SIMP Compliance for Indonesian Tuna: The Importer’s Checklist We Actually Use
SIMPIndonesian tunaNOAAIFTPACEFAO areascompliancetransshipment

SIMP Compliance for Indonesian Tuna: The Importer’s Checklist We Actually Use

10/2/20258 min read

A practical, importer-side guide to SIMP for Indonesian yellowfin, skipjack, and bigeye tuna. Exactly which documents and harvest data to collect, how to validate vessel IDs and FAO areas, how to map info to ACE, and the pitfalls that trigger NOAA/CBP holds.

If you’ve ever had a tuna shipment stuck in “Documents Required” at US Customs, you know the pain. In our experience, 8 out of 10 SIMP issues on Indonesian tuna trace back to the same handful of mistakes: wrong FAO area, missing vessel IDs, unclear transshipment details, or trying to reuse an EU catch cert as SIMP. The good news is you can avoid nearly all of this with a tight checklist and clean data mapping.

Below is the exact, practical flow we recommend for US importers buying Indonesian wild-caught tuna (yellowfin, skipjack, bigeye) in whole round, H&G, loins, or steaks. Canned tuna is generally not subject to SIMP. Fresh/frozen is.

A SIMP-first checklist for Indonesian wild-caught tuna

We start at the end: what does NOAA expect your ACE SIMP filing to contain, and what proof can you show in an audit? Work backward and request only what you actually need.

Do I need an IFTP to import Indonesian tuna into the US?

Yes. Every importer of record filing SIMP must hold a valid International Fisheries Trade Permit (IFTP) under NOAA’s National Permitting System. It’s online, paid, and renewed annually. We recommend applying at least a week before your first SIMP entry so you’re not rushed. Brokers can’t file SIMP for you without your active IFTP number.

Immediate takeaway: Confirm your IFTP is current before you book production. An expired permit is a preventable hold.

What SIMP documents should I request from an Indonesian tuna supplier?

Ask for documents that map cleanly to SIMP’s “who, what, when, where, how” harvest elements and chain of custody. For Indonesian tuna, we request:

  • Harvest event data sheet per lot. Species (common and scientific), gear type, vessel name and flag, IMO or UVI, trip start/end dates, catch date range, FAO area, estimated catch weight tied to the lot, and vessel license/authorization number. One row per harvest event feeding your lot.
  • Vessel ID proof. Equasis printout for IMO vessels, or UVI evidence for smaller vessels (national registry or RFMO list). Include photos of hull markings if available.
  • Logbook or trip ticket excerpts. Pages showing dates, gear, area, and vessel name. Don’t ask for everything, just the relevant pages that substantiate the harvest data.
  • Transshipment and landing records if applicable. RFMO observer transshipment declaration, carrier vessel details, date, position, and receiving port documents.
  • Processor production/lot records. How raw fish from specific harvest events were converted into your final SKU and lot. Show weights and yields.
  • Commercial set. Invoice, packing list, labels/cartons indicating species, cut, net weights, and lot codes that link back to production records.

We keep this bundle minimal but sufficient. Extra PDFs don’t help if the key fields don’t reconcile.

Which FAO area should I report for tuna caught near Indonesia?

Most Indonesian tuna is caught in one of two FAO areas:

  • FAO 57. Eastern Indian Ocean. Typical for longliners operating west/south of Sumatra and south of Java. Landings often through Benoa or Cilacap.
  • FAO 71. Western Central Pacific. Typical for handline, pole-and-line, purse seine activities around eastern Indonesia and the Banda/Timor/Seram seas, and landings through Bitung, Ambon, Sorong, or Kendari.

If your documentation mentions IOTC and Indian Ocean sets, you’re probably in FAO 57. If it mentions WCPFC activities or eastern Indonesia grounds, FAO 71 is more likely. Don’t guess. Cross-check vessel authorizations and the trip coordinates against the charts your supplier provides.

Immediate takeaway: Wrong FAO codes are a top-3 rejection reason. Verify against the RFMO and landing port pattern. Map visualization of Indonesia highlighting two key tuna fishing areas: the eastern Indian Ocean to the west/south of Sumatra and Java, and the western Pacific around eastern Indonesia, with dotted vessel tracks and markers at major landing ports like Benoa, Cilacap, Bitung, Ambon, Sorong, and Kendari; no text shown.

How do I verify an Indonesian fishing vessel’s IMO or UVI number?

  • For IMO vessels. Use Equasis to confirm the IMO number, vessel name, flag, and history. Watch for name changes that don’t match your documents. Screen for IUU listings.
  • For UVI on smaller vessels. Ask for the national registration/UVI evidence issued by Indonesia’s authorities or the RFMO Authorized Vessel Lists (IOTC/WCPFC). Match the name/ID exactly across documents.

Practical tip: We ask suppliers for a photo of the hull showing the vessel name and ID. It catches typos early.

What gear type should I enter for Indonesian handline or longline tuna?

Use the standard NOAA gear descriptions or codes your broker’s ACE template expects:

  • Handline. HL, single hook-and-line. Common for yellowfin in eastern Indonesia. Don’t confuse with pole-and-line.
  • Longline. LL, pelagic longline. Common in the Indian Ocean.
  • Pole-and-line. PL, live-bait fishery, often for skipjack.
  • Purse seine. PS, common for skipjack/juvenile yellowfin. If FAD sets or free-school sets are specified, keep the description but the gear stays PS.

Your goal is consistency. The gear on the harvest sheet must match the trip records and RFMO authorization.

How to map harvest data to ACE SIMP filing without rework

This is where many teams lose days. We use a simple, rigid structure:

  1. Create a master harvest file. One row per harvest event feeding your entry. Columns: species, scientific name, gear, FAO area, vessel name, flag, IMO/UVI, trip dates, catch date range, transshipment details (if any), landing port/date, harvest event weight allocated to your lot.

  2. Tie production lots to harvest events. Your Indonesian processor should show how each harvest event contributes to your finished lot. Yields must make sense. If you’re importing 10,000 kg loins, there must be enough raw catch behind it.

  3. Mirror your broker’s ACE template. Copy exact field names and valid code lists. Pre-validate species names (e.g., Thunnus albacares for yellowfin), gear codes, and FAO numeric codes to avoid free text.

  4. Lock the numbers. Net weights on the invoice should reconcile to SIMP quantities aggregated from harvest events. Discrepancies over 2-3% will draw attention.

Need a sanity check on your mapping or a sample harvest template? If you want a quick review before you book production, Contact us on whatsapp and we’ll share the format we use with US importers.

Transshipment and landing documentation that passes audits

Transshipments aren’t a problem if they’re documented. Ask for:

  • At-sea transshipment declaration with observer endorsement where required by IOTC/WCPFC.
  • Carrier vessel name, flag, and IMO, plus date, position, and product transferred.
  • Evidence of first landing port and date. This connects the chain from harvest to shore.

If there was no transshipment, get a simple statement in the harvest sheet: “No transshipment. Direct landing at [port] on [date].” That one line has saved us days during audits.

Recordkeeping: how long and what exactly to keep?

SIMP requires you to keep all supporting records for at least two years and provide them to NOAA upon request. We keep:

  • Harvest data sheets tied to lots
  • Logbook/trip ticket excerpts, vessel IDs (Equasis/RFMO), licenses/authorizations
  • Transshipment declarations and landing docs
  • Processor production and lot reconciliation records
  • Commercial invoice, packing list, bills of lading, labels

Organize by entry number, then by lot. When NOAA asks, response time is short. Having a single PDF bundle per lot has made our audits straightforward.

Common SIMP rejection pitfalls and how to avoid them

  • FAO area mismatch. FAO 57 vs 71 confusion. Match RFMO and landing patterns.
  • Missing or invalid vessel ID. No IMO/UVI, or name/ID inconsistency. Verify in Equasis/RFMO lists.
  • Gear confusion. Handline recorded as pole-and-line, or vice versa. Align gear across all documents.
  • EU catch certificate submitted as SIMP. They’re different regimes. EU docs don’t replace SIMP data elements.
  • Species naming. “Tuna” isn’t enough. Use scientific names tied to specific HTS lines.
  • Weight reconciliation. Invoice net weights don’t tie to harvest allocations. Lock your math before sailing.
  • Transshipment gaps. No carrier details or position/date. Get the declaration or a no-transshipment statement.
  • IFTP issues. Expired permit or wrong importer of record.

We’ve seen an uptick in data-quality holds in the last few months, especially around transshipment details and FAO areas. A 10-minute pre-check against this list avoids week-long delays.

Quick reference: the SIMP data elements you must capture for Indonesian tuna

  • Species: common and scientific (e.g., Yellowfin Tuna, Thunnus albacares)
  • Product form at import: whole/H&G/loins/steaks, fresh or frozen
  • Harvest method (gear): HL, LL, PL, PS
  • Harvest area: FAO 57 or 71 for most Indonesian tuna
  • Vessel details: name, flag, IMO or UVI, license/authorization number
  • Harvest/trip dates: start/end, and catch date range
  • Transshipment info: yes/no; if yes, carrier vessel name/flag/IMO, date, position, observer declaration
  • First landing: port and date, entity at landing
  • Chain of custody to your processor: how fish moved from landing to processing
  • Quantities: harvest event weights allocated to your lot and reconciled to invoice

Final word

Here’s the thing. SIMP isn’t hard. It’s unforgiving. The system rewards clean, consistent data and penalizes small mismatches. We recommend building your purchase orders around data deliverables, not just price and cut. The Indonesian fleets and processors we work with can provide everything above. The difference between a smooth clearance and a hold is whether the importer asks for it upfront.

Questions about your current setup or a shipment in progress? If you want a quick, practical second look, Contact us on whatsapp. We’re happy to sanity-check FAO areas, vessel IDs, and your ACE mapping before you file.