Earlier today, the Ad Hoc Shrimp Industry Committee filed papers with the U.S. International Trade Commission requesting permission to participate in the Commission’s investigation of the impact of unfairly traded imports on the domestic shrimp industry. The Committee is comprised of 180 commercial fishing businesses, unloading/shoreside facilities, shrimp processors and wholesalers, as well as seafood industry organizations from throughout the country.
The individual members of the Committee reflect the breadth and diversity of the domestic shrimp industry, including the only two identified processor participants in the U.S. Department of Commerce’s 2012 voluntary Seafood Inspection Program for frozen non-breaded shrimp products.
The Committee’s filing today represents the first formal action taken by the domestic shrimp industry in response to the countervailing duty petitions filed by the Coalition of Gulf Shrimp Industries (COGSI), a group of 30 shrimp processors and unloading docks located in the Northern Gulf. Although the Committee has taken no position regarding the petitions, participation in the proceedings facilitates the domestic industry’s capacity to monitor developments.
Members of the domestic shrimp industry are generally supportive of measures designed to address unfair trade. Subsidies that are granted to foreign shrimp industries provide an unfair advantage to imports in the U.S. marketplace. The elimination of such subsidy programs would help to level the playing field for all shrimp producers.
Nevertheless, there are aspects of the petitions that raise questions. In a supplemental submission to the U.S. Department of Commerce on Wednesday, COGSI submitted a table indicating that its membership accounted for 97.76% of all frozen warmwater shrimp processed in the United States. This is impossible.
COGSI’s claim is based on NOAA’s reporting of data regarding shrimp processing in the United States. NOAA obtains these data through surveys of seafood processors around the country. The Southern Shrimp Alliance, in turn, tracks the information compiled by NOAA. These data provide useful information regarding the health of the overall domestic shrimp industry. Because NOAA’s reporting of shrimp processing data has been largely consistent over the last decade, it should be possible to reconcile COGSI’s claims with NOAA’s data.
In 2011, NOAA reports that one out of every two pounds of shrimp processed in the United States was processed by 29 companies in three states: Texas, Florida, and California. COGSI’s membership includes only one processor in Florida and two processors in Texas. It includes no processors in California. As such, COGSI’s production figures do not include the shrimp processing production of 26 of the 29 seafood processors in those three states. In order for COGSI’s claims to be accurate, these 26 seafood processors would only have produced less than 3.4 million pounds of frozen warmwater shrimp collectively in 2011.
COGSI’s claim to represent virtually all domestic frozen warmwater shrimp processing is inconsistent with NOAA’s reporting and, moreover, is inconsistent with the structure and composition of the domestic shrimp industry. By participating in the Commission’s investigation, the Ad Hoc Shrimp Industry Committee seeks to provide a more accurate portrayal of the industry and its constituent members.
Download the entry of appearance filed by the Ad Hoc Shrimp Industry Committee with the U.S. International Trade Commission: http://www.shrimpalliance.com/wp-content/uploads/2013/01/Entry-of-Appearance-and-APO-Applications.pdf
Download the revised table of “Industry Support for the Petitions” submitted to the U.S. Department of Commerce by COGSI here:
Download summary tables of U.S. shrimp processing statistics from 2003 through 2011 maintained by the National Marine Fisheries Service, Office of Science and Technology, Fisheries Statistics Division here: http://www.shrimpalliance.com/wp-content/uploads/2013/01/Summary-Tables-NOAA-Shrimp-Processing.pdf