Effective September 20th, 2016, the National Marine Fisheries Service (NMFS) will transition to US Customs and Border Protection’s Automated Commercial Environment (ACE) for its documentation programs. As a result of this implementation, the Highly Migratory Species International Trade Permit (HMS ITP) and Antarctic Marine Living Resources Dealer Permit (AMLR) will be replaced by a single permit: the NMFS’ International Fisheries Trade Permit (IFTP). The new consolidated permit will be required of imported products currently subject to Tuna Tracking and Verification Program (TTVP, Form 370) documentation. The consolidated permit allows the holder to conduct trade under any of the three NMFS programs: HMS ITP, AMLR, and TTVP.
Current HMS and AMLR permit holders may continue to use their permits until September 19th, and TTVP importers may continue importing without a permit until then. On September 20th, importers of HMS, AMLR, or TTVP products must have an IFTP when filing imports, exports, or re-exports with CBP. IFTPs will be valid for one year from the date of issuance, and must be held by the importer of record in the US. Prior to expiration, an email notice will be sent and permit holders will be required to renew their IFTP. Permits are available for $30 through the NMFS National Permit System (available online 24/7) and must be obtained prior to any shipments occurring after September 20, 2016. The permit number is a required data element for processing in ACE and is 13 numbers long preceded by a “P.”
Most of the required documentation remains the same: commercial invoices, Form 370, copy of IFTP (or at least the permit number), and a copy of the International Commission for the Conservation of Atlantic Tunas (ICCAT). It is also helpful to include the scientific name of the fish and describe it as whole or otherwise. Additionally, ICCATs will be required for Blue Fin Tuna, Swordfish, frozen Big Eye Tuna, and shark fins. Form 370 will be required for all tuna and tuna products except fresh fish.
Frequently asked questions are available in the Compliance Guide for NMFS’ Implementation of International Trade Data System (ITDS). Additionally, the new regulations can be found in the Federal Register and trade program details are available on the National Oceanic and Atmospheric Administration website.