On February 10th, the Oregon Trawl Commission (OTC) submitted comments on the Scientific Report of the 2025 Dietary Guidelines Advisory Committee (“Scientific Report”), urging the Committee to adopt a more comprehensive approach to seafood recommendations in the dietary guidelines.  The Scientific Report provides the evidence base and recommendations to the U.S. Departments of Agriculture (USDA) and Health and Human Services (HHS) for shaping the official Dietary Guidelines for Americans, 2025–2030, which are expected to be published by the end of the year.  The Dietary Guidelines for Americans is the federal government’s nutrition recommendations designed to promote health, reduce the risk of chronic disease, and help individuals of all ages make informed food choices throughout every stage of life.  As part of the guideline development process, the HHS invited public comments on the Scientific Report to help inform the final set of guidelines.

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Published by the USDA in December 2024, the Scientific Report for the 2025-2030 period concluded that Americans’ diet quality must improve to align with the Eat Healthy Your Way Dietary Pattern.  Based on this conclusion, the Committee recommended that Americans should increase their seafood consumption.  However, the Committee did not differentiate between the sources of seafood products in its recommendation.  This is so despite numerous reporting and studies finding that farm raised seafood, particularly those from certain Asian countries such as China, India, Indonesia, and Vietnam, are often produced using drugs and chemicals that may pose serious health risks to humans.[1]  In contrast, wild-caught seafood does not pose these concerns.  Accordingly, in its comments, the OTC suggested that if the Committee’s advice to increase seafood consumption is ultimately followed, it should emphasize a preference for wild-caught seafood over imported, farm-raised alternatives.

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Additionally, the Scientific Report stated that, in its new Guidelines, the Committee may consider the Food and Drug Administration (FDA) and Environmental Protection Agency’s (EPA) Advice about Eating Fish for pregnant and breastfeeding mothers, and young children.  The OTC pointed out that this advice is based solely on the varying mercury levels across different types of seafood and fails to consider drug residue or other contaminants predominately found in farm-raised seafood that are known to be carcinogenic and genotoxic.  Therefore, OTC urged the Committee to consider other health concerns in addition to mercury content when advising on which types of seafood are best for pregnant or breastfeeding women and children.

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Because Oregon trawl fishermen are continuously forced to compete in the U.S. market with unfairly traded foreign farmed seafood, such as Chinese tilapia, which poses serious public health risks, the OTC supports reforming national dietary guidelines on seafood to better protect American consumers and the domestic seafood industry.

 

“It is of the utmost importance that the seafood that is being advised for consumption to Americans, especially to vulnerable groups like pregnant women and children, is clean, safe, and responsibly sourced,” said Yelena Nowak, Director of the OTC.  “Domestic wild seafood like seafood harvested in the pristine cold waters of the Pacific off the Oregon coast, is the best choice for quality, food safety, and sustainability. The Federal authorities should be advocating for healthy seafood options for Americans.”

 

Read the OTC’s comments here.

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[1]  See, e.g., Monterey Bay Aquarium, Seafood Watch, “Review of global antibiotic use, impacts, solutions, and gaps in Aquaculture,” 5-6, https://www.seafoodwatch.org/globalassets/sfw/pdf/projects/antibiotics-in-aquaculture/seafood-watch-antibiotics-in-aquaculture-state-of-affairs.pdf.  See also U.S. FDA, “Import Alert 16-131 [Detention Without Physical Examination of Aquacultured, Shrimp, Dace, and Eel from China and Hong Kong SAR - Presence of New Animal Drugs and/or Unsafe Food Additives],” (Feb. 28, 2025), https://www.accessdata.fda.gov/CMS_IA/importalert_33.html (accessed Aug. 6, 2025); U.S. FDA, “Import Alert 16-124 [Detention Without Physical Examination of Aquaculture Seafood Products Due to Unapproved Drugs],” July 28, 2025), https://www.accessdata.fda.gov/cms_ia/importalert_27.html (accessed Aug. 6, 2025); U.S. FDA, “Import Alert 16-127 [Detention Without Physical Examination of All Seafood Due to Chloramphenicol], (Mar. 31, 2025), https://www.accessdata.fda.gov/cms_ia/importalert_29.html (accessed Aug. 6, 2025); U.S. FDA, “Import Alert 16-129 [Detention Without Physical Examination of Seafood Products Due to Nitrofurans],” (July 17, 2025), https://www.accessdata.fda.gov/cms_ia/importalert_31.html (accessed Aug. 6, 2025). ​