Background

An executive order issued by President Biden in March 2022 banned imports of seafood of Russian origin. However, because such seafood has been processed into other products in other countries to bypass this restriction, Biden issued a new EO in December 2023 prohibiting imports of fish, seafood, and preparations thereof if they were mined, extracted, produced, or manufactured wholly or in part in Russia, harvested in waters under Russian jurisdiction, or harvested by Russia-flagged vessels, regardless of whether such products have been incorporated or substantially transformed into another product with a country of origin other than Russia.

In support of this order, effective Dec. 22, 2023, U.S. Customs and Border Protection is requiring importers to provide self-certification that imported fish, seafood, and seafood-containing products do not contain any inputs originating from Russia. This includes any seafood products or components from Russia that are processed in a third country before they are imported into the U.S.

In addition, for all entry and certified from summary transactions, as well as goods admitted into a foreign-trade zone, that include the affected commodities, purchase orders and/or executed contracts and/or any other documentation showing when the order and/or contract went into effect must be uploaded to the Automated Commercial Environment’s Document Image System. 

Acting CBP Commissioner Troy Miller said “importers of seafood need to do their part by practicing due diligence over their supply chains to ensure their products do not contain components originating from the Russian Federation.”

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