The passage of the Trying to Combat Illegal Fishing Act (TIFFA) in December 2018 marked a significant shift in U.S. policy toward tightening seafood supply chain controls. By mid-2019, seafood importers and processors found themselves grappling with a new and demanding compliance landscape. The Act’s core requirement—that all seafood imports be traceable to the port of landing—might seem, at first glance, a straightforward administrative measure. But in reality, it introduced a web of operational, technological, and logistical challenges that many firms had not fully anticipated. One can sense, in conversations with industry insiders, a mixture of acceptance and quiet apprehension about the scale of the transformation underway.
A key feature of TIFFA’s framework is the mandated use of NOAA Fisheries’ open data on authorized vessels. This dataset, maintained meticulously by NOAA, is designed to provide importers and processors with verifiable records of vessels cleared for lawful fishing activity. The idea, at least in theory, is to create a transparent link between the catch and the point of legal entry into the market. Yet as many companies have discovered, integrating this data into existing systems is no small task. For processors accustomed to dealing with fragmented or informal supplier networks, the shift requires not only new technology but, arguably more importantly, a new mindset. The task of matching supplier paperwork with NOAA’s vessel registry and verifying it against port records is not as routine as some policymakers might have imagined. There are grey areas—cases where vessel names are misspelled in documentation, or where landing dates don’t quite line up with VMS (Vessel Monitoring System) logs. And resolving these discrepancies often takes time, negotiation, and a certain tolerance for uncertainty.
For firms determined to stay ahead of the curve, cross-referencing VMS logs with docking times has emerged as a critical part of compliance. The process involves comparing real-time or near-real-time data from vessel transponders with official port records, a task that sounds simple but can prove maddeningly intricate in practice. Some companies have invested in custom software solutions that automate much of the matching process. Others, perhaps more cautiously, rely on manual checks by compliance staff who must navigate between multiple databases, often juggling mismatched formats or incomplete entries. Neither approach is without its frustrations. And here, too, the variability in supplier sophistication plays a role. Larger, better-resourced fishing operators tend to have cleaner, more reliable records. Smaller operators, particularly those in developing countries, may struggle to meet the documentation standards TIFFA now demands.
One approach gaining traction is the introduction of “catch-to-consumer” traceability labels. These labels aim to reassure buyers—whether retailers, food service companies, or end consumers—that the seafood they are purchasing complies with TIFFA’s requirements. A typical label might include information such as the name of the vessel, the flag state, the port of landing, and perhaps even a QR code linking to a digital traceability record. But creating these labels is not a purely technical exercise. Companies must first ensure that the underlying data is accurate, complete, and verifiable. And that, as many are discovering, is the hard part. Some firms have piloted internal templates for generating these labels, drawing on best practices from other sectors where traceability is more mature. But consistency remains elusive, partly because the industry is still feeling its way forward and partly because the regulatory environment itself continues to evolve in response to implementation challenges.
It is worth noting that while TIFFA’s objectives have been broadly welcomed—few dispute the need to combat illegal, unreported, and unregulated fishing—the practicalities of compliance have sparked quiet debate within the sector. There is, to be sure, widespread recognition that improved traceability will ultimately benefit legitimate operators by leveling the playing field. Yet there is also concern that the burden of compliance could fall disproportionately on smaller processors and importers, who may lack the resources to build sophisticated data systems or hire dedicated compliance teams. Some industry voices have called for greater support from regulators, whether in the form of clearer technical guidance, financial assistance for technology adoption, or more proactive engagement to address data gaps and inconsistencies.
The use of NOAA’s Fisheries open data and VMS logs represents, in many ways, a step change in how the U.S. seafood supply chain operates. It introduces a level of transparency and accountability that, while long overdue in the eyes of some, is undeniably complex to implement. Companies are having to rethink long-standing relationships and practices, often under tight timelines and with limited room for error. And while progress is being made—there are encouraging signs that industry is rising to the challenge—the road ahead remains, by most accounts, a demanding one. The question of how to balance regulatory rigor with practical feasibility will likely shape the evolution of TIFFA-related policies and practices in the years to come.