Good, Bad & Ugly in addressing IUU Seafood in Australia
Australia’s efforts to address illegal, unreported and unregulated (IUU) fishing by foreign fishing vessels—primarily through the Australian Fisheries Management Authority’s International Compliance and Engagement Program (ICEP) 2025–2027—represent a complex and evolving set of policies aimed at protecting fisheries resources in the Australian Fishing Zone and on the high seas.
That represents the good, however, glaring gaps persist in threatening supply chain integrity and undermining seafood consumer confidence, especially around seafood naming, and traceability.
Australia’s IUU Response: Strengths and Strategies
The ICEP 2025–2027 is designed to “detect, deter, and respond” to IUU fishing in national waters and in areas where Australia has an interest. The program targets foreign vessels that threaten local fisheries, supporting robust enforcement, regional cooperation (such as with Indonesia), public campaigns, and leveraging technology like vessel monitoring systems and port inspections. Australia’s National Plan of Action to Prevent, Deter and Eliminate IUU Fishing also highlights ongoing legal, monitoring, and international collaboration measures designed to apprehend and prosecute foreign offenders.
ICEP’s key actions include:
- Coordinating patrols with Border Force and working closely with regional partners
- Education and engagement strategies for prevention
- Prosecution and sanctions for vessels found culpable of IUU activities
- Continued development of “effective governance of domestic fisheries” and tracking foreign fishing vessels within Australia’s zone.
Where the Gaps Lie: HS Codes and the Fish Names Standard
Despite Australia’s strong efforts to combat illegal fishing at sea, significant regulatory blind spots persist, particularly relating to imported seafood. Currently, there is no mandatory requirement to link imported fish Harmonised System (HS) codes with the Australian Fish Names Standard (AFNS, AS5300). This lack of integration leaves imported seafood vulnerable to mislabeling, species substitution, and concealed origins, profoundly undermining traceability and consumer trust.
Why is this a critical issue?
- Traceability Failure: Without compulsory linkage between HS codes and AFNS, verifying the exact species entering Australia, their sustainability credentials, or even their safety for consumption is difficult. HS codes are often broad and non-specific, grouping multiple species together and masking factors such as whether the fish is wild-caught or farmed. The system is lagging well behind as most of the seafood consumed nowadays is farmed.
- Food Safety Risks: The AFNS remains voluntary within the domestic supply chain except for exports. This means imports sold within Australia do not have consistent, standardized naming or labeling, leaving the food safety system vulnerable to gaps in species identification and adulteration risks.
- Poor Consumer Transparency: Consumers are left unable to confidently identify what they are buying or eating. This undercuts Australia’s reputation for seafood integrity and makes claims of world-leading regulatory compliance appear hollow when imports can evade scrutiny.
Adding to these concerns, the Country-of-Origin Labelling (CoOL) system—set for mandatory implementation in hospitality venues from July 2026—is also problematic. The CoOL ‘AIM’ system, which requires indicating whether seafood is Australian (A), Imported (I), or Mixed (M), is a blunt tool. The ‘Mixed’ category effectively serves as a catch-all and can obscure the true origin of seafood products.
To be fair, many hospitality operators rely on the ‘Mixed’ label because Australia depends heavily on seafood imports, making detailed provenance disclosure challenging. However, this workaround is unsatisfying for consumers who want clarity, and it complicates menu transparency for the hospitality industry as they try to comply with CoOL regulations.
The CoOL regime needs to be rethought with a stronger consumer focus, emphasizing clear, accurate, and meaningful origin information rather than broad, ambiguous categories.
Perhaps most ironically, exporters from Australia must comply rigorously with the AFNS for species identification on outbound products—adding regulatory layers and audits—while, domestically, imports and retailers often circumvent these safeguards with vague or misleading naming. This double standard place public health at risk and undermines the credibility of Australia’s seafood regulatory framework.
This revised section captures the regulatory gaps around HS code linkage, the voluntary status of AFNS domestically, and the shortcomings of the CoOL system, highlighting why these issues threaten food safety and consumer confidence. It also fairly notes industry challenges and the call for a consumer-centered rework of labeling laws.
Why Australian Government Action Is Needed ?
Australia positions itself as a leader in the fight against IUU fishing at sea, but on land, the regulatory gaps undermine these efforts:
- seafood is a prime vector for mislabeling, fraud, and unregulated supply chain risks.
- Harmonising HS codes with mandatory AFNS use (not just for exports) would provide consumer-centric, traceable, and auditable food safety outcomes.
- Genuine enforcement of species naming—aligned with the global customs system—would enable better recalls, reduce fraud, and increase trust throughout the seafood supply chain.
- Revisiting the CoOL system is essential to meet consumers’ needs but considering the complexities of the hospitality industry. If it cannot be improved, then it should be withdrawn.
Major seafood consumer and industry advocates argue for making the Australian Fish Names Standard (AS5300) mandatory for all seafood —not just exports—so every product, imported and domestic, is subject to robust, auditable traceability. Linking HS codes with AFNS and scientific identifiers (CAAB codes) would close loopholes, boost retail transparency, and ensure that consumers are told exactly what species they are eating.
The Road Forward: Tightening the Net
To rebuild confidence and safeguard public health, the Australian Government needs to:
- Move quickly from voluntary to mandatory AFNS adoption in the domestic market so all retailers, importers, and processors are held to the same standard.
- Enforce harmonisation of HS codes with AFNS and bring them under the same traceability and food safety requirements as local products.
- Ensure that overseas products are not shielded from scrutiny and recall by regulatory loopholes, given how much of Australia’s seafood is imported.
Conclusion
Australia’s ICEP and broader IUU fishing response is strong in enforcement at sea, but weak in connecting regulatory dots on land. Consumers deserve supply chain transparency and safety assurance—making mandatory AFNS uptake and HS code alignment critical next steps. Without these reforms, food safety, traceability, and supply chain integrity are at risk, putting both public health and national reputation on the line.
For genuine seafood consumer confidence, Australia must tighten IUU controls—not just at the border, but throughout what lands on our plates.