Collection of catch and landing documentation for certain fish and fish products will be accomplished through the government-wide International Trade Data System. The rule requires data to be reported on the harvest of fish and fish products. In addition, this rule requires retention of additional supply chain data by the importer of record and extends an existing National Marine Fisheries Service requirement to obtain an annually renewable International Fisheries Trade Permit to the fish and fish products regulated under this rule. The information to be reported and retained, as applicable, under this rule will help authorities verify that the fish or fish products were lawfully acquired by providing information to trace each import shipment back to the initial harvest event(s).
However, the rule is facing heavy challenges and adversity to its purpose as a few of the fishing industry’s biggest players including the National Fisheries Institute have sued the NOAA and Department of Commerce for placing what they say is an onerous and expensive burden on importers who already follow the rules.
In 2000, the Marine Stewardship Council (MSC) also developed a sustainable fishery standard and “Chain of Custody” traceability with certification that is applicable to the full supply chain from a MSC-certified fishery to final sale. In 2012, the Aquaculture Stewardship Council (ASC) developed a responsible aquaculture standard with the same traceability standard of MSC. Every company in the supply chain handling or selling of an MSC- or ASC-certified product must have a valid Chain of Custody certificate. This means that seafood sold with the MSC or ASC label can be traced back to the ocean or the aquaculture farm, giving buyers confidence in its origin and means of production.
Companies certified against the MSC-ASC Chain of Custody standard are audited regularly to ensure that they meet five traceability requirements: 1) seafood products can only be purchased from MSC-certified suppliers and from MSC-certified fisheries or ASC-certified farms; 2) MSC-certified seafood products must be identifiable; 3) MSC-certified seafood products must be segregated from non-MSC-certified seafood at each step of the supply chain; 4) MSC-certified seafood product volumes must be recorded; and 5) the MSC-certified organization must have a document management system. Each processor, storage, trader, and importer in the world who wants to use MSC or ASC label must be audited by accredited third-party certification body.
In addition, a new digital tracing technology called blockchain is on the rise and being tested in the seafood industry. Originally used to track the digital currency bitcoin, blockchain is a digital ledger in which transactions are recorded chronologically and publicly. New information cannot be removed or changed after it has been recorded. Blockchain aims to replace the severely outdated process of tracking seafood through tags and paper records by digitally tracking seafood across the supply chain.
The new blockchain approach allows fishermen to record their harvest (i.e. date, type of species, quantity, fishing area, fishing gear, name of vessel) and register their catch on the blockchain system. The data is then sent to the fish processor. When the fish are processed, packed, and stored, the processor records data to the blockchain system and forwards on to the next client in the chain until it reaches its final destination. The information on the origin and supply chain journey of the seafood can then be accessed and verified on smartphones used by retail buyers, restaurateurs, and consumers.
Label Verification Training
There is no universal seafood labeling system for grocery stores so buying fish products often requires a little diligence to ensure it is what it is. However, the FDA launched an online learning module to help food retailers ensure the proper labeling of seafood products offered for sale in the U.S. marketplace. Proper identification of seafood is important throughout the seafood supply chain to ensure that appropriate food safety controls are implemented and that consumers are getting the type of seafood they expect and for which they are paying.
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