Guide to Seafood Import Monitoring Program (SIMP) Audit

Have you received a letter from NOAA Fisheries advising you that they have selected your entry for an audit? Do you know what course of action you need to take upon receiving the SIMP audit letter? The industry has tremendously changed, and we understand how you need support to walk you through the complexity of import requirements. As your Customs Broker, we are your partner every step of the way. If you have received a SIMP audit letter, please do not hesitate to reach out to us and we can guide you through the entire process. We will just need some paperwork to be provided to us and we can help communicate with National Marine Fisheries Services (NMFS) audit team on your behalf.

AUDIT PROCESS OVERVIEW  

Seafood Import Monitoring Program was mandated on January 1, 2018, requiring Customs Brokers to transmit certain information through CBP’s ACE system. There are also separate record-keeping requirements for importers/IFTP holders..

According to National Marine Fisheries Services (NMFS), the purpose of a SIMP audit is to verify the harvest and landing information provided in an entry filing as well as the sufficiency of chain of custody records documenting the movement of fish and seafood products from harvest/landing into the US.  The U.S. importer/IFTP holder will be notified by a NMFS auditor if an entry is selected for an audit and asked to provide supporting records within 5-10 days. Auditees will provide results within 30 days of receiving the chain of custody records and advise for non- conformities, discrepancies and corrective actions to support compliance of future shipments.

COMPLETE CHAIN OF CUSTODY RECORDS AND INFORMATION Sec 300.324(e)

In addition to the entry requirements, NMFS seek for identification of products and each custodian of the fish or seafood product: a transhipper, processor, storage facility, or distributor at every step of the movement of the product through the supply chain.

Some examples of records that may be used to establish chain of custody:

1. Vessel Manifest Records
2. Raw Material Invoice
3. Fish Tickets at Landing Port
4. Off Loading Reports with Vessel Names
5. Country Catch Certificates
6. Proforma Invoice
7. Processor’s Bill of Lading and Receiving Bill
8. Cold Storage Receiving Ticket
9. Mate’s Receipt
10. Transshipment Log
11. Cold Storage Unloading Log
12. Daily Production Log
13. Finished Product Packaging Label
14. Cold Storage Discharge and Receiving Log
15. Processor’s Raw Material Receiving Log
16. Packing Log

To read further information and to access the resource materials:

https://www.iuufishing.noaa.gov/RecommendationsandActions/RECOMMENDATION1415/FinalRuleTraceability.aspx

Posted in NMFS, NOAA, SIMP, SIMP Audit Tagged with: , ,

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