U.S. Imports of Fish and Seafood

The United States (U.S.) is the world’s largest single-country importer of seafood by value, importing $25 billion in seafood in 2024. Globally, up to a third of seafood is caught through illegal, unreported, and unregulated (IUU) fishing, with an estimated annual value between $15.5 and $36.4 billion. The complexity and opacity of global seafood supply chains enable misrepresentation and fraud, particularly through the substitution of visually similar “close-substitute” species. The U.S. is likely importing some share of illegal seafood; the U.S. International Trade Commission estimated that 11% ($2.4 billion) of U.S. seafood imports in 2019 were derived from IUU fishing. IUU fishing degrades fish stocks around the world, distorts global seafood trade and U.S. markets, suppresses income for regulated domestic producers, undermines trade enforcement credibility, enables transnational criminal networks, and weakens U.S. leverage in global supply chains where the U.S. is structurally import-dependent. To prevent IUU-harvested and fraudulently labeled fish and seafood from entering the United States, National Oceanic and Atmospheric Administration (NOAA) Fisheries established the Seafood Import Monitoring Program (SIMP) in 2016.

SIMP currently applies to 13 species groups. In 2024, U.S. importers brought fish and seafood into the United States under 618 separate 10-digit Harmonized Tariff Schedule (HTS) codes, only 138 of which qualified to trigger SIMP reporting and recordkeeping requirements; together, these SIMP-listed codes accounted for approximately 39% of the total value of U.S. seafood imports. The percentage of species groups covered by SIMP varies drastically on a country-by-country basis. For example, despite China being identified as one of the worst actors for IUU fishing by the IUU Fishing Risk Index, only 22% of U.S. fish and seafood imports from China were covered by SIMP in 2024. 

Purpose and Approach

This study evaluates the coverage of U.S. seafood imports under SIMP to determine whether the program is adequate for the 13 currently listed target species. By summarizing the value of individual HTS codes covering U.S. imports of fish and seafood and analyzing the data in the aggregate and at the individual product level, the analysis assesses how SIMP coverage currently operates in practice. The research reviews 2024 import data for SIMP-listed species and their potential close substitutes; examines gaps, limitations, and loopholes in SIMP’s tariff code and species framework; and evaluates the extent to which claims of close-substitute species may be used to bypass SIMP requirements.

This study uses six SIMP-listed species or species groups as case studies—Atlantic cod, Pacific cod, Atlantic blue crab, red king crab, northern red snapper, and tuna—to examine how the present scope of SIMP applies in theory and in practice across different product forms and species groupings. The U.S. imported seafood from 151 countries in 2024, and this study also briefly considers country-level dynamics. The broader aim of this analysis is to provide an accurate assessment of current SIMP coverage so that future policy discussions and procedural mechanisms for expansion are grounded in a clear understanding of where gaps and loopholes persist.

Key Findings

• SIMP’s reliance on a two-criteria trigger limits effective coverage: SIMP presently relies on a two-criteria trigger; both a SIMP-listed HTS code and a SIMP-listed species declaration must be present for SIMP reporting to be required. This structure creates clear loopholes when HTS codes are not species-specific or when they cover multiple species and product forms, which can be exploited by importers to bypass SIMP requirements.

• Close substitutes pose a significant and largely unaddressed risk: Across most case studies, imports of close-substitute species account for a substantial share of trade but are largely not covered by SIMP, creating strong incentives and opportunities for species mislabeling and evasion.

• Product form exclusions undermine SIMP’s effectiveness: HTS codes covering certain product forms—most notably, a catch-all, multi-species HTS code for “frozen fish fillets, not elsewhere specified or indicated”—are excluded from SIMP coverage, despite being a common import and retail product form that may include SIMP-listed species.

• Partial species coverage creates incentives and opportunities for evasion: IUU fishing and seafood fraud extend well beyond the 13 species covered by SIMP and commingling of seafood is routine in global seafood supply chains. With SIMP applying to only a subset of species and product forms, importers can inadvertently or intentionally misdeclare species or use alternative HTS codes to avoid requirements. Present partial coverage means that NOAA should not only be analyzing the incoming SIMP data, but should be carefully tracking shifts between SIMP and non-SIMP-listed HTS codes and species in order to identify changes in how importers are classifying U.S. imports of seafood. 

Recommendations

The following recommendations outline a path forward to close the gaps and loopholes in current SIMP coverage and to expand the program so that IUU-harvested and/or misrepresented seafood can be effectively prevented from entering U.S. commerce:

• Expand SIMP to cover all seafood species: Expanding SIMP to cover all seafood species is necessary for the U.S. government to effectively and accurately monitor seafood imports and prevent IUU fishing and seafood fraud from entering U.S. commerce. Partial species coverage creates both inadvertent and intentional pathways for IUU-harvested and/or misrepresented seafood to continue entering the U.S. market. The most effective way to achieve full species coverage under SIMP is to require reporting and recordkeeping for all HTS codes covering fish and seafood products—broadly defined as all products in Chapter 3 and those products in Chapter 16 under headings 1604 and 1605. Full expansion could be approached in different ways, including stepwise application.

• Increase taxonomic specificity in HS and HTS codes: Expanding SIMP to all U.S. imports of fish and seafood should not replace the need for greater taxonomic specificity in global Harmonized System (HS) codes and local, more detailed, country-specific HTS codes. Additional specificity would improve U.S. enforcement of existing SIMP provisions, provide clearer guidance to traders, support transparency for U.S. consumers, and be a more consistent basis for effective SIMP expansion.

• Improve transparency through public-facing SIMP data dashboards: NOAA Fisheries should develop public-facing dashboards that communicate aggregated SIMP data, while protecting business confidential information, and better explain and enhance how SIMP data support targeting and enforcement. Publishing aggregated summaries by SIMP key data elements would provide valuable information for U.S. industry and traders and would potentially assist in exposing and enforcing SIMP violations.

Given that the United States is the world’s largest importer of seafood, U.S. leadership in addressing IUU fishing and seafood fraud is critical to leveling the playing field for U.S. competitiveness, while also sending a strong signal on the importance of regulatory compliance, environmental stewardship, and labor standards. SIMP’s initial framework was an important step forward. However, NOAA Fisheries’ 2024 SIMP Action Plan and the findings of this study make clear that coverage of the initial 13 SIMP-listed target species (or species groups) is likely allowing significant amounts of already-covered products to escape proper reporting and recordkeeping scrutiny while also disregarding other high-risk species and products entirely. Closing existing loopholes and expanding SIMP coverage will require sustained collaboration among government, industry, and non-governmental organizations in a manner that is practical, enforceable, and non-disruptive to legitimate trade, while still achieving the program’s core objective of preventing IUU-harvested and/or misrepresented seafood from entering U.S. commerce. Strong U.S. action to protect fair trade in seafood imports is an important complement to steps to maintain the viability of U.S. domestic fisheries and production.