AI agents for business finance: what they can and can't do
What AI agents can do in bookkeeping, close, collections and compliance today, where a person must stay in charge, and how to judge a product.
The short answer
Commercial stockfish, dried fish and crayfish come under the FDA's seafood HACCP rule, so the US importer must verify each foreign processor under 21 CFR 123.12, and the FDA's Nigeria import alerts cover uneviscerated dried fish and seafood Salmonella. NOAA paperwork applies too where the species or HTS code is covered: cod and shrimp are in NOAA's Seafood Import Monitoring Program, and since 1 January 2026 fish from fisheries denied comparability findings under the Marine Mammal Protection Act are banned.
Two agencies, two questions
The FDA asks whether the fish is safe. NOAA Fisheries asks whether it was caught legally and in a way that meets US marine mammal standards. A shipment of dried fish from Lagos can need answers for both, depending on the species and the tariff code, and the answers belong to the importer.
The FDA side: seafood HACCP
Fish and fishery products are outside the general Foreign Supplier Verification Program if the supplier complies with the FDA's seafood HACCP rule in part 123. In place of FSVP, section 123.12 makes the importer prove it. Unless the product comes from a country with an FDA memorandum of understanding, you need written verification procedures that include:
- product specifications designed to make sure the fish is not adulterated; and
- affirmative steps, such as obtaining the processor's HACCP and sanitation records for each lot, a continuing or lot-by-lot certificate from an inspection authority, regular inspection of the processor, an English copy of its HACCP plan with a written guarantee, or periodic testing.
A third party can carry out these steps for you, and records must be in English. If you cannot show adequate assurance, the regulation says the product will appear adulterated and be denied entry.
Import alerts that touch dried fish from Nigeria
| Alert | Subject | Why it matters |
|---|---|---|
| 16-74 | uneviscerated or partially eviscerated fish that are salt-cured, dried or smoked | whole dried fish with guts in is a classic Nigerian product and sits squarely in this alert |
| 16-81 | seafood products with Salmonella | dried crayfish and fish dried in the open |
| 16-119 | fish and fishery products, importer and foreign processor HACCP | targets firms that cannot show HACCP compliance |
The FDA's Nigeria country page listed all three when it was posted on 21 October 2026. Whole fish that has not been gutted is the hardest to import; gutted, cleaned product from a processor with a written HACCP plan stands a better chance. For the home-traveller side of this, see is dried fish from Nigeria allowed into the US.
The NOAA side: SIMP and the MMPA
Seafood Import Monitoring Program
NOAA's Seafood Import Monitoring Program covers 13 species groups, around 1,100 species: abalone, Atlantic cod, Atlantic blue crab, dolphinfish, grouper, red king crab, Pacific cod, red snapper, sea cucumber, sharks, shrimp, swordfish and five tunas. For those, NOAA says importers must report key data from harvest to entry into US commerce, which NOAA traces through the International Trade Data System; its page also links to the International Fisheries Trade Permit application, so ask your broker whether you need one. Stockfish is commonly dried cod, so check the species with your supplier; if it is Atlantic or Pacific cod, SIMP applies. If what is sold as "crayfish" is in fact a shrimp species, SIMP applies to that too. NOAA's page does not single out dried forms, so ask your broker how the HTS code you use is flagged.
Marine Mammal Protection Act import bans
Since 1 January 2026, fish and fish products from fisheries that NOAA has denied a comparability finding are prohibited. NOAA publishes the prohibited fisheries and flagged HTS codes in spreadsheets; we did not confirm the entries for Nigeria, so check the current list. Where a country of origin and HTS code combination is flagged, entry needs a Certification of Admissibility, specific to the shipment, signed by an authorised official of the foreign government and uploaded to CBP's ACE document system.
Origin is where the fish was produced
Stockfish is commonly imported into Nigeria rather than made there. If your supplier in Lagos re-exports dried cod made in another country, that country is its origin for NOAA, the FDA and customs duty, and its own fishery status decides MMPA admissibility. Ask for the producer's documents, not only the trader's invoice.
Worked example
Example: a Houston wholesaler wants 800 kg of gutted, dried catfish and 200 kg of dried crayfish from a Lagos processor. Catfish is not one of the SIMP groups, so her checks focus on the FDA: an English HACCP plan from the processor, lot records for each consignment, and photographs showing the fish are eviscerated, given Import Alert 16-74. For the crayfish she asks for the species name first; if it turns out to be a shrimp species, she adds the SIMP data to the entry. She then checks the MMPA lists for both products against their HTS codes.
Steps before the first order
- Identify the species by scientific name and the producing country.
- Get the processor's HACCP plan in English and decide your 123.12 verification steps.
- Check the FDA Nigeria import alerts for the product form, especially uneviscerated fish.
- Check NOAA's SIMP species list and the MMPA prohibited and flagged lists.
- Confirm the Nigerian facility's FDA registration and have your broker file prior notice.
Duty is a separate step; see current US tariffs on Nigerian goods.
Where Pryme fits
Seafood importers often pay a deposit to secure a lot and the balance once documents check out. A Pryme Business Account holds USD and NGN with local details, so you can pay a Lagos supplier in naira with Swap; the app shows the rate and the fee before you approve. See business multicurrency accounts.
Questions people ask
Do I need NOAA paperwork for stockfish?
If the stockfish is Atlantic or Pacific cod, NOAA's Seafood Import Monitoring Program applies, with harvest-to-entry data reported at entry. Check the MMPA lists as well.
Can I import dried fish with the guts in?
It is very difficult. Import Alert 16-74 covers uneviscerated or partially eviscerated salt-cured, dried or smoked fish from Nigeria, so such shipments can be detained without examination.
Does FSVP apply to dried fish?
Not if the supplier complies with seafood HACCP; the importer instead follows the verification rules in 21 CFR 123.12.
Is crayfish covered by NOAA rules?
Only if the species is in a covered group, such as shrimp under SIMP, or its HTS code is flagged under the MMPA. Identify the species first.
Sources
- eCFR: 21 CFR 123.12, Special requirements for imported products (fish and fishery products) · accessed Oct 2026
- FDA: Import alerts by country, Nigeria (posted 21 Oct 2026) · accessed Oct 2026
- NOAA Fisheries: Seafood Import Monitoring Program (last updated 30 May 2025) · accessed Oct 2026
- NOAA Fisheries: Seafood import prohibitions under the Marine Mammal Protection Act import provisions (last updated 6 Oct 2026) · accessed Oct 2026
- eCFR: 21 CFR Part 1, Subpart L, Foreign Supplier Verification Programs for food importers (current text) · accessed Oct 2026
This article is general information, not financial, legal or tax advice. Products described are provided under the terms on this site and are subject to regulation and eligibility.