How to prevent illegal seafood imports

Lessons learned from across the globe

A toolkit for seafood importing states

What is a fisheries import control scheme?

Import control schemes (ICS) are regulatory systems implemented by market States that operate by requiring comprehensive catch documentation (e.g. through catch, trade, and other certificates) that trace seafood through the supply chain to ensure it has been caught and traded in accordance with applicable national, regional, and international laws, and management measures. Schemes are implemented by a single government authority, ideally covering all imported seafood species, or alternatively covering fewer but key commercially targeted species.

When well designed and implemented, fisheries import control schemes are market-based and government-driven tools that close markets to seafood products from illegal, unreported and unregulated (IUU) fishing.


Why do more states need an import control scheme?

With one in five seafood products caught by IUU fishing, it is highly likely that States are importing products tainted by IUU fishing and its associated crimes, such as forced, bonded, or slave labour. Therefore, ensuring these products do not enter market States is essential to protect food security globally and uphold decent working conditions.

By establishing a fisheries import control scheme, governments send a strong message to flag and exporting States that IUU fishing will no longer be tolerated and that products caught by IUU fishing will not enter their markets. An import control scheme can help to exclude and deter IUU-caught seafood from entering market States, making it less profitable and, in turn, safeguarding fish stocks, livelihoods, consumers, and marine biodiversity.

As multilateral schemes, implemented by Regional Fisheries Management Organisations (RFMOs), have stalled in recent years while unilateral ones have proliferated, expanded to cover more species, or recognised the need to improve performance, the aim of this Handbook is to provide technical guidance on establishing a unilateral import control schemes for wild-caught fisheries and assist policymakers in developing or improving such schemes.


It is estimated that 1 in every 5 fish caught comes from IUU fishing

...With a total cost to coastal nations between U.S. $10 billion and $23 billion a year

What are the benefits of a Fisheries Import Control Scheme?

- Exclusion of products linked to IUU fishing by increasing the likelihood of detecting illicit seafood before it enters the market.

- Sustainable resource management by using market access as a tool to drive regulatory improvements in fisheries management of exporting States.

- Disincentivisation of human and labour rights abuses that are heavily associated with IUU fishing by incorporating import controls that detect and deter these activities.

- Market integrity and growing consumer confidence by ensuring seafood products are true to their label and have been caught lawfully.

- Increased coordination and cooperation with partner states from the necessary information exchanges for effective import control schemes. (COPY)

"We have a zero-tolerance policy towards IUU fishing. It is not only about preventing illegal fishing activities, but also using market access towards this goal. Big market states like the EU, have significant leverage to impose rules of transparency on exporting countries."

Charlina Vitcheva
Director-General for Maritime Affairs and Fisheries, European Commission

Speaking at Our Ocean 2025

Countries are increasingly using unilateral catch documentation schemes for imported seafood

European Union

In 2008, the EU introduced the world’s first seafood import control scheme—the Catch Certification Scheme—through the adoption of the EU IUU Regulation. It covers all marine fish caught in the wild (with some exemptions) traded by non-EU countries into the EU market.

In January 2026, following the revision of the EU's fisheries control regulation, the data requirements in the EU's catch certificate were expanded. In addition, an IT System for the management of all procedures linked to the EU catch certification scheme was established, "IT CATCH".

CATCH is intended to improve the effectiveness of the EU IUU Regulation’s catch certification scheme by ensuring a centralised digital management environment with the objective to identify and prohibit importation into the EU of seafood caught through IUU fishing.

Use of CATCH will be mandatory for EU Member States and EU Importers from 10th January 2026. Use by non-EU countries will be on a voluntary basis.

United States of America

The US introduced its own import control scheme—the Seafood Import Monitoring Program—in 2016, covering 1,100 species within 13 species groups that were identified as most vulnerable to IUU fishing and seafood fraud.

Unlike the other global import control schemes, SIMP places importers as legally responsible for verifying import information and does not require the submission of catch data  prior to entry, meaning products enter the market before issues are detected.

In November 2024, NOAA Fisheries published an Action Plan to Improve the U.S. Seafood
Import Monitoring Program
.

This action plan aimed to expand SIMP traceability requirements to cover all U.S. seafood imports (as opposed to its current coverage of 1,100 species), and contribute to government-wide efforts to address forced labour in the global seafood supply chain, among other planned improvements.

While NOAA Fisheries intends to implement components of the SIMP Action Plan, it is currently unclear which elements of the action plan will be delayed or abandoned.

Japan

In 2022, Japan established a catch documentation scheme based on the EU’s system, prior to its revision. It currently covers seven species/species groups deemed the highest risk for IUU fishing: four imported species groups* and the domestic catch of three others.

* Squid, cuttlefish, pacific saucy, mackerel, and sardines. Squid and cuttlefish are collectively counted as one species group.

Following the first review of the Japanese system in September 2024, blue shark and shortfin mako shark were identified as candidate species for the first round of coverage expansion for imported species.

We encourage Japan to continue expanding species coverage following future reviews.

Republic of Korea

The Korean Ministry of Oceans and Fisheries (MOF) adopted a country-level CDS in 2017 targeting three species, namely bobo croaker, longneck croakers and Pacific saury.

Although the scheme still covers only three species, the data requirements were expanded in 2024 to meet the recommendations of the EU IUU Fishing Coalition.

We commend South Korea for its expanded data requirements and now encourage species expansion, particularly for species most vulnerable to IUU fishing, with a risk-based assessment.

United Kingdom

Following the UK's withdrawal from the EU, with a view to stemming the flow of seafood caught through IUU fishing to the UK market, the UK has retained the EU's catch certification scheme (under the UK IUU Regulation). This requires that all seafood consignments falling within the scope of the UK IUU Regulation be accompanied by a catch certificate validated by the flag State of the fishing vessel that caught the fish.

The Coalition for Fisheries Transparency is now calling on the UK Government to expand the data requirements within the UK catch certificate, digitise its catch cerficate scheme and ensure proper implementation of the UK IUU Regulation.

As catch documentation systems continue to emerge globally, it is crucial that they are harmonised and designed for interoperability

There is already a lack of harmonisation in terms of the species coverage and the data required within catch documentation

Markets with established or proposed ICS

EU

US

Japan

UK

Republic of Korea

Species covered by ICS

All wild-caught seafood species (with some exemptions)

1,100 species within 13 species groups*

5 species**

All wild-caught seafood species (with some exemptions)

3 species***

Key data element

Who

Vessel name

Required

Required

Required

Required

Required

Unique vessel identifier (IMO number)

Required from 1st January 2026

Conditional

Conditional

Conditional

Required

Vessel flag

Required

Required

Required

Required

Required

International Radio Call Sign (IRCS)

Required

Not Required

Conditional

Required

Required

Information on exporter / re-exporter

Required

Required

Required

Required

Required

Identity of import company

Required

Required

Required

Required

Required

What

Product type

Required

Required

Required

Required

Required

Species name - ASFIS 3-Alpha Code

Required

Required

Conditional

Required

Required

Estimated live weight (kg)

Required

Not Required

Required

Required

Required

Processed weight (kg)

Required

Required

Required

Required

Required

Transshipment: Declaration and authorisation of transshipment at sea, IMO number and vessel master information

Required

Conditional

Required

Required

Required

When

Event date

Required

Required

Required

Required

Required

Where

Catch area (defined with a clear distinction between the EEZ and the high seas)

Required from 1st January 2026

Required

Required

Not Required

Required

Authorisation to fish

Required

Conditional

Required

Required

Required

Port of landing

Required from 1st January 2026

Required

Not Required

Not Required

Required

Processing location

Required

Required

Required

Required

Required

How 

Fishing gear type or catch method

Required from 1st January 2026

Required

Conditional

Not Required

Required

*The US SIMP 13 species groups covered are abalone, Atlantic cod, blue crab, dolphinfish, grouper, king crab, Pacific cod, red snapper, sea cucumber, sharks, shrimp, swordfish, and tuna.

**Japan’s CDS covers squid, cuttlefish, pacific saury, mackerel, and sardines, and domestic catch of abalone, sea cucumber, and glass eel.

***The Republic of Korea’s CDS covers only three species: Pacific saury, bobo croaker, and longneck croaker.

Many large market states still lack catch documentation schemes to prevent the importation of illegal products

Including Australia

In 2023, the Australian government agreed to “consider a framework that addresses the importation of seafood from fisheries that involve IUU fishing practices.” This took the form of an iterative, multi-stakeholder consultation process led by the nation’s Department of Agriculture, Fisheries, and Forestry (DAFF). A final report detailing the outcome of the process – and the future of Australia’s seafood import framework – was due to be released in the first half of 2024.

On 11th November 2025, the Australian Government committed to  reviewing tariff code usage and to continue supporting anti-IUU fishing measures, domestically and internationally, but did not commit to a seafood traceability system.

Australian NGOs, fisheries stakeholders and the public are joining the international community in calling on the Government to act now, align Australia with global best practices and close its borders to products linked to IUU fishing.

And Canada

In 2019, the government announced its intention to improve seafood traceability in Canada, then held multi-stakeholder consultations from 2020 to 2021, and established an intergovernmental task force on seafood traceability.

However, these efforts have not resulted in any tangible action towards stronger import requirements.

Canada continues to fall behind, requiring only minimal information on seafood imports entering the market.

The importance of harmonised import control schemes

As more countries develop import control schemes, inconsistent data requirements fragment the global system, leading to confusion and enforcement gaps that can be exploited by unscrupulous actors. Without harmonisation, these systems are at risk of falling short—allowing IUU-caught seafood to slip through the cracks.

Harmonised import control schemes will establish a robust baseline of global seafood traceability, helping market State authorities and making it easier for international supply chain operators to meet aligned requirements. This will, in turn, increase efficiency and drive compliance costs down.

"As global momentum to tackle IUU fishing builds and more markets consider systems to prevent imports of illegal seafood, it is increasingly important that harmonisation is prioritised. A patchwork of global requirements creates loopholes for those operating illegally to exploit and allows bad actors to continue profiting from illegal operations, at the expense of everybody else."
Tom Walsh, Coordinator of the EU IUU Fishing Coalition

The growing number of countries establishing and improving their own import control scheme is promising. Harmonising systems now can deliver globally aligned and robust import control schemes that remove the incentive for IUU fishing and lock illegal seafood out of markets, for good.

“The effective and efficient operation of the catch documentation scheme requires the understanding and the cooperation of the businesses and governments of the flag states and domestically… from the global aspect, international cooperation is indispensable for success.”

Yu Otake
Deputy Director, Fisheries Processing Industries and Marketing Division, Fisheries Agency of Japan

Speaking at Our Ocean 2025

Our call to action

Together, the EU IUU Fishing Coalition, the US IUU Fishing and Labor Rights Coalition and the IUU Forum Japan call on all market States to:

1. Establish import control schemes in line with recommendations in the Fisheries Import Control Scheme Handbook (FICSH) to protect global markets and consumers from buying products of IUU fishing.

2. Ensure that any future import control scheme is harmonised with existing schemes to close loopholes for those seeking to trade IUU-caught seafood and relieve unnecessary burden on exporters.

3. Cooperate and share information with other market States to strengthen efforts in closing the net to IUU fishing globally.


The Fisheries Import Control Scheme Handbook

The five steps needed to develop an effective import control scheme to prevent the importation of illegal seafood

photo of underwater

Photo by Jeremy Bishop on Unsplash

Photo by Jeremy Bishop on Unsplash

school of fish swimming underwater

1. Scoping

A market State needs to understand its seafood trade flows and the potential risks associated with them and the exporting States they trade with. Basic scoping will involve stakeholder engagement, legal assessments, defining the scope and species coverage of the import control scheme, as well as a clear division of responsibilities domestically.

2. Design

Once the scope of an import control scheme has been decided, market States can design their system. This must include the following essential design elements:

  • Catch documentation including the key data needed to help authorities detect seafood caught by IUU fishing
  • Trade certification to help track seafood through complex supply chains beyond the point of catch to the point of sale
  • Certificate validation by partner States to ensure information is legitimate
  • Digitalisation of the system to maximise efficiency - Simple, secure, user-friendly, accessible digital systems must be a key priority for all management authorities
  • Simplified documentation for small-scale fisheries
  • Mutual recognition of, and where possible, alignment with other import control schemes

3. Implementation

Following the system design phase, market States need to plan their implementation strategies to ensure the effective enforcement of the import control scheme. This includes:

  • Requiring catch documentation to be received before seafood enters the market (prior notification), allowing time for necessary checks;
  • Using risk assessments to flag imports from sources deemed of high-risk of IUU fishing;
  • Implementing additional measures for imports flagged as high-risk or suspicious, such as seeking to verify the information in the associated certificates;
  • Holding imported products at the border to allow sufficient time for inspections;
  • Physically inspecting high-risk and suspicious imports; and
  • Refusing the entry of imports linked with IUU fishing and its associated crimes, and sanctioning those responsible to deter IUU fishing operators.

4. Assessment

The proposed system—with its essential design elements and implementation strategies—should undergo a socio-economic analysis of the investments versus returns alongside an overall consultation with all relevant stakeholder groups.

5. Review

Once established in national legislation and in operation, the scheme’s performance must be transparently monitored and periodically reviewed, including through stakeholder feedback on its implementation, to improve its performance into the future, address any challenges, and incorporate new tools or technological solutions.

The Environmental Justice Foundation (EJF), Oceana, The Nature Conservancy, The Pew Charitable Trusts and WWF EU are working together to promote EU leadership in improving global fisheries transparency and governance to end illegal, unreported and unregulated (IUU) fishing.
Contact: info@iuuwatch.eu
The U.S. IUU Fishing and Labor Rights Coalition brings together human rights and environmental organizations focused on the nexus of IUU fishing and labor rights in seafood supply chains. Members include: Conservation International, Corporate Accountability Lab, FishWise, Greenpeace USA, Humanity United Action, International Corporate Accountability Roundtable, National Resource Defense Council, Oceana, Oxfam America, and World Wildlife Fund.
Contact: hello@penelopekyritsis.com


The IUU Forum Japan was established in September 2017, consisting of NGOs and social ventures engaged in efforts for sustainable fisheries to jointly work on measures against IUU fishing. Current members are Environmental Defense Fund (EDF), Sailors for the Sea Japan (SFSJ), Seafood Legacy (SFL), UMITO Partners and World Wide Fund Japan (WWF Japan).
Contact: info@iuuwatch.jp