NFI comments on Presidential Task Force on Combating IUU Fishing...
The U.S. National Fisheries Institute (NFI) again submits comments to the Presidential Task Force on IUU Fishing and Seafood Fraud/National Ocean Council, this time in response to the Task Force’s August 3, 2015, Federal Register Notice applying seven principles to designate 12 seafood categories as “at risk” for both IUU fishing and seafood fraud and one as “at risk” for seafood fraud. These categories, according to the Task Force’s Action Plan, will be subjected to the traceability system outlined in a similar, July 1, 2015, Federal Register Notice, which requires affected seafood businesses to continuously collect and submit for unrestricted, perpetual Federal review a minimum of 17 pieces of data for every package containing any of those items imported into the United States.
NFI must again express disappointment with the Task Force’s proposal. In the August 3 Notice, the Task Force:
- Adopts as principles for designating seafood at risk for IUU fishing and seafood fraud the concept of “complexity of the chain of custody and processing” – a widely applicable (and entirely unobjectionable) characteristic of the global seafood industry
- Concludes with no evidence beyond the opinions of unidentified “experts” that the 13 chosen seafood categories – among them four of the top ten domestic categories – are at risk for IUU fishing and mislabeling, in effect alleging that multiple U.S. trading partners are complicit in widespread illegality intended to defraud tens of millions of American consumers and subvert fishery management systems that those partners established in the first place
- Ignores the simple fact that seafood fraud related to imported and domestic product occurs overwhelmingly in the United States and cannot possibly be addressed by targeting overseas producers who have no connection to the violations in question
- Denies, apparently, the obvious beneficial impact of enforcing existing Food and Drug Administration requirements related to economic adulteration of seafood in reducing seafood fraud
- Continues on a path that will trigger retaliation, in seafood and perhaps elsewhere, in the form of traceability requirements designed to hobble market access for U.S. exporters.
Click here for the full document.
Click here to see comment from VASEP
All comments related to the Presidential Task Force on IUU Fishing and Seafood Fraud/National Ocean Council can be found here.