Starting Jan. 1, SIMP will require U.S. seafood importers to submit detailed data elements for 11 species of seafood and seafood-containing food products.
Many importers and their customs brokers, which will file the SIMP information to NOAA through Customs and Border Protection’s Automated Commercial Environment (ACE) and International Trade Data System (ITDS), are scrambling to gather the additional information about their fish imports.
"There remains much confusion and misunderstanding in many parts of the supply chain," said Geoff Powell, president of the National Customs Brokers and Forwarders Association of America (NCBFAA), in a letter to NOAA on Dec. 1.
"Importers are working to figure out how they can accurately and efficiently gather this information, which resides with many different, and often unrelated, parties in the supply chain," he added. “Until all segments of the supply chain adjust to this new flow of information, the implementation will be difficult.”
SIMP filings require details such as where the fish was caught, the type of net used, the name of the vessel, where the fish was off-loaded, the weight of the fish when it was off-loaded, and the name of the processor.
NOAA announced the initiation of the SIMP pilot on Oct. 4. Software providers have been hurrying to get their broker clients ready to enter SIMP data in ACE-ITDS.
“Many brokers are still struggling to work out the technical kinks in their systems,” Powell said. “As a result, the pilot has been slow to get off the ground, with only around eight seafood entries actually filed in ACE as of last week. With the Jan. 1, 2018 mandatory date looming, this troubles us greatly.”
The NCBFAA does not suggest that NOAA delay SIMP’s implementation, but enact a “soft compliance” policy with regard to the new data entry requirements in ACE.
“NOAA could make some or all of the new data fields optional for an initial period of time, allowing importers and filers to fully develop a supply chain information infrastructure to ensure the correct information is known and available at the time of entry,” Powell said. “This would enable filers to request and input the data from importers when it is available, yet not disrupt the flow of trade when it is not.”
The NCBFAA also asked NOAA to set up a “war room,” which would be staffed 24 hours, seven days a week, to assist importers and brokers during the initial launch and continuing through successful SIMP implementation. Currently, NOAA plans to provide a help desk staffed with two people Monday to Friday, 8 a.m. to 4:30 p.m. EST.
“This coverage is not adequate for the complex entry data requirements that NOAA is about to implement,” Powell warned. “Not only does it leave West Coast importers high and dry for almost half of every business day, but it ignores the fact that trade at ports around the country is not confined to regular business hours.”