The National Oceanic and Atmospheric Administration (NOAA) will require a permit and additional data reporting for certain imported fish and fishery products. Starting January 1, 2018, failure to provide the appropriate permit information and/or sufficient accompanying data can delay entry or even result in the rejection of shipments.
Who should be concerned?
If you work with the following fish species: Atlantic Cod, Pacific Cod, Blue Crab, Red King Crab, Dolphinfish (Mahi Mahi), Grouper, Red Snapper, Sea Cucumber, Sharks, Swordfish and Tunas (Albacore, Bigeye, Skipjack, Yellowfin, and Bluefin). However, you won’t be affected by the new requirement if you are an importer of fish oil or processed fish products such as fish cakes.
International Fisheries Trade Permit (IFTP)
NOAA requires entities which import, export, or re-export covered fish and fishery products to obtain an IFTP by electronically applying for an annual renewable permit through the National Permit System (NPS). Importers must submit the permit number, additional data and all trade documentation via the Customs Automated Commercial Environment (ACE) upon filing entry in the United States.
What Additional Data is Required with the IFTP?
The importer must submit through ACE all the information regarding the fish harvesting or fish farming:
- Name and flag state of harvesting vessel(s)
- Evidence of authorization to fish (permit or license number)
- Unique vessel identifier (when available)
- Type(s) of fishing gear used
- Name(s) of farm or aquaculture facility
- Species of fish – Aquatic Sciences Fishery Information System (ASFIS) number
- Landing date(s)
- Point(s) of first landing
- Name of entity(s) to which the fish was landed or delivered
- Product form(s) at time of landing including quantity and weight of product
- Area(s) of wild-capture or aquaculture harvest[1]
If the importer (or their broker) does not submit the required data upon filing the entry, then the ACE system will reject the entry, which means that there will be a delay in the eventual release of the fish and fishery products into the United States.
In addition to the above information, importers should maintain a listing of all the participants in their supply chains. This can be a complex situation due to modern global supply chains that normally involve multiple parties. Even though only U.S. importers are legally required to comply with this rule, other trade members (such as the foreign manufacturer and the supplier) should still be prepared because importers will request this information from the manufacturer.
What Can Importers Do Now?
It is vital for those members of the trade community to establish the proper Standard Operating Procedures (SOPs) that implement the requirements for the above referenced NOAA permit and Customs filing.
Starting October 1, 2017, the NOAA’s National Marine Fisheries Service has opened a voluntary pilot program to test the electronic filing of the above required data. Importers can participate in the pilot program to get familiarized with the system and prepare to get the seafood entries processed smoothly after the compliance date January 1, 2018.
FDAImports.com is here to help you establish the proper procedures and prepare your seafood entries for compliance. Contact us today to speak with one of our seasoned professionals.
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[1] The list is non-exhaustive.
