Trade Groups Warn of Participation Costs in Seafood Trusted Trader Program; Others Want Forced Labor Protections
Participation in the upcoming Commerce Trusted Trader Program for seafood importers could be more costly than the National Marine Fisheries Service purports, trade groups told the agency in recent comments. Contrary to estimates in a January proposed rule on CTTP, compliance plans that would be required for membership in the program “could be highly complicated to develop, and it would require extensive review, clearance, or internal sign-off before submission to NMFS,” the Pacific Seafood Processors Association said.
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“The cost estimates associated with the proposed CTTP are woefully underestimated,” the National Fisheries Institute said in comments on the proposal. “The agency has estimated that a Compliance Plan can be developed from “square one” in less than 24 hours. It is questionable whether or not this time estimate is only for the time necessary to take pen to paper to document the Compliance Plan and not the time necessary for actual development and implementation,” the NFI said. Costs could be especially burdensome for larger suppliers that deal with multiple species and suppliers, it said.
NMFS should consider additional program benefits to counter some of the costs associated with participation, the NFI said. CTTP participants will still be subject to NMFS’s Seafood Import Monitoring Program, and “TTP participants must still collect and hold every data element and supporting custodial document in precisely the same way those companies would had they not joined the CTTP,” it said. “NMFS should consider providing CTTP participants in the final rulemaking with additional relief from SIMP requirements. Otherwise, the agency risks placing significant resources and time in a proposal that ultimately will attract no more than modest industry interest,” the trade group said.
On the other hand, environmental and other advocacy groups called on the NMFS to add new requirements to the program related to forced labor. “We strongly urge NOAA to require that ‘Trusted supply chain’ companies should have due diligence procedures to verify that labor is voluntary, and not associated with human trafficking, child, forced, bonded or indentured labor,” FishWise said in its comments. “Those willing to risk engaging in one form of illegal activity might risk engaging in more than one. There are examples of [illegal, unreported and unregulated] IUU fishing and human rights violations happening at the same time,” it said.
Global demand for cheap seafood and depleted seafood stocks have resulted in the “widespread” use of forced labor in the seafood supply chain, the Center for American Progress said. As fishing boat owners must go further from shore to find fish, one way to cut costs is through use of forced labor and human trafficking, it said. “Fishing in waters further from shore also makes it more difficult for states with limited enforcement capacities to detect and act against labor abuses.” In particular, “a significant portion of imported shrimp consumed in the United States comes from countries with known occurrences of human trafficking,” the group said.