News & Blog
OTC Weighs in on Dietary Guidelines for Americans
February 10, 2025
On February 10th, the 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. 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. 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. 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. 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.
OTC Petitions FTC Over Misleading Seafood Certification Claims
February 12, 2025
On February 12th, the OTC submitted a petition to the Federal Trade Commission (FTC) requesting an investigation into the Global Seafood Alliance’s (GSA) third-party aquaculture certification scheme, Best Aquaculture Practices (BAP). BAP is a certification scheme for farmed seafood products and is one of the world’s largest and most prominent aquaculture certification bodies. The OTC asked the FTC to examine whether BAP’s widely used logos, seals, and general marketing practices mislead American consumers by certifying farmed seafood – Chinese tilapia in particular – as safe, responsibly produced, and sustainable, despite documented violations of U.S. food safety laws. Tilapia is one of the most popular seafood in the United States. Americans consume over 200 million pounds of this fish each year, 83% of which is supplied by Chinese producers who raise tilapia in aquaculture farms. Chinese tilapia is widely sold across the United States, including in major grocery stores and meal kit services. BAP claims to certify seafood across the entire production chain, including feed mills, hatcheries, farms, and processing plants, based on its “BAP Standards and Guidelines” that emphasize food safety, environmental and social responsibility, and animal health and welfare. To assure consumers that BAP-certified products follow BAP’s Standards and Guidelines, BAP claims that all its certified facilities undergo a thorough certification process and are subject to rigid audits to ensure ongoing compliance. However, the enforcement data from the U.S. Food and Drug Administration (FDA) and public information from BAP’s own website demonstrate that its assurance is misleading. The OTC’s petition shows that several BAP-certified Chinese tilapia producers have repeatedly violated U.S. food safety standards. At least 10 of the top 25 Chinese tilapia exporters in 2023 were BAP-certified, despite having a history of FDA import refusals for unapproved veterinary drug residues and other food safety issues. Some of these companies are currently listed on FDA Import Alert lists for violations including the presence of unapproved drug residues, such as malachite green and nitrofurans, which are both recognized as carcinogenic and genotoxic. Others have been the subject of FDA warning letters and formal regulatory action, such as “Red List” status, for violating seafood safety standards. Despite these findings, these products continue to hold BAP certification and are sold to American consumers as safe and sustainable. The FTC has made clear that third-party certifications must be truthful, substantiated, and not misleading. The OTC’s petition alleges that the BAP label violated the Federal Trade Commission Act by falsely assuring consumers that certified seafood is safe and ethically produced, even when it comes from exporters with known violations. The OTC emphasized that such deceptive marketing practices harm consumer trust and unfairly disadvantage American own seafood producers. Specifically, this misrepresentation directly impacts the Oregon trawl fishing and seafood industry who operate under the strict and costly federal and state regulations that aim to ensure their products are safe and sustainable. Domestic seafood producers, including those in Oregon, are being forced to compete against poorly regulated, low quality, cheap foreign seafood which undercuts domestic seafood, threatening the viability of America’s sustainable fisheries. Read the OTC’s full FTC Petition here.
OTC Urges the Administration to Address Gaps in Oversight of Chinese Tilapia Imports
February 24, 2025
OTC Urges the Administration to Address Gaps in Oversight of Chinese Tilapia Imports In February 2025, the Oregon Trawl Commission developed a white paper outlining its concerns about the use of unapproved antibiotics in imported whitefish, particularly Chinese tilapia, as a resource to inform policymakers, federal agencies, and NGOs and encourage stronger enforcement by the Food and Drug Administration (FDA). U.S. law prohibits the importation of seafood products that contain traces of antibiotics due to their carcinogenic and genotoxic properties. However, many Chinese tilapia farmers continue to use unapproved antibiotics (e.g., nitrofurans and sulfadiazine) in producing tilapia destined to the United States to lower their operating costs. This practice provided Chinese tilapia producers an unfair advantage over its U.S. competitors, such as Oregon’s trawl fishing and seafood processing industry, who is committed to meeting strict food safety and sustainability standards yet is being undercut by cheaper Chinese imports produced with banned antibiotics. Tilapia is one of the most popular whitefish in the U.S. Americans consume approximately 200 million pounds of tilapia each year, 83% of which comes from China. The OTC underscores the importance of enhancing the FDA’s testing efforts to prevent contaminated Chinese tilapia from reaching American consumers. Specifically, the OTC points to discrepancies between the regulation of Chinese tilapia and Chinese aquaculture more broadly. For instance, the OTC points out that the FDA determined that shrimp, dace, and eel from China consistently contained unapproved antibiotics and placed a country-wide Import Alert on shipments of these products – a policy that has been in place since 2007. In comparison, there is no such program in place for Chinese tilapia, despite a 2022 FDA report listing farmed tilapia as having a high potential for “aquaculture drug hazards.” The OTC highlighted that the FDA’s sampling of tilapia imports has significantly decreased in recent years despite there being no evidence that Chinese tilapia farmers have stopped using unapproved antibiotics. The lack of enforcement actions by the FDA means that Americans are at an increased risk of consuming antibiotic-laden tilapia. To address this issue, the OTC called on the Administration to provide more oversight by working with the FDA to determine the current level of import testing on shipments of Chinese tilapia and conduct more thorough sampling studies to determine whether Chinese tilapia needs to be placed on an Import Alert, limiting imports to only those producers that prove their shipments are in accordance with U.S. food and safety regulations. The OTC also called on the FDA to determine how it plans to implement recommendations by the Government Accountability Office (GAO) to increase foreign facility inspections and ensure the safety of America’s food supply. “Oregon’s fishermen play by the rules because they believe in delivering safe, sustainable seafood to American consumers,” said Yelena Nowak, Director of the Oregon Trawl Commission. “But without meaningful enforcement of our food safety laws, they’re forced to compete against cheaper, noncompliant seafood imports that erode both public health and the viability of the domestic seafood industry. Stronger FDA oversight would level the playing field and protect the US consumer market.” Read the OTC’s FDA white paper here.
OTC Asks USTR to Initiate a Section 301 Investigation into the Use of Veterinary Drugs in Foreign Farm-Raised Seafood Production
July 14, 2025
The Oregon Trawl Commission joined the Southern Shrimp Alliance and members of the domestic crawfish industry in formally requesting that the Office of the U.S. Trade Representative (USTR) initiate a Section 301 investigation, with a particular focus on the use of unapproved antibiotics and veterinary drugs in farm-raised seafood production in China, India, Indonesia, and Vietnam. The petition asks USTR to examine how the continued use of these substances constitutes an unfair trade practice that puts downward pricing pressure on U.S. seafood producers operating under much stricter safety standards. Certain antibiotics and veterinary drugs, such as chloramphenicol and nitrofurans, are largely unapproved in the United States for use in aquaculture because of their potential to cause antimicrobial resistance and, in some cases, because they are known to be carcinogenic and genotoxic. The possible harm caused by these drugs has resulted in heavy regulation in the United States, with the Food and Drug Administration (FDA) maintaining a very limited list of approved drugs for use in farmed seafood raised for human consumption. Despite the recognized health concerns with the use and consumption of these unapproved drugs in aquaculture production, farmed seafood that violates U.S. standards continues to be imported into the U.S. at an alarming rate. Together, China, India, Indonesia, and Vietnam account for nearly one-third of the total value of U.S. seafood imports. While these countries have existing regulatory frameworks for the use of antibiotics and veterinary drugs in aquaculture, the enforcement of food safety standards is not comparable to that of the U.S. Since 2019, approximately 77% of FDA seafood entry refusals due to drug residues came from these four countries. Not only does the existence of veterinary drugs in farm-raised seafood produce various health concerns for consumers, but the use of these drugs also represents an unfair trade practice that harms domestic seafood industry. Because U.S. seafood producers are held to higher food safety standards, they are subject to higher costs. By allowing the use of these substances, countries like China, India, Indonesia, and Vietnam enable their seafood producers to boost production, lower costs, and consequently flood the U.S. market with artificially cheap seafood that U.S. producers cannot compete with. American seafood producers are now struggling to compete for sales in the seafood market and face extinction in the commercial sector. Since 2017, Oregon groundfish and coldwater pink shrimp fishermen and processors have faced declining revenue, profits, and employment. The average price of groundfish landed in Oregon decreased to $0.55 per pound, while the average price of Oregon pink shrimp decreased to $0.42 per pound – the lowest price in years. The petition highlights the urgent need for trade enforcement to restore fair competition and to protect public health. A Section 301 investigation into the use of veterinary drugs in farm-raised seafood from China, India, Indonesia, and Vietnam would empower the U.S. government to address these unfair practices. “For Oregon seafood producers like those represented by the Oregon Trawl Commission, this kind of relief is essential,” said Director of the OTC, Yelena Nowak. “It’s about leveling the playing field for domestic, sustainable fisheries by stabilizing prices and preserving a viable domestic seafood sector that has existed in Oregon for generations. It’s also about protecting American consumers and ensuring only high-quality seafood is sold in the U.S.” Read the July 14, 2025, letter to the USTR here.
Oregon Trawl Commission, Shrimp Producers Marketing Cooperative, and Oregon Department of Agriculture Call to Open U.K. Market
September 18, 2025
On September 18th, the Oregon Trawl Commission (OTC), together with the Shrimp Producers Marketing Cooperative (SPMC) and the Oregon Department of Agriculture (ODA), submitted a letter to the U.S. Trade Representative Ambassador Greer, urging the Administration to expand the United Kingdom (U.K.) market access for Oregon’s coldwater pink shrimp in trade talks with the U.K. The U.K. market is heavily reliant on imports to satisfy consumer demand for seafood, with nearly 80% of its seafood demand met through imports. Coldwater shrimp, especially, has long been a staple for U.K. consumers. Traditionally, Canada, Greenland, and Norway have been the largest suppliers of coldwater shrimp to the U.K. market. Coldwater shrimp from these countries enjoy a preferential tariff treatment where up to certain volume of the products are allowed to enter the U.K. market tariff free. In contrast, coldwater shrimp from the United States is subject to a steep 20% tariff rate. Sold in a single frozen cooked and peeled format, Oregon pink shrimp is high quality and produced with sustainable fishing methods. The Oregon pink shrimp fishery was the first shrimp/prawn fishery in the world to become certified against the rigorous seafood sustainability standard of the Marine Stewardship Council (MSC) in 2007. The fishery remains MSC-certified, underscoring the industry’s long-term commitment to responsible fishing practices. However, the 20% tariff puts Oregon pink shrimp at a severe disadvantage in the U.K. market. To address this unfair trade practice, the OTC, SPMC, and ODA joined in an effort to urge the Administration to seek elimination of the U.K.’s longstanding 20% tariff on Oregon pink shrimp. Alternatively, the OTC, SPMC, and ODA urged the Administration to negotiate an Autonomous Tariff Quota (ATQ) for Oregon pink shrimp, if full tariff removal is not possible. An ATQ would ensure that Oregon pink shrimp receives the same treatment as that afforded to shrimp from Canada, Greenland, and Norway. Importantly, either proposal would not only open the U.K. market to Oregon shrimp exports, but also provide British seafood processors with a reliable, sustainable supply of coldwater shrimp. Read the OTC, SPMC, and ODA’s full letter here.