IUU Task Force
c/o Laurel Bryant
1315 East-West Highway
Room 14556
Silver Spring, MD 20910

September 2, 2014

Re: Presidential Task Force on Combatting Illegal, Unreported and Unregulated Fishing and Seafood Fraud; NOAA-NMFS-0214-0090

Dear Under Secretary Sullivan, Under Secretary Novelli, and Task Force Members:

On behalf of our organizations and our combined millions of members, we thank you for the opportunity to provide comments to the President’s Task Force on Combatting Illegal, Unreported, and Unregulated (IUU) Fishing and Seafood Fraud. As groups working to protect the health of our oceans and the environment, we strongly support a solution that will help ensure that our seafood is safe, legally caught, and honestly labeled. As the Task Force formulates its recommendations for the President, we urge an expeditious rulemaking to develop regulations that will keep illegally-caught fish out of the U.S. market; ensure that all seafood sold in the United States is fully traceable from point of harvest to point of sale; and provide consumers with more adequate and accurate information about the origins of their seafood.

In creating this Task Force, the President acknowledged the long-standing problems of IUU fishing and seafood fraud and the role that the U.S. market currently plays in driving those practices. Across the globe, IUU fishing is exploiting the health and economic viability of our marine resources, resulting in an estimated $10-23 billion in lost revenues every year. Estimates on seafood substitution, a type of seafood fraud, are alarming: studies suggest anywhere from 25 to 70 percent of commonly-swapped species like red snapper, wild salmon, and Atlantic cod are mislabeled. Unfortunately, the seafood supply chain is so complex and non-transparent that, paired with limited border controls, mislabeled seafood and illegally-caught products are entering the U.S. market. With insufficient enforcement against seafood fraud and no uniform standards for seafood traceability, the United States provides a lucrative market for IUU fishing and seafood fraud.

Fortunately, this Task Force has a significant opportunity to address these problems and improve the integrity of the seafood supply, both in the United States and abroad. The Task Force should recommend that new regulations be promulgated under existing law, creating a comprehensive solution to:

Prevent illegally-caught fish from entering the U.S. market by requiring that all seafood imported into the United States or offered for sale demonstrate that it originated from legal fishing;

Require that all seafood sold in the United States be fully traceable from the final point of sale back to the point of harvest, incorporating basic information about the who, what, where, when, and how of fishing and production as well as subsequent processing and distribution;

Improve consumer awareness by revealing basic information about a seafood product’s origins, such as type of fish, and where and how it was caught, to allow buyers to make informed decisions;

Strengthen detection of IUU product by implementing enhanced inspections, both at the border or in advance of entry into the U.S. market, including random audits of the supply chain. Relevant, verifiable information must be provided at any point in the chain upon request; and

Improve interagency cooperation and planning with the sharing of resources, expertise, and real-time information, as well as increased and improved inspections to ensure cost-effective deterrence and prevention of these problems.

These recommended actions will protect law-abiding fishermen and seafood businesses that are competing with illegal and fraudulent products; it will give consumers more information about the origins of their seafood; and it will help stop IUU fishing, which harms the oceans, people’s livelihoods, and the food security of coastal communities dependent on sustainable fisheries.

The time for strong leadership is now. Our organizations urge you to adopt these recommendations to protect our oceans, consumers, and honest businesses from the negative consequences of IUU fishing and seafood fraud.

Thank you for your consideration.

Sincerely,

David McGuire, MEH
Director, Shark Stewards