2017-10 - USA: New requirements for the export of some fish species to the USA

Date of issue: 1 December 2017
Date of effect: 1 January 2018

Attention:

  • Seafood Export Consultative Committee
  • Export establishments (including vessels) preparing fish and fish products for export to the USA
  • Licensed exporters
  • Seafood Trade Advisory Group
  • Department of Agriculture and Water Resources—Central and Regional offices

Purpose

To notify exporters of advice from the United States National Oceanic and Atmospheric Administration (NOAA Fisheries) of new requirements for documentation when exporting some species of fish to the USA.

Summary of key points

  • The United States of America (USA) has implemented a Seafood Import Monitoring Program (SIM) to be administered by NOAA Fisheries to curb Illegal, Unreported and Unregulated (IUU) fishing practices and identify misrepresented seafood imports before they enter the US Market.
  • The SIM program requires importers to provide information and maintain records about the harvest, landing and chain of custody of imported fish and fish products for certain priority species identified as especially vulnerable to IUU fishing and seafood fraud.
  • As of 1 January 2018, exports of some species of fish to the USA will need to be accompanied by additional information to enable importers to report and maintain the required records.
  • This additional information is required for some but not all products prepared from priority species and includes live, chilled, frozen and some highly processed products but not all (i.e. canned tuna is included but not fish oil, fish cakes or fish balls prepared from tuna).
  • Of the priority species included in the SIM program, the species listed are fished from Australian waters and additional information will be required to be provided to gain entry of product to the US:
    • Tunas: Albacore, Bigeye, Skipjack, Yellowfin and Bluefin
    • Sea Cucumbers (all species)
    • Swordfish Xiphias gladius
    • Dolphinfish (Mahi Mahi) Coryphaena spp.
    • Groupers (Rockcods and Coral Trouts)
    • Snappers (Lutjanidae)
    • Sharks (all species)
  • The species listed are not fished from Australian waters and additional information will only be required if imported into and used in Australia to prepare chilled, frozen dried, salted or smoked fish products for export to the US:
    • Atlantic Cod / Pacific Cod / Northern Cods (Gadus spp. including G. morhua, G. ogac, G. microcephalus)
    • Atlantic Blue Crabs (Callinectes spp. including C. apidus)
    • Red King Crabs (Paralithodes spp. including P. camtschaticus)
    • Red Snapper (Lutjanus campechanus)

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If not all fish species or fish products are included, how do I know if I need to provide additional information?

Exporters are strongly encouraged to confirm the requirement for additional information with their importers. A table of priority species fished in Australia as identified in EXDOC including the corresponding 3-Alpha species codes required by US importers is provided at Attachment 1. A full list of priority species is available at IUU Fishing and Seafood Fraud Web Portal.

What additional information is required and when do I need to provide it?

There are two parts to the information that needs to be provided to the importer or broker:

  1. Harvest and landing information that must be provided to the importer so it can be reported electronically at the time of import. Examples of this information are provided as Attachments 2 and 3.
  2. Further chain of custody / traceability records that must be provided to the importer and retained by them for two years. These records are subject to audit by NOAA Fisheries. Examples of this information are provided as Attachments 4 and 5.

Do I need to use the forms provided as attachments?

No, the forms at Attachments 2 through 5 are based on examples provided by NOAA and used here to illustrate the types of information required to be provided. You can use your existing documentation if it includes all required information, revise your existing documentation or create your own documents or processes for providing the required information to your importer.

How do I obtain information about the harvesting or transhipment of the fish that I receive and process?

Not all exporters or processors are involved in the fish supply chain from the point of harvest or capture through processing to export. If you are receiving fish that you may process for export to the US you will need to obtain the required information from your suppliers. Attachments 1 and 2 will assist you in identifying any additional information required to be obtained.

Will fish from every harvest or catch need to be segregated through processing and shipment?

No, while information about each harvest and each unload of catch is required to be reported separately, processed product can be comprised of fish from more than one harvest or unload.

Each harvest or landing of catch is to be identified by a unique catch document number. This number may be an existing unique number (i.e. vessel log book number, transfer certificate number) or one used by the initial purchaser.

Product processed from combined harvests or unloads is required to identify the source of the products processed by documenting the catch document numbers that contributed to the processed lot. The quantity contributed from each individual harvest or unload is not required.

This information is required as of 1 January 2018, when should I start collecting information?

If you intend to export product to the US after 1 January 2018 that has been prepared from product being harvested or processed prior to that date – you should start to obtain records in preparation for export from your harvesters, processors and shippers.

I already collect this information for fish I export to the EU, how is this different? Can I use the same forms?

The EU require copies of Catch Certificates signed by the State or Commonwealth authority responsible for managing the fishery applicable to the fish for export. The US requirements are essentially the same, but it is the information that is required, not a document verified by a specified authority.

The majority of information required for export of fish to the EU is the same as for the US, with the exception of the US requirement to provide details of the fishing gear used to wild harvest (see table at Attachment 2.). If this additional information is added to existing EU documentation – the same document can be used to identify harvest vessels.

Is there anything else I need to do?

Much of the responsibility for reporting and retaining information under the SIM Program sits with the importer or their broker who will enter the information you provide into the International Trade Data System (ITDS). To access this system, your importer needs to hold a current International Fisheries Trade Permit (IFTP). As these permits are only available to US residents – this may be via a Broker or agent.

It is strongly suggested that you contact your importer prior to 1 January 2018 to confirm their access to the system and the form in which you will be providing the required information.

Attachments

The attachments are provided to assist in identifying and meeting requirements for providing the required additional information.

Templates are examples only and exporters are encouraged to combine or modify to meet the recording needs of their specific fish products.

Identifying priority species, product types and associated species codes

Attachment 1: Table of EXDOC Product Codes and FAO 3-Alpha species codes

This table can be used to identify fish products that require additional information to be provided to the importer and the associated species codes. As many of the fish species identified by the US as priority species are not exported from Australia, only fish products available through the department’s EXDOC system have been identified.

Information required to be collected when landing or harvesting priority species that may undergo primary or secondary reprocessing for export to the US

Attachment 2: Catch Certificate for Traceability – Harvest and landing receipt

This form may be completed for all catches of priority species that may be exported to the US when sourced from an aquaculture facility or a single vessel unloading to shore or a dock.

Attachment 3: Aggregated Catch Certificate for Traceability – Harvest and landing receipt

This form may be completed when unloads from multiple vessels that are all less than 12 metres in length or less than 20 gross tons in weight are consolidated on landing to shore.

Can also be used for aquaculture product received at a single collection point in a single day from multiple small scale aquaculture facilities when each facility delivers less than 1000 kilograms in total on that day.

Note: if multiple small vessels unload to a single larger vessel which then unloads to shore, this is recorded on the form at Attachment 2.

Information to be collected when processing landed or harvested fish for export to the US

Attachment 4: Reprocessing Certificate for Traceability – Primary or secondary processing

This form may be completed when packing or processing landed or harvested fish for export to the US. Received lots can be mingled during processing but input must be identified by the Catch Document Identifiers unique to each harvest event.

Information to be collected when fish for export to the US are stored or transhipped by vessel prior to or following harvest or unload.

Attachment 5: Transhipping Certificate for Traceability

Background

The U.S. will use the existing International Trade Data System to collect seafood catch and landing documentation for the priority seafood species. This data system is the U.S. government’s data portal for all imports and exports. Information collected through this program is confidential and will not be available to consumers.

January 1 2018, is the mandatory compliance date for most priority species listed in the rule. Due to gaps in availability of information regarding U.S. farmed shrimp and abalone, implementation for these species will be effective at a later date.

For additional information see Seafood Import Monitoring Program

Further information

Contact Dairy Eggs Fish if you have any queries.

The information provided in this advice is current at the time of writing and is intended for use as guidance only and should not be taken as definitive or exhaustive. The Commonwealth endeavours to keep information current and accurate, however, it may be subject to change without notice. Exporters are encouraged to verify these details with their importers prior to undertaking production/exports. The Commonwealth will not accept liability for any loss resulting from reliance on information contained in this notice.

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Attachment 1

Product types included:

Tunas—Chilled, frozen, whole, headed and gutted, gilled and gutted, portions, in airtight containers (foil, flexible or other), in oil or not in oil
Sea Cucumbers—Live, chilled, frozen, salted, dried or in brine
Swordfish, Mahi Mahi, Snappers & Groupers—Chilled, frozen, whole, headed and gutted, gilled and gutted, portions, fillets
Sharks—Chilled, frozen, whole, headed and gutted, gilled and gutted, portions, fillets – includes fins

EXDOC Product Type

Fish name

Scientific name

3-Alpha code

ALB

Tuna - Albacore

Thunnus alalunga

ALB

TNB

Tuna - Bigeye

Thunnus obesus

BET

NBT

Tuna - Northern Bluefin

Thunnus orientalis

PBF

TSB

Tuna - Southern Bluefin

Thunnus maccoyii

SBF

TNS

Tuna - Skipjack

Katsuwonus pelamis

SKJ

TNY

Tuna - Yellowfin

Thunus albacares

YFT

FBD / IMP

Tuna, processed

Thunnini

TUN

SWF

Swordfish

Xiphias gladius

SWO

MAH

Mahi Mahi

Coryphaena hippurus

DOL

SEP

Snapper - Tropical

Lutjanidae spp.

SNX

GSN

Snapper Golden

Lutjanus johnii

SNX

CSP

Snapper - Crimson

Lutjanus erythropterus

SNX

MSP

Snapper - Moses'

Lutjanus russelli & Lutjanus sp.

SNX

SSP

Snapper - Stripey

Lutjanus carponotatus

SNX

SES

Snapper - Saddletail

Lutjanus malabaricus

SNX

EPR

Emperor - Red

Lutjanus sebae

SNX

RDS

Red Bass

Lutjanus bohar

SNX

BDM

Sea Cucumbers

Species of families Holothuriidae

WBX

BDM

Sea Cucumbers

Species of families Stichopodedae

CUX

BWR

Deepwater Redfish (Sea Cucumber)

Actinopyga echinites

KUE

BSF

Stonefish (Sea Cucumber)

Actinopyga lecanora

YVV

BDU

Surf Redfish (Sea Cucumber)

Actinopyga mauritiana

KUY

BBB

Blackfish (Sea Cucumber)

Actinopyga miliaris

KUQ

BBF

Burrowing Blackfish (Sea cucumber)

Actinopyga spinea

YGS

BTF

Leopardfish (Sea Cucumber)

Bohadschia argus

KUW

BBS

Brown Sandfish (Sea Cucumber)

Bohadschia vitiensis

BDV

BCH

Chalkfish (Sea Cucumber)

Bohadschia marmorata

KUH

BDB

Oval Blackfish (Sea cucumber)

Cucumaria frondosa

KHG

BDL

Lollyfish (Sea Cucumber)

Holothuria atra

HFA

BBP

Pinkfish (Sea Cucumber)

Holothuria edulis

HFE

BDW

White Teatfish (Sea Cucumber)

Holothuria fuscogilva

HFF

BET

Elephants' Trunkfish (Sea Cucumber)

Holothuria fuscopunctata

HOZ

BDG

Golden Sandfish (Sea Cucumber)

Holothuria lessoni

JCO

BDS

Sandfish (Sea Cucumber)

Holothuria scabra

HFC

BDA

Black Teatfish (Sea cucumber)

Holothuria whitmaei

JDG

BLF

Blackspotted Sea Cucumber

Pearsonothuria graeffei

EHV

BGF

Greenfish (Sea Cucumber)

Stichopus chloronotus

JCC

BCU

Curryfish (Sea cucumber)

Stichopus herrmanni

JNG

BDP

Prickly Redfish (Sea Cucumber)

Thelenota ananas

TFQ

BAM

Amberfish (Sea Cucumber)

Thelenota anax

HLX

BBC

Deepwater Blackfish (Sea Cucumber)

Actinopyga palauensis

YGP

BRC

Rockcod - Bar

Epinephelus spp.

Refer to species list at: www.iuufishing.noaa.gov

BWC

Rockcod - Birdwire

Epinephelus merra

EER

BTC

Rockcod - Blacktip

Epinephelus fasciatus

EEA

ERC

Rockcod - Goldspotted

Epinephelus coioides

ENI

HRC

Rockcod - Longfin

Epinephelus quoyanus

EFQ

MRC

Rockcod - Maori

Epinephelus undulatostriatus

EIU

YSR

Rockcod - Yellowspotted

Epinephelus areolatus

EPR

CTR

Trout - Coral

Plectropomus & Variola spp.

Refer to species list at: www.iuufishing.noaa.gov

RCC

Rockcod

Aethaloperca, Anyperodon spp.

Refer to species list at: www.iuufishing.noaa.gov

SHK

Shark

Chondricthyes

Refer to species list at: www.iuufishing.noaa.gov

Attachment 2

The information in this form is required to be provided to the importer to enable entry of exported product into the US. It is intended to provide details of the unique harvest event that provided the raw materials of the fish product being exported and is required for fish products prepared at registered establishments in Australia, including products prepared from imported fish of priority species.

Model Catch Certificate for Traceability - Harvest and landing/receipt

(1) Unique Catch or Production Document Identifier
(Unique number used to identify the harvest event)

(  ) Wild capture fishery (Complete section 2)
(  ) Farm raised (Complete section 3)

(2) Complete this section for wild capture fish products

Flag State of vessel:
(Country where vessel is registered)

Name of harvesting vessel

Vessel registration or documentation number: (IMO/Lloyd’s no. or radio call sign or AMSA 6 digit registration no.*)

Fishing permit number:
(Fishing licence no. issued by the relevant local authority)

Fishing/catch area:
(Catch area code as reported to local authority – or FAO zone**)

Fishing gear:
(Gear code as reported to local authority or FAO gear code***)

(3) Complete this section for farm raised fish products

State of jurisdiction:

Facility License or Authorisation:
(Aquaculture licence no. issued by the relevant local authority)

Name & location of aquaculture facility:

(4) Complete this section for receipt of fish products

Name of recipient, processor or buyer:

Telephone:
Email:

Business address

Receiving facility or vessel:

Date of landing/transhipment:

Landing port or delivery location:

Species of fish (ASFIS 3-Alpha code)
(See Attachment 1)

Landed or delivered weight (kg)

Product form (i.e. whole, H&G, G&G, fillets)

1

 

 

2

 

 

* In Australia this will be the IMO/Lloyd’s number or International Radio call sign or 6-digit registration number as per the AMSA register
** FAO Major Fishing Areas for Statistical Purposes
*** Table 6.3.3 Databases and Data Management

Attachment 3

The information in this form is required to be provided to the importer to enable entry of exported product into the US. It is intended to provide details of the unique harvest event that consolidated the raw materials of the fish product being exported and is required for fish products prepared at registered establishments in Australia, including products prepared from imported fish of priority species.

Aggregated Catch Certificate for Traceability - Harvest and landing/receipt
Only for small-scale harvest events: vessels ≤20 measured gross tons or ≤12 meters length, or aquaculture facilities deliveries ≤1,000 kg

(1) Unique Catch or Production Document Identifier
(Single unique number used to identify the consolidating harvest event)

(  ) Wild capture fishery (Complete section 2)
(  ) Farm raised (Complete section 3)

(2) Complete this section for wild capture fish products

Flag State of vessels:
(Country where vessels are registered)

No. of deliveries:

Fishing/catch area:
(Catch area codes as reported to local authority – or FAO zone**)

Fishing gear: (Gear code as reported to local authority or FAO gear code***)

(3) Complete this section for farm raised fish products

State of jurisdiction:

Facility license or authorisations:
(Aquaculture licence no. issued by the relevant local authority)

Names and locations of aquaculture facilities

(4) Complete this section for receipt of fish products

Name of recipient, processor or buyer:

Telephone:
Email:

Business address:

Receiving facility or vessel:
(If vessel include name, flag state and identifier*)

Date of landing/transhipment:

Landing port or delivery location:

Species of fish (ASFIS 3-Alpha code)
(See Attachment 1)

Landed or delivered weight (kg): (Total weight of consolidated harvest event)

Product forms (i.e. whole, H&G, G&G, fillets):

1

 

 

 

2

 

 

 

* In Australia this will be the IMO/Lloyd’s number or International Radio call sign or 6-digit registration number as per the AMSA register
** FAO Major Fishing Areas for Statistical Purposes
*** Table 6.3.3 Databases and Data Management

Attachment 4

The information in this form is required to be provided to the importer for their records. It is intended to provide details of the unique harvest event/s that contributed the raw materials of the fish product being exported and is required for fish products prepared at registered establishments in Australia, including products prepared from imported fish of priority species.

Reprocessing Certificate for Traceability - Primary or secondary processing

(  ) Wild harvest or (  ) Farm raised

Referenced Unique Catch Document Identifier(s)
(Unique numbers used to identify the harvest events that contributed fish to this export lot)

Company product received from:

Processor name

Processor address

Processor approval or registration number

Phone:
Email:

Commodity scientific name
(See Attachment 1)

Commodity market name
(See Attachment 1)

Species of fish (ASFIS 3-Alpha code)
(See Attachment 1)

Received weight (kgs):
(Total weight of input to production of this export lot)

Received lot identifier(s):

Received product forms (e.g. whole, H&G, G&G, fillets):

Processed weight (kgs):

Finished product lot identifier(s):

Finished product form (e.g. G&G, fillets, cans, pouches):

Finished product weight (kgs):

Production date(s):

 

No. of packages:

Type of packaging:

Attachment 5

The information in this form is required to be provided to the importer for their records. It is intended to provide details of any transhipment related to the harvest event/s that contributed the raw materials of the fish product being exported or the fish products to be exported following processing and is required for fish products prepared at registered establishments in Australia, including products prepared from imported fish of priority species.

Transhipping Certificate for Traceability

( ) Wild harvest or ( ) Farm raised

Referenced Unique Catch Document Identifier(s):
(Unique numbers used to identify the harvest events)

Port or storage location of loading/unloading:

Name of vessel/cold storage unloaded from:

Unique Unloaded Vessel Identifier (registration, documentation, or license number): (IMO/Lloyd’s no. or radio call sign or AMSA 6 digit registration no.*)

Date(s) of unloading/loading:

Name of vessel/cold storage loaded to:

 

Unique Receiving Vessel Identifier (registration, documentation, or license number): (IMO/Lloyd’s no. or radio call sign or AMSA 6 digit registration no.*)

Commodity scientific name:
(See Attachment 1)

Commodity market name:
(See Attachment 1)

Species of fish (ASFIS 3-Alpha code)
(See Attachment 1)

Transhipped weight (kgs)

Transhipped lot identifier(s):

Transhipped product form (i.e. whole, H&G, G&G, fillets, cans):

Production / harvest date(s):

Number of packages:

 

Type of packaging:

* In Australia this will be the IMO/Lloyd’s number or International Radio call sign or 6-digit registration number as per the AMSA register

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