24-hour hotline : 23 922 922
e-mail address : enquiry@tid.gov.hk
Ref. : EIC 111/2
2 September 2025
(Updated on 5 February 2026)
Dear Sirs,
Further to Commercial Information Circular (CIC) no. 839/2023 of 20 November 2023, the US National Oceanic and Atmospheric Administration (NOAA) announced on 2 September 2025 the implementation of trade restrictions for certain fish and fish products1 under the import provisions of the Marine Mammal Protection Act (MMPA) effective from 1 January 2026.
2.Under the original timeline and subsequent extensions of the exemption period, the US would implement new requirements for imports of fish and fish products to the US under the MMPA import provisions effective from 1 January 2026 and failure to comply may result in import prohibitions for fish and fish products. For details, please refer to CICs no. 648/2021, 928/2022 and 839/2023 of 14 September 2021, 25 November 2022 and 20 November 2023 respectively.
3.On 2 September 2025, the US NOAA issued a Federal Register (FR) notice announcing comparability finding2 determinations under the MMPA for all fisheries on the List of Foreign Fisheries for harvesting nations/economies that export fish and fish products to the US. Nations/economies whose fisheries were denied comparability findings will be prohibited from importing fish and fish products from those fisheries into the US beginning 1 January 2026. Until such time as the import restrictions imposed by this action are lifted or revised, trade restrictions on these products associated with the fisheries for which a comparability finding has been denied will continue and Certification of Admissibility3 will be required. Comparability findings announced in the notice and compliance with the import restrictions and Certification of Admissibility requirements described in the notice are required beginning 1 January 2026, and will remain in effect until 31 December 2029, unless otherwise specified. For the list of nations/economies including the individual fisheries receiving and not receiving comparability findings, as well as the Harmonized Tariff Schedule codes associated with the prohibited fish and fish products, please refer to the US NOAA’s web links in the notice.
4.For further details, please refer to the FR notice at https://www.govinfo.gov/content/pkg/FR-2025-09-02/pdf/2025-16776.pdf and the US Customs and Border Protection’s message at https://content.govdelivery.com/bulletins/gd/USDHSCBP-4075785?wgt_ref=USDHSCBP_WIDGET_2.
5.For enquiries concerning the content of this circular, please contact us at telephone number 2398 5405.
Yours faithfully,
(Miss Kwany KOU)
for Director-General of Trade and Industry
1 “Fish and fish products” under MMPA is defined as any marine finfish, mollusk, crustacean, or other form of marine life other than marine mammals, reptiles, and birds, whether fresh, frozen, canned, pouched, or otherwise prepared.
2 A comparability finding is a finding by the US NOAA that the harvesting nation/economy has met the applicable conditions specified in the US regulation.
3 If fish or fish products are subject to an import prohibition under the MMPA, the US NOAA may require that the same or similar fish and fish products caught or harvested in another fishery of the harvesting nation/economy and not subject to the prohibition be accompanied by a Certification of Admissibility.
Note: While every effort is made to ensure the accuracy of the above information, the Department cannot guarantee this to be so and will not be held liable for any reliance placed on the same.