NCBFAA Warns NOAA: Seafood Supply Chain Not Ready for New Entry Data Requirements


In a letter to the National Oceanic and Atmospheric Administration's ITDS Program Coordinator (NOAA), NCBFAA expressed concern about the trade's readiness to meet the agency's new extensive entry data requirements for 11 species of seafood and seafood-containing food products.  Beginning January 1, under the Seafood Import Monitoring Program (SIMP), importers are required to electronically submit detailed data elements, including:  where the fish was caught, the type of net used, the name of the vessel, where the fish was off-loaded, the weight of the fish when it was off-loaded, the name of the processor, among other details.


"There remains much confusion and misunderstanding in many parts of the supply chain," wrote NCBFAA's President Geoff Powell, "Even when the U.S. importer is fully aware of his obligations, the task at hand is daunting. The global seafood supply chain is a very complex network of people and companies..., making the SIMP electronic filing data especially hard to gather -- particularly when a typical shipment mixes seafood from multiple sources. It requires the importer to gather details not just from his immediate foreign supplier, but data from his supplier's suppliers -- which can be many layers deep."


With the pilot to test the new program only recently started, the NCBFAA President told NOAA, "We can tell you with certainty, four to six weeks of pilot testing is not sufficient lead-time to ensure a successful implementation on January 1."


NCBFAA urged the agency to plan a "soft compliance" policy with regard to the new data entry requirements in ACE as the seafood supply chain adjusts to the new requirements.


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