Has the US ban on Russian seafood stopped Putin’s pollock from entering the United States?
Global seafood trade is big business, accounting for more than $140 billion each year.  Commercial fishing has a complex supply chain and over 56 million people work on vessels to support it. The United States is the second largest importer of seafood in the world behind Europe, and the demand is greater than ever. In 2022, the U.S. imported approximately 85 percent of its seafood, valued at just over $30 billion.  Roughly 40 percent of the U.S. seafood imports are caught in American waters yet processed overseas, predominately in China, and then re-imported back into the United States. Groundbreaking reporting by the Outlaw Ocean Project found that some of this seafood is processed using Uyghur forced labor.  
At the same time, Russian seafood exports to the U.S. have been growing steadily.  Dating back to 2014, Russian seafood exports grew by 173 percent.  In 2021, Russia exported $1.2 billion worth of crab, cod, pollock, salmon, and other fish into the United States.   
That trajectory started to falter when Russia invaded Ukraine. In March 2022, the Biden Administration issued U.S. Executive Order 14068 banning the import of Russian-caught seafood. However, despite the good intentions to send a clear message that Putin’s pollock was not welcome in the U.S., Russian seafood continued to enter our markets. As a result, American consumers have unwittingly funded Russian atrocities in Ukraine.  
Undermining the ban is a major loophole in the U.S. Country of Origin Labeling (COOL) Act, wherein seafood products are labeled as products of the country where it is last processed or altered. As a result, Russian-caught fish that is processed in China becomes a product of China – essentially masking its real origin when it is imported into the U.S. Further, Russian catch is often processed alongside U.S.-harvested fish and can be co-mingled and processed together into fish blocks, fish sticks, canned salmon, or frozen fillets. These products are sent back to the U.S. and purchased by wholesalers, grocery stores, the U.S. military, and even school lunch programs. 
To address this ongoing concern that hides the true origin of seafood, in December the Biden Administration issued a second executive order, U.S. Executive Order 14068, to immediately prohibit the importation of seafood “harvested in Russian waters or by Russia-flagged vessels, even if these products are then transformed in a third country.”  The U.S. Department of Treasury and the Bureau of Customs and Border Protection will administer the ban to prohibit entry of Russian salmon, cod, pollock, and crab products. Currently pre-purchased banned items are still allowed to enter the U.S. market until May 31, 2024.
Recent trade data shows that China imported more Russian crab last year than ever before. According to one seafood consultant, China imported 40.9 million metric tons of crab in 2023 – a 75 percent increase in volume compared to 2022.
The question persists: did China continue to export this increase of Russian seafood to the US using the COOL Act loophole, or was Russian seafood sold to China for their own domestic market? Some seafood trade experts suggest that China is paying the Russians far less for their seafood than the U.S. had previously paid. At the same time, American seafood importers have started to include a self-certification letter attesting that their product is not of Russian origin as part of their import documentation.  This could be an early sign indicating the ban is starting to work.  
In addition to banning specific Russian seafood, closing the loophole in the COOL act, and importers attesting their seafood is not from Russia, a more sweeping and long-term fix exists. The U.S. government could also implement a comprehensive traceability-based import control system that tracks all seafood and ensures that it is not a product of forced labor or supporting malign state actors such as Russia. A comprehensive traceability-based seafood import control program could also address illegal, unregulated, and unreported (IUU) fishing – a pervasive global threat.
IUU fishing harms the economic, food, and environmental security of coastal communities, destabilizes the security of maritime states, supports organized criminal networks, fuels corruption, distorts markets, and drives human trafficking and labor and human rights abuses in the fishing industry. It also undermines the rule of law, good governance, and law-abiding fishers’ trust in authorities.
This is not a trivial concern, the International Trade Commission estimated that $2.4 billion worth of IUU-caught products entered the U.S. market in 2019 alone
Although the U.S. National Oceanic and Atmospheric Administration (NOAA) has implemented a limited seafood trade tracking system called the Seafood Import Monitoring Program (SIMP), it has been hampered by a lack of adequate funding and poor government management. SIMP was initially designed to detect, deter and prevent illegally harvested and fraudulently labeled seafood from entering the U.S. by tracing seafood from where it was harvested to entry into domestic commerce – or “bait to gate”. However, the program has not lived up to its potential. Now in operation for seven years, SIMP covers about 40-45% of U.S. seafood imports but excludes several high-risk species including Russian-caught fish such as pollock and salmon.
As more countries around the globe move to ban Russian seafood and implement seafood traceability systems, they are looking to the United States as a global leader. We can do much more to implement a functional seafood traceability-based import control program that is standardized, streamlined, and synchronized.
Against this complicated backdrop, we know one simple truth: American consumers – and consumers around the world – do not want to eat seafood that is caught illegally or is the product of forced labor, and certainly not Putin’s pollock, supporting the Russian war in Ukraine.
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