUU) fishing, seafood fraud, and human rights abuses.