NOAA thinks SIMP imports cost US companies $20. Are they right?

Does SIMP compliance really cost $20?

Importers, brokers and vendors: Click here to complete our 5-minute survey on SIMP to make the industry’s efforts heard as the government considers expansion! Special thanks to NCBFAA for partnering on this effort.

Earlier this month, we asked NOAA for more time to review its cost assessment for its proposal to expand the Seafood Import Monitoring Program (SIMP) and got 30 more days. Here’s how we’re making the most of it:

When we saw the table below in the Regulatory Impact Review, our first thought was that these figures look low. We built Goldfish to help ease the pain of regulatory compliance for US seafood imports after years of observing and discussing industry's experience with compliance. Reading that SIMP audits should take importers just 30 minutes to work through, and entry filing takes brokers 18 minutes sounded very, very optimistic.

We’re obsessed with data-driven analytics, so the standard narrative public comment letter didn’t feel right. Instead, we reverse-engineered the table above into an industry survey to test our assumptions and provide feedback to NOAA. The survey allows importers, customs brokers and other service providers to offer feedback on each assumption without digging into an incredibly dense report (even for us, and we reverse-engineer government cost estimates for fun). When the survey closes on April 21, we will anonymize the data and produce a revised table with industry-sourced figures. The results so far are fascinating, and we can’t wait to share what we learn!

Let’s talk strategy for a minute because, if we’re honest, there are more accurate ways to estimate the burden of regulations. Our goal is to influence this regulation, and we will have our best shot by making our proposal the path of least resistance. In this case, it means giving edits that are effortless to incorporate. If NOAA accepts them, the justification is clear. If not, they will have to justify why industry data shouldn’t be considered. Either way this turns out, we’re proud of the effort – it is one small way we can use our expertise to help ensure our customers are fairly considered when the government writes regulations.

One last plug: please take 5 minutes to fill out our SIMP compliance cost survey by April 21 if you are an importer, broker or service provider experienced with SIMP!