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Trusted Trader Program Proposed for Seafood Imports

Friday, January 19, 2018
Sandler, Travis & Rosenberg Trade Report

The Department of Commerce is proposing a Commerce Trusted Trader Program as part of a seafood traceability process designed to combat illegal, unreported, and unregulated fishing and seafood fraud. DOC states that qualified importers that choose to participate in the CTTP would benefit from reduced reporting and recordkeeping requirements as well as streamlined entry of seafood imports subject to the Seafood Import Monitoring Program. Comments on this proposal are due no later than March 19.

Under this proposed rule, a CTT would be required to establish a secure supply chain (free of IUU fish or fish product and falsely labeled seafood product) and maintain, either directly or through a third party, the records necessary to verify the legality of all seafood products subject to SIMP that the CTT enters into U.S. commerce. Compliance with these requirements would replace the SIMP requirement to enter harvest event data into the International Trade Data System at the time of entry filing and would provide increased flexibility for complying with SIMP recordkeeping requirements.

The CTT would be expected to produce all traceability documentation associated with an entry filing subject to the SIMP within 14 days of a DOC request to support an audit and to make such documentation available for inspection. However, the CTT would have significantly reduced reporting requirements for imports of SIMP species. With the exception of any records or documents required by other state or federal programs, such as the Tuna Tracking and Verification Program or the Food and Drug Administration’s prior notice of imported food, the CTT would only be required to enter its international fisheries trade permit number and species codes into ITDS at the time of entry filing.

DOC is seeking comment on the possibility of establishing a species-specific CTTP. The proposed rule would allow a CTT to import all species subject to SIMP and benefit from reduced reporting requirements at the time of import. As an alternative, an applicant for CTT status could specify that it has a secure and controlled supply chain for some, but not all, SIMP species and request that CTT status be limited to that subset. Under this alternative, a CTT would be required to comply with all SIMP reporting and recordkeeping requirements for imports of SIMP species not specifically included in its compliance plan.

The proposed rule would establish the qualifying criteria and application procedures for approval as a CTT. It would also establish requirements for a trusted trader compliance plan, recordkeeping, and third-party audits for CTTP participants.

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