If you source, process, or sell tuna in 2026, forced labor compliance is no longer something you can put off. Five major regulations now directly affect how tuna brands operate, and each one comes with its own requirements, timelines, and risks. Here is a practical breakdown of what each regulation covers, what it means for your business, and how the Work in Fishing Convention principles running through all of them are shaping the new standard for supply chain accountability.
The forced labor compliance clock is ticking for tuna brands
Forced labor in seafood supply chains has moved from a reputational concern to a legal liability. Regulators in the US, EU, and UK have introduced or strengthened laws that require tuna brands to actively prove their supply chains are free from forced and child labor. Waiting for a violation to surface before acting is no longer a viable approach.
The five regulations below each target different parts of the supply chain, but they share a common thread: documentation, verification, and traceability at the source. If you cannot show where your tuna came from, who caught it, and under what conditions, you may find yourself unable to meet the requirements of any of them.
1: US Uyghur Forced Labor Prevention Act (UFLPA)
The UFLPA creates a rebuttable presumption that any goods with connections to the Xinjiang Uyghur Autonomous Region of China involve forced labor. For tuna brands, this matters because Chinese processing facilities handle a significant share of global tuna volume. If your supply chain passes through any facility with potential Xinjiang-linked inputs, including labor, materials, or components, US Customs and Border Protection may detain your shipment at the border.
To rebut the presumption and clear detained goods, importers need to provide clear and convincing evidence that the goods were not produced using forced labor. This means detailed supply chain mapping, vessel-level sourcing records, and documentation of labor conditions at processing facilities. General certifications alone are often not enough.
The UFLPA is actively enforced, and seafood has already appeared on CBP’s radar. Tuna brands importing into the US should audit their processing facility relationships and confirm whether any labor or input sourcing connects to flagged regions.
2: EU Corporate Sustainability Due Diligence Directive (CSDDD)
The CSDDD requires large companies operating in the EU to identify, prevent, and address human rights and environmental risks across their entire value chains. For tuna brands, this means going beyond your direct suppliers and looking at fishing vessel operators, crew recruitment agencies, and transshipment practices.
The directive aligns closely with the principles of the Work in Fishing Convention, particularly around crew welfare, recruitment practices, and the right to safe and fair working conditions at sea. Under the CSDDD, companies may need to conduct regular due diligence assessments, put in place corrective action plans, and report publicly on how they are managing identified risks.
Implementation is phased by company size, with the largest companies facing earlier deadlines. However, smaller brands in the supply chain of a covered company could face pressure to comply indirectly as their buyers update their own supplier requirements. Building your documentation now puts you ahead of that curve.
3: EU Forced Labour Regulation (FLR)
The EU Forced Labour Regulation takes a product-focused approach. It gives EU authorities the power to ban goods made with forced labor from the EU market, regardless of where in the world the forced labor occurred. Unlike the CSDDD, which focuses on company processes, the FLR targets the product itself.
For tuna brands, this regulation could affect both imports into the EU and goods already on EU shelves. If a product is found to involve forced labor at any point in its production, including at-sea harvesting, it could be withdrawn from the market and destroyed. The financial and reputational consequences of a product ban under the FLR could be significant.
The FLR is expected to apply from 2027, but investigations can look back at supply chain practices before that date. Companies that start building verifiable, first-mile labor records now will be in a much stronger position when enforcement begins.
Book a demo4: UK Modern Slavery Act (MSA) — evolving enforcement
The UK Modern Slavery Act requires companies above a certain revenue threshold to publish an annual statement disclosing what steps they have taken to ensure their supply chains are free from modern slavery and human trafficking. For years, enforcement was light and statements were largely unverified. That is changing.
The UK government has signaled stronger scrutiny of Modern Slavery Act statements, with some authorities pushing for more specific, evidence-based disclosures rather than generic policy commitments. Tuna brands selling into the UK market should expect their statements to face closer examination, particularly around fishing vessel labor conditions and crew recruitment practices.
The Work in Fishing Convention framework is increasingly referenced in UK enforcement guidance as the relevant standard for assessing labor conditions on fishing vessels. Brands that can point to vessel-level labor data, third-party audits, and social compliance certifications will be better positioned to meet the evolving expectations of UK regulators and major retailers.
5: US Seafood Import Monitoring Program (SIMP) expansion
SIMP already requires importers of certain seafood species to report harvest and chain of custody information at the point of entry into the US. The program is designed to combat illegal, unreported, and unregulated fishing, but its data requirements also create a foundation for labor compliance verification.
Ongoing discussions around SIMP expansion could bring additional species and data fields into scope, including labor-related information about vessel crews and fishing conditions. Some proposals have suggested requiring importers to certify that their seafood was not produced using forced labor as part of the SIMP filing process.
Even under the current SIMP framework, the documentation requirements for tuna importers are substantial. Vessel registration, flag state, fishing area, gear type, and chain of custody records all need to be accurate and traceable. Brands that automate their SIMP reporting using verified first-mile data reduce both their administrative burden and their risk of a compliance gap.
What compliance actually looks like across all 5 regulations
Across all five of these regulations, a few common requirements stand out. You need vessel-level data captured at the point of harvest, not reconstructed after processing. You need documented labor conditions tied to specific fishing trips and crews. And you need that information to be accessible quickly, because regulators and buyers do not wait.
The Work in Fishing Convention sets the international benchmark for labor rights on fishing vessels, covering areas like crew agreements, hours of rest, medical care, and repatriation. Several of the regulations above either reference it directly or use its standards as a baseline for assessing compliance. Building your traceability system around those standards gives you a defensible, internationally recognized framework.
Practically, this means moving away from manual documentation and post-processing record assembly. It means capturing data at sea using satellite tracking, linking crew welfare records to specific vessel trips and raw material batches, and storing everything in a format that regulators and auditors can verify independently.
SmarTuna’s digital traceability platform is built to do exactly that. It captures first-mile vessel data via satellite VMS and AIS, integrates social compliance certifications including BSCI, SMETA, and the FISH Standard for Crew directly into each batch record, and automates regulatory reporting for frameworks like SIMP. Every raw material batch gets a unique ID that links origin, labor conditions, and verification evidence, so when a regulator or retailer asks for proof, you have it ready.
[seoaic_faq][{“id”:0,”title”:”How do I know which of these five regulations actually applies to my tuna business?”,”content”:”Your exposure depends on where you source, process, and sell. If you import tuna into the US, UFLPA and SIMP apply directly. If you sell into the EU or operate as a large company with EU market presence, CSDDD and the FLR are relevant. If you sell into the UK above the revenue threshold (currently £36 million turnover), the Modern Slavery Act applies. Many tuna brands will fall under multiple regulations simultaneously, so it is worth mapping your full commercial footprint — sourcing origin, processing locations, and end markets — before deciding where to prioritize your compliance efforts.”},{“id”:1,”title”:”What is the single most important piece of documentation I should have in place right now?”,”content”:”Vessel-level harvest records tied to specific fishing trips are the foundation that every one of these regulations builds on. If you cannot identify which vessel caught your tuna, when, where, and under what labor conditions, you cannot satisfy the evidentiary requirements of the UFLPA, the FLR, or an evolving Modern Slavery Act statement. Start by auditing whether your current supply chain documentation reaches all the way back to the point of harvest, and identify where the gaps are between what you have and what a regulator would need to see.”},{“id”:2,”title”:”Our processing facilities are not in Xinjiang — does the UFLPA still apply to us?”,”content”:”Yes, it can. The UFLPA’s rebuttable presumption extends to goods that have any connection to Xinjiang, including inputs, components, or labor recruited from the region — not just goods physically produced there. If your processing facility sources any materials, packaging, or labor through channels that touch Xinjiang, CBP may still flag your shipment. The safest approach is to conduct a full input-level audit of your processing partners, not just a facility-level check, and document that audit thoroughly.”},{“id”:3,”title”:”The EU Forced Labour Regulation doesn’t take effect until 2027 — is it too early to start preparing?”,”content”:”No — and the regulation itself makes this clear. Investigations under the FLR can examine supply chain practices that predate the enforcement date, which means the labor conditions and documentation practices you have in place today could be scrutinized tomorrow. Companies that begin building verifiable, first-mile labor records now will have a multi-year track record to present when enforcement begins, while those who wait until 2027 will be starting from scratch under active regulatory pressure.”},{“id”:4,”title”:”What does the Work in Fishing Convention actually require, and how do I use it as a compliance framework?”,”content”:”The Work in Fishing Convention (ILO C188) sets minimum international standards for labor conditions on commercial fishing vessels, covering crew agreements, hours of work and rest, medical care, food and accommodation, and repatriation rights. To use it as a compliance framework, you need vessel-level records that demonstrate adherence to each of these areas for specific fishing trips and crew members. Third-party certifications like the FISH Standard for Crew are built directly on C188 principles and provide an auditable, internationally recognized way to demonstrate compliance to regulators and buyers.”},{“id”:5,”title”:”How should I handle supplier relationships where I cannot get full labor documentation from the vessel operator?”,”content”:”This is one of the most common implementation challenges, and it carries real risk. If a vessel operator cannot or will not provide labor condition records, your options are to work with them to build that documentation capacity, source from operators who already have it, or accept the compliance exposure of a gap in your records. Given the evidentiary standards required by the UFLPA and the FLR in particular, undocumented vessel relationships are increasingly difficult to defend. Engaging a traceability platform that captures vessel data directly via satellite — rather than relying on self-reported records from operators — significantly reduces your dependence on supplier cooperation.”},{“id”:6,”title”:”Can social certifications like SMETA or BSCI replace the need for vessel-level traceability data?”,”content”:”No — certifications and traceability data serve different but complementary roles. Social certifications like SMETA or BSCI verify that a facility or operation meets a defined labor standard at a point in time, but they do not provide the batch-level, trip-level, or vessel-level linkage that regulators increasingly require. Under the UFLPA, for example, general certifications alone have been deemed insufficient to rebut the forced labor presumption. The strongest compliance position combines recognized social certifications with granular, verifiable traceability data that ties each batch of tuna to a specific vessel, trip, and documented set of labor conditions.”}][/seoaic_faq]