On July 31, 2015, ThisFish contributed to and co-signed a submission to the Presidential Task Force on Combating Illegal, Unreported and Unregulated (IUU) Fishing and Seafood Fraud. The submission came from Future of Fish's new Traceability Technology pod, of which ThisFish is an active member. This group consists of some of the world's leading traceability technology providers with deep experience in global seafood supply chains. Here's the submssion:
To the National Ocean Council Committee on IUU Fishing and Seafood Fraud:
We, the undersigned, represent a collaboration of technology companies and experts actively working to promote transparency and traceability within the global seafood industry. Our group is part of a collaboration organized by Future of Fish (FoF), a non-profit systems change incubator that works with entrepreneurs, industry players, and investors to create business solutions to ocean challenges.
Our joint comments address the minimum types of information necessary for an effective seafood traceability program to combat IUU fishing and seafood fraud, as well as the operational standards related to collecting, verifying and securing that data.
Minimum Data Required
Based on our experiences with the seafood industry and the challenges that stem from both industry culture and practices, we address the following categories related to seafood product information and traceability:
(1) Who harvested or produced the fish?
Supply chain relationships and identities of trading partners are guarded fiercely within the seafood industry. Yet knowing all players in a chain is also critical to rooting out fraud and IUU. Therefore, we recommend that any required information that might reveal the identities of producers or processors within a supply chain be masked by anonymous identity codes known only to the relevant government regulatory agencies. Key producer data should include:
- Identification number of vessel, either IMO or call sign;
- Flag State of harvesting vessel (including when vessels offload to tenders);
- Type of fishing gear or catch method; and
- Proof of fishing license or authorization of legal harvest (both wild and farmed).
(2) What fish was harvested and processed?
We recommend requiring the following product-level information:
- Scientific (Latin) name;
- Common name;
- Form of product; and
- Estimated quantity or weight.
(3) Where and when was the fish harvested and landed?
It may be impossible to pinpoint specific dates and locations for wild-caught fish that are harvested and aggregated across multiple days (or weeks) and harvest areas, unless the vessel or tender is able to segregate and label fish caught at different times and locations. Therefore, the data requirements related to these attributes should allow some flexibility to account for comingling. We recommend the following minimum data elements:
- Wild harvest date range (consisting of "Start date of fishing trip" and "Landing date");
- Area of harvest should include either National Fisheries Management Zone within EEZ, FAO Major Fishing Area outside EEZ, or finer scale of management unit, where available;
- Location of aquaculture facility; and
- First port of landing.
(4) What was the chain of custody of the fish or fish product through the supply chain to point of entry into U.S. commerce?
By definition, traceability requires data that is created and shared among multiple players within a supply chain. Thus, an effective traceability system must collect data throughout a seafood product's chain of custody, from harvest to import. We recommend the following minimum information be collected at all critical tracking events (e.g., product aggregation, separation, transformation), in order to create an effective pedigree for each seafood product entering US commerce:
- What happened? (e.g., comingling, processing, separation, re-processing, etc.);
- Where? (Fishing area or city, province, country);
- When? (Date or range of dates); and
- Who? (Name or ID number of company or parent company involved).
In order for a traceability system to put a stop to IUU, mislabeled, and fraudulent seafood products entering US commerce, it must require data collection, management, sharing, and verification at both the company and supply-chain levels. Thus, with respect to the development of operational standards, we strongly recommend that the Committee consider incorporating the following core functions, which were identified by Future of Fish and are the foundation upon which our technology collaboration is based:
Product-data Pairing: Data is captured at the point of harvest or landing and is linked to the product (e.g., individual fish, batch, or lot) with physical identifiers (e.g., alpha numeric code, data-carriers such as 1D or 2D barcodes, or RFID), which follow the product through all aggregations and transformations within the supply chain.
Internal Traceability: Intra-company, one-up and one-down product tracking — where did it come from, where did it go? — which requires tracking the receipt, transformation, and shipment of products from one business to another in the supply chain. Many enterprise resource planning (ERP) systems perform this function which is also required to meet food safety HACCP requirements and product recalls.
Supply-chain Transparency: A map of the supply chain based on known relationships (not transactional data), including which companies are part of a chain, where they are located, what they do, and how they do it (e.g., Are relevant certifications up to date? Are there facility violations? Are there known human rights violations? Etc.).
Verification: The capacity to cross check information at any point in the supply chain with data supplied by other players or third parties. Verification can include mass-balance; data entry checks; prohibition of post hoc data deletions and modifications; verification of data accuracy via fish tickets or landing documents; and verification that a fishery identified by the data elements above actually exists. In terms of traceability, this function is about proving the legitimacy of the data — not data integrity in the technological sense (e.g., proper formatting).
Each core function is a form of traceability in its own right, yet each has limited scope. While some technology providers can offer more than one function, no current traceability technology company can singlehandedly deliver all four. Such traceability requires a level of transparency, data gathering, verification, and tracking that only a collaborative ecosystem of supply chain players and technology vendors can provide.
Through Future of Fish's strategic facilitation, the undersigned group of traceability technology vendors and experts are currently seeking and exploring opportunities to pilot such traceability collaborations. We welcome any interest or inquiries from the Committee regarding how such collaboration may serve to further the goals of the Task Force.
Marketing Manager, Global Product Strategy
Thomas J Kraft
Tilson Technology Management
Director, Systems Division
Sustainable Fisheries Partnership
Co-Founder and Managing Director
Buyer Engagement Program Manager
Sustainable Fisheries Partnership
Eric Enno Tamm
General Manager, Traceability
ThisFish / Ecotrust Canada
Global VP Food/Seafood Traceability
Director of Marketing and Business Development
JJ McDonnell & Co., Inc.
Product Development Director
Head of International Sales fTrace
Project Management + Business Development