I have read with interest in the past reports from the Stimson Centre, so I was interested to read their Assessment of the US SIMP in 4 countries. Yet this particular report was quite disappointing to read… not my opinion matter to them in any case. But if you gonna tackle a topic of importance like TREMs do it with impact.
Yeah.. is all legal! I entered the data my self in the website!
I’ve written a lot in the past about the US SIMP, and basically my main issue is that it relays completely on importers in the US to follow due diligence to provide that the compliance and traceability data entered by the seller is right and truthful. It does not involve AT ALL any flag, coastal, port or processing state authorities to verify the data been supplied… and this is total mistake… I actually co wrote a book for FAO in the roles of each for legality and compliance.
So here we have two parties that have a specific incentive in “not rocking the boat” and making the process flawless. So who is going to voluntarily report their fish is IUU?
They recognise that “Stimson researchers conducted research and interviews primarily focused on understanding the ability of NOAA, foreign governments, and seafood exporters to comply with and implement SIMP and to identify challenges that seafood exporters may be facing due to the new SIMP requirements”
Forget foreign governments from start, the US chose to ignore them all along, so they literally have no responsibility or legal obligation to be involved… as for NOAA… even if they were to come and do audits (none published yet)… under which authority would be doing that?
The ultimate test to see if import control measures for IUU fishing are working is to see if there is a reduction in the volumes of imports… anything else is just words. Interestingly not even the EU CCS passed that test.
Of the recommendations, the only useful I found are:
Paper documentation continues to be utilized across these countries, which can lead to significant falsification challenges. As such, the US Government should more broadly support the creation of electronic and digital traceability systems. Paper import records should be phased out with a mandate for an electronic and digital traced system for all SIMP seafood imports.
The US Government should increase the number of SIMP audits and auditors available to conduct reviews. NOAA should develop a dedicated a group to conduct the SIMP audits for both verification and training purposes. The importer of record is responsible for tracking seafood along the supply chain for SIMP. Despite the private sector’s responsibility for SIMP, foreign governments play a key role in verifying some of the documentation required by SIMP auditors. These documents play a critical role in ensuring that fisheries are managed effectively and IUU caught fish does not enter the US market. Therefore, it is critical that the US Government have enough auditors to verify compliance and work with partner governments to ensure document validity.
The US Government and its auditors should increase the number of technical workshops in target countries, which could focus on sharing trends for non-compliance, specific areas to improve traceability within the target country, and provide regular guidance to low-capacity governments. Furthermore, these technical workshops should include SIMP auditors so that they can better understand what true and accurate documents from each country should look like.
NOAA should share public information on the status of compliance with SIMP as this will assist in capacity building efforts from the NGO and foundation community.
Yet this one is the one that puzzles me: Stimson’s research revealed that SIMP assumes a level of capacity and oversight by governments in verifying documents that are passed along in the supply chain. Well… SIMP does not really include the government organizations on the picture, not of the need of certification as to be able to crosscheck the legality of those documents they are sending to the importer… so what you expect?
Yet I totally agree with these ones:
As the US Government considers expanding SIMP to all species, there needs to be a full and critical assessment of the existing system …a serious assessment of the SIMP program is needed to ensure it is effective.
For me, SIMP is just another missed opportunity and an example of a country doing something based on the perceived need to do something, but not on making a real gamechanger.