From 00:00 on January 1, 2026, any seafood shipment arriving at U.S. ports without a Certificate of Admissibility (COA) will face the risk of being denied customs clearance. NOAA has confirmed that there will be no exemption mechanism for inventory already in stock or goods currently in transit if the import date falls within the effective period of the regulation. Therefore, if enterprises do not proactively complete COA documentation from now on, the risks of cargo congestion, additional warehousing costs, and refusal of customs clearance are very real.
1. New COA Certification Requirements
According to the latest announcement from the U.S. National Oceanic and Atmospheric Administration (NOAA), Vietnam has only been partially recognized as equivalent for 11 fishery codes. This means that products belonging to these categories must have a Certificate of Admissibility (COA) in order to be eligible for customs clearance.
Currently, the Ministry of Agriculture and Environment has issued Circular No. 74, decentralizing the authority to issue COA certificates to local fisheries authorities to support enterprises in completing procedures more quickly. However, Mr. Le Huu Tuan Anh notes that enterprises must carefully check the HTS (Harmonized Tariff Schedule) codes to accurately determine which shipments are subject to mandatory certification, in order to avoid unnecessary confusion.
A greater challenge lies in the 12 fishing gear codes that have not been recognized by the U.S., meaning that products from these fisheries will be completely banned from entering the U.S. market. In light of this risk, the Directorate of Fisheries advises enterprises to strictly monitor traceability from the input stage. In particular, companies importing raw materials for processing and export must absolutely avoid sourcing from countries or fisheries that are on the U.S. blacklist to prevent losses due to rejected shipments.
2. List of 12 Fishing Gear Codes Not Recognized as Equivalent Under U.S. MMPA Regulations
- 2932: Grouper fishing using gillnets and bottom trawls
- 2988: Crab and other crustacean fishing using gillnets, trawls, traps/stationary nets
- 2990: Cuttlefish, demersal fish, flounder, grouper, mullet, snapper, halibut fishing using gillnets, longlines, trawls
- 2991: Shortfin scad fishing using gillnets and longlines (pelagic fishery)
- 2992: Lobster fishing using bottom gillnets
- 2994: Mackerel fishing using gillnets and purse seines
- 3051: Mackerel fishing using gillnets and purse seines
- 3052: Mullet fishing using bottom gillnets
- 3054: Mackerel fishing using midwater gillnets
- 3057: Pelagic fish and tuna fishing using gillnets
- 13124: Bigeye tuna, skipjack tuna, yellowfin tuna fishing using midwater gillnets and surface purse seines
- 13125: Marlin and swordfish fishing using midwater gillnets and handlines
3. Eleven Vietnamese Fishing Gear Codes Recognized as Equivalent
- 2979: Squid fishing using lift/drop nets and bottom trawls
- 2984: Anchovy and herring/sardine fishing using purse seines
- 2985: Yellowfin tuna and bigeye tuna fishing using handlines and rod-and-line
- 2986: Octopus fishing using octopus traps
- 2987: Anchovy and herring/sardine fishing using purse seines
- 2989: Sea eel fishing using bottom trawls
- 3053: Yellowfin tuna, bigeye tuna, skipjack tuna, swordfish fishing using handlines, rod-and-line, and longlines
- 3055: Marine shrimp fishing using bottom trawls
- 3058: Mackerel and tuna fishing using purse seines
- 3059: Squid fishing using handlines, purse seines, and trawls
- 3061: Amberjack/red snapper fishing using bottom trawls