SIMP Compliance for Seafood Importers
Two agencies, two programs, one shipment. SIMP handles legality and traceability; FDA handles food safety — and both can apply at once.
Key Takeaways
- SIMP is NOAA's, not FDA's — run by NOAA Fisheries (NMFS) and CBP to combat IUU fishing and fraud.
- Three pillars: an IFTP permit, harvest/landing data reported at entry via ITDS/ACE, and two-year records.
- 13 priority species groups are covered — roughly half of all U.S. seafood imports.
- The importer of record holds the IFTP and is responsible for reporting and recordkeeping.
- SIMP runs in parallel with FDA — meeting one doesn't satisfy the other.
- Expansion is proposed — check the current species list rather than assume.
What SIMP Is — and Why It Exists
SIMP is a risk-based traceability program. For covered species, importers must provide data and keep records tracing the product from the point of harvest to entry into U.S. commerce, so the government can confirm the seafood was legally harvested and accurately identified. The target is IUU fishing — illegal, unreported, and unregulated — and seafood fraud such as species substitution and mislabeling, which distort markets and undercut legal producers.
What SIMP Requires of Importers
1. IFTP permit
An International Fisheries Trade Permit from NOAA Fisheries, required to import SIMP-covered products for human consumption. One IFTP also covers NOAA's other trade monitoring programs.
2. Data at entry
Harvest and landing data — species, harvest area, gear, vessel, landing details — reported at entry through the International Trade Data System (ITDS), part of ACE.
3. Two-year records
Chain-of-custody records documenting each step from harvest to entry, retained by the importer of record for two years and available to NOAA on request.
The 13 SIMP Priority Species Groups
SIMP vs. FDA — How They Differ
| SIMP (NOAA) | FDA | |
|---|---|---|
| Agency | NOAA Fisheries (NMFS) + CBP | Food and Drug Administration |
| Purpose | Traceability & legality (anti-IUU, anti-fraud) | Food safety & sanitation |
| Core requirement | IFTP, harvest data at entry, 2-year records | Seafood HACCP verification (123.12) |
| Also | Applies to 13 priority species | Food facility registration, prior notice, labeling |
| Rules | 50 CFR | 21 CFR |
How to Comply with SIMP
Check if your species is covered
Determine whether your seafood is a SIMP priority species; if so, SIMP applies on top of FDA requirements.
Obtain an IFTP
Apply to NOAA Fisheries for an International Fisheries Trade Permit to import SIMP-covered products.
Gather harvest & landing data
Collect species, harvest location, gear, vessel, and landing details from your supply chain.
Report at entry through ITDS/ACE
Transmit the required data to the U.S. government at entry through the International Trade Data System.
Keep chain-of-custody records
Maintain traceability records from harvest to entry, retained for two years.
Coordinate with FDA compliance
Meet your separate FDA obligations — Seafood HACCP, registration, and prior notice — alongside SIMP.
Navigate SIMP and FDA Together
FDA Registration Assistance helps seafood importers on both fronts — guiding SIMP traceability, the IFTP, and data and recordkeeping, while handling the FDA side: Seafood HACCP verification, food facility registration, U.S. Agent, and prior notice. (SIMP itself is administered by NOAA, not FDA.)
Contact us at info@fdaregistrationassistance.com or call +1 (928) 275-8333. Trusted by importers across 135+ countries, with 15+ years of experience.
Frequently Asked Questions — SIMP
1. What is the Seafood Import Monitoring Program (SIMP)?
A risk-based seafood traceability program requiring importers to report data and keep records from harvest to entry, for priority species vulnerable to illegal fishing and fraud — to keep IUU and misrepresented seafood out of the U.S. market.
2. Is SIMP an FDA program?
No — the key point. SIMP is administered by NOAA Fisheries (NMFS) with U.S. Customs (CBP), under the Department of Commerce. It's separate from FDA. Priority-species importers must meet SIMP and their FDA obligations, under different agencies and rules.
3. Which species are covered?
13 groups: abalone, Atlantic cod, blue crab (Atlantic), dolphinfish (mahi mahi), grouper, red king crab, Pacific cod, red snapper, sea cucumber, sharks, shrimp, swordfish, and tunas (albacore, bigeye, skipjack, yellowfin, bluefin) — over 1,100 species, about half of U.S. seafood imports.
4. Since when have shrimp and abalone been covered?
Most groups became effective January 1, 2018; shrimp and abalone became effective December 31, 2018. All 13 are currently subject to the program.
5. Is SIMP expanding?
NOAA has proposed expanding it — broader snapper and tuna groups, and species like squid, octopus, eels, queen conch, spiny lobster, and all king crabs — and ran a program review. It currently operates with the original 13 groups, so check the current list.
6. Do I need a permit?
Yes — an International Fisheries Trade Permit (IFTP) from NOAA Fisheries to import SIMP-covered products for human consumption. The IFTP also covers NOAA's other trade monitoring programs.
7. What data must be reported?
At entry: species, harvest location or area, gear, harvesting vessel or aquaculture facility, and landing details — through the International Trade Data System (ITDS), part of ACE. It's a confidential business-to-government submission.
8. How long must records be kept?
The importer of record retains chain-of-custody records from harvest to entry for two years, available to NOAA for audit or verification on request.
9. Who is responsible?
The importer of record — the party for the entry who holds the IFTP. You can rely on your supply chain for data, but accurate reporting and recordkeeping rest with the importer.
10. How does SIMP differ from FDA rules?
SIMP is traceability and legality; FDA is food safety — Seafood HACCP, registration, prior notice, labeling. Both can apply to one shipment, but they're different programs and meeting one doesn't satisfy the other.
11. Do seafood importers need FSVP for the FDA side?
Generally no — seafood is exempt from FSVP and follows Seafood HACCP importer requirements (123.12) instead. See our seafood importers page.
12. What if I don't comply with SIMP?
Shipments of covered species without the permit, data, or records can be delayed, denied entry, or face enforcement. SIMP is enforced at entry through CBP alongside NOAA, so gaps hold up product just like an FDA issue would.
13. Does SIMP apply to all my seafood?
No — only priority species. Species outside the list aren't subject to SIMP reporting, though FDA obligations still apply. Correct classification matters, since mislabeling to avoid SIMP is exactly what it targets.
14. How does FDA Registration Assistance help?
It helps importers navigate both — guiding SIMP traceability, the IFTP, and data/records, while handling the FDA side (Seafood HACCP, registration, U.S. Agent, prior notice), for importers across 135+ countries. SIMP itself is administered by NOAA, not FDA.
15. How do I get started?
Contact FDA Registration Assistance at info@fdaregistrationassistance.com or call +1 (928) 275-8333 with your species and suppliers for a clear plan across SIMP and FDA.
