Correspondence
Email sent to the contact address for PanaPesca USA.
The email described the general findings of The Outlaw Ocean Project's investigation into China's squid fishing fleet, and then provided specific links between those findings and PanaPesca’s supplier, Zhejiang Industrial Group. It said that two vessels owned by a company under Zhejiang Industrial Group’s majority owner, Zhejiang Shengda Ocean Co. Ltd., have a history of disabling their vessel tracking, while footage shows a Zhejiang Industrial Group worker unloading squid for the plant from a vessel on which an Indonesian worker died. The email asked if the company had any comment in light of the information discovered in The Outlaw Ocean Project investigation.
TJ Winick, Senior Vice President of Issues Management Group, emailed a statement from PanaPesca: “PanaPesca holds the suppliers of our seafood to the highest of standards by demanding that our product is procured in a safe, environmentally conscious, and socially responsible way.
To ensure these standards are achieved, we continually monitor our supply chain from the source so that we achieve the consistent performance our customers expect of our products. This process includes unannounced spot-checks of our suppliers around the world by PanaPesca’s own employees and audits of these production facilities by internationally recognized third- party food safety inspection organizations.
Among those suppliers are Zhejiang Industrial Group, a seafood processor located in Zhejiang, China. A text message recently sent by your group to one of PanaPesca’s customers alleged that a fishing vessel beneficially owned by one of Zhejiang Industrial Group’s owners had a crew member die in 2019 under mysterious circumstances.
We asked Zhejiang Industrial Group about this claim and were told that the crew member died of a heart attack at sea and that, in accordance with maritime protocol, his body was brought to port in Uruguay. An autopsy performed by local authorities confirmed that he had died from a heart attack, and that at the request of the crew member’s family and with the permission of the local government in Uruguay, the crew member’s body was cremated, and his ashes transported back to his family.
At no time has Zhejiang Industrial Group ever appeared on any industry list of firms accused of illegal fishing abuses. In fact, PanaPesca has never knowingly done business with any company accused of IUU (illegal, unreported, and unregulated) practices.
In addition, all high seas squid caught for PanaPesca is from Argentine flagged vessels. PanaPesca does not use any squid from Chinese flagged vessels.
PanaPesca prides itself on being a global leader in working to prevent any illegal, unregulated, unreported fishing & human rights abuses in the squid fishing industry. To that end, we have joined our colleagues in the Sustainable Fisheries Partnership to prevent this abuse by being a public signatory to the commitments made by the Squid IUU Prevention Group in July 2021.
Note: PanaPesca did not intentionally fail to respond to your organization’s inquiry in March 2023. In fact, the employee who monitored that inbox left PanaPesca a few weeks later and neglected to alert management that the email had been received. PanaPesca prides itself on the high-level of transparency with which it operates and is typically very responsive to any inquiries.”
TJ Winick, Senior Vice President of Issues Management Group, emailed on behalf of PanaPesca: “Hi Ian: You can read the language below from PanaPesca, but the net is that Zhejiang Industrial Group is only PanaPesca’s exporter NOT their supplier. That would be De Lai Men. There is documentation which backs this up, only the company doesn’t want their receipts posted on any site or in any story. As a result, PanaPesca is asking the Outlaw Ocean Project and The Boston Globe to not include their name in the piece that has posted and is printing. Please let me know your response and if you have any questions. Thank you, T.J.”
In the same email from TJ Winick, he provided the following statement from Panapesca: “Panapesca USA have been working with Zhejiang Industrial since 2006, and, after several years of developing business in USA the processing plant of Zhejiang Industrial was no more able to support our needs, as their orders for their Japanese partner, Maruha, were increasing, and after many issues with delayed shipments and our increasing pressure, they decided to start moving our production to a third factory (outside of Zhejiang Industrial Group), Zhoushan De Lai Men Food Co., LTD, plant code 3300/02081, after a couple of years of packing some product in Zhejiang and most in De Lai Men, from about June 2014 all our production was moved to De Lai Men factory and have been this way since then.”
The email also said: “Here attached copies of some documents from some of the shipments, from were it is easy to see the actual production plant. Initially the FDA reg. Number of De Lai Men factory was 17636124638 then was updated to 10607299214. Zhejiang Industrial was only financially supporting De Lai Men, providing them with the Raw Material for our production that was sourced from Argentinian vessels, or New Zealand Vessels or Peruvian vessels, or Chinese Vessels under our Todarodes FIP, as per our requirements, and then invoicing us for the shipments.” Though the email said documents were being attached, none were attached. Presumably, these were the receipts that TJ Winick said the company did not want to share.
The Outlaw Ocean Project wrote PanaPesca: "Thank you again for engaging with us on this topic. We also appreciate your phone call on October 13, 2023. In that phone call you apologized for having not replied to our initial set of questions that we emailed to PanaPesca on March 13, 2023. You also explained in the phone call that someone on PanaPesca’s side was not watching the relevant email inbox as they should have been. PanaPesca’s subsequent written responses are helpful. However, they leave many things in need of clarification. Below we offer some additional context and more questions that we hope to get answered.
Firstly, there is the issue of the Dong Yu 1519, the ship that unloaded a dead crew member into the port of Montevideo. Your statement that you sent in the October 13, 2023 email says the crew member’s death was deemed as a heart attack as though that is definitive proof that beriberi was not involved. However, as you may know, heart failure is the leading cause of death in cases of beriberi and, as such, beriberi is rarely identified as the cause of death. We consulted with a source in the DC medical examiner’s office in Washington DC on the matter. He emphasized that it is unusual that a healthy male would die of a heart attack without any underlying issues. We have found in our research that cases that have been described as heart attacks often carry additional symptoms of beriberi (such as swelling, fatigue, gastric issues, and so on). In fact, the focus on proximate causes as such is one of the bigger issues that our reporting highlighted as a reason that avoidable deaths tied to beriberi are more prevalent than they should be. As a result, we have since begun talking to crewmembers Dong Yu 1519 to get more details about the death. We will be sure to come back to you on the matter. Additionally: you mention that you are in touch, indirectly, with officials in Uruguay. Can you provide us with the autopsy so that we can review it? Obviously, in light of what we saw tied to Daniel Aritonang’s official cause of death and his autopsy by officials in Montevideo Uruguay, when he too was dropped off there, we are interested to look further into the case.
Secondly, there is the October 13, 2023 comment about PanaPesca only importing squid from Argentinian flagged ships. You wrote on October 13, 2023: “all high seas squid caught for PanaPesca is from Argentine flagged vessels. PanaPesca does not use any squid from Chinese flagged vessels....”. This we find is confusing. Argentinian-flagged vessels primarily fish in the Southwest Atlantic for illex squid, which PanaPesca does import, but PanaPesca also imports dosidicus gigas and todarodes pacificus squid from Zhejiang Industrial Group, from what we can tell based on trade and other records. Both species are endemic to the Pacific Ocean, where virtually no Argentinian vessels operate. You have told us that Zhejiang Industrial Group does source from Peru, but not in sufficient quantities to meet your needs. The trouble we have understanding your point about only receiving squid or other catch from Argentinian vessels is heightened with your next email on October 14, 2023, where, what you wrote seems to explicitly contradict the original claim. In the October 14, 2023 email you state that “Zhejiang Industrial was only financially supporting De Lai Men, providing them with the Raw Material for our production that was sourced from Argentinian vessels, or New Zealand Vessels or Peruvian vessels, or Chinese Vessels under our Todarodes FIP, as per our requirements, and then invoicing us for the shipments.” The wording in the above sentence that caught our attention is your admission of using “Chinese vessels under your todarodes FIP”. Doesn’t that mean you indeed get some of your squid from Chinese ships?
Thirdly, there is the issue of how Zhejiang Industrial Group, De Lai Men and PanaPesca are connected to each other. Apologies if we are confused here but we need some help parsing the matter. You emailed, TJ, on October 14, 2023: “You can read the language below from PanaPesca, but the net is that Zhejiang Industrial Group is only PanaPesca’s exporter NOT their supplier. That would be De Lai Men. There is documentation which backs this up, only the company doesn’t want their receipts posted on any site or in any story.” Obviously, we respect your desire not to provide documentation backing up your claim, though it does make it tough for us to verify your claims. But the bigger issue is that the statement from PanaPesca says plainly that the company has been taking “raw material” from Zhejiang Industrial Group, which in this context, of course, means they were taking catch from the processing plant. You also said in your October 14, 2023 email that Zhejiang Industrial was “financially supporting De Lai Men”. So, alas, we appear to have multiple contradictions and could use some help explaining the ties between Zhejiang Industrial Group, De Lai Men and PanaPesca.
Fourthly, there is a need to pause and talk about the issue of commingling. You wrote on October 13, 2023 that you ensure that your catch is only from Argentinian ships. But one of our core findings in this investigation is that traceability is fraught. As I am sure you know better than anyone, seafood products can be difficult to track from the point of harvest through processing, and distribution. In many fisheries, transshipment at sea and aggregations on land lead to the commingling of seafood caught by multiple vessels across multiple days or weeks. Commingling also happens at processing plants where catch from various ships is mixed as the supplier/processor facility operates largely behind closed doors and ships seafood to a downstream customer. Unlike some types of fish, like tuna, that can be tagged to some degree, squid does not lend itself to traceability in the same manner. When squid is cleaned and processed at plants, parts of it (surely from the same species) are easily mixed between various ships and batches. We do not know for a fact that this has happened with PanaPesca’s imports. We simply point it out as it is a widely recognized problem and fairly open secret within the industry – as, in fact, we heard repeatedly from seafood company officials at the recent global Seafood Expo in Boston. In this context, we want to know how PanaPesca and its subcontractors, be it Zhejiang Industrial Group or any other processing plant, prevent commingling at the transshipment phase and at the processing phase? We would very much like to learn about your steps taken.
Fifthly, we would like to ask you more about the plant you have identified as among your primary providers: De Lai Men. We have started reviewing videos from inside the plant. On initial review, we found footage showing squid catch from various Chinese ships on the factory floor. In some Douyin videos that we have collected, we see squid in bags that are being processed and that seems to have come from several ships. Can you confirm that all of your “raw material”, ie catch, is processed by this one plant. If not, can you tell us what other plants you use? Furthermore, with regard to De Lai Men, can you please identify which ships you are supplied by that feed into that one plant? Furthermore, we have looked through trade data to identify exports from De Lai Men but we have so far found none since 2011. If it is true that De Lai Men is a primary supplier for PanaPesca squid products now, by what means do these products arrive in the United States and elsewhere? Does De Lai Men rely on a third party for export apart from Zhejiang Industrial Group?
And, lastly, since you have been kind enough to engage here, and we are sure you saw the other component tied to our investigation relating to the use of Xinjiang labor in seafood processing plants, we would like to ask you if you can confirm that neither Zhejiang Industrial Group plants nor the De Lai Men plant uses or has within the past 5 years used any workers from the Xinjiang autonomous region? We are continuing to investigate this topic and continue to find more plants with these workers, which as you know is prohibited to be associated with U.S. imports. We do not have any evidence presently that these plants do have such workers nor are we implying you do. However, we wanted to ask you now since you have been willing to talk with us on record and openly.
Thanks again for your attention."
Louis Helbling from the office of Corporate Affairs emailed on behalf of Panapesca: "Dear Mr. Urbina,
We are writing on behalf of PanaPesca in response to your October 15, 2023 email.
We first want to thank you and your organization for publicizing and sounding the alarm about serious abuses on board Chinese fishing vessels and in Chinese processing plants. As we have seen in recent days, your reporting is proving to be a significant catalyst to much-needed reforms.
We have provided below additional information you have requested. As you will see, for many years PanaPesca has been taking steps to ensure that none of its product is caught on the vessels nor processed at the plants you have identified. PanaPesca therefore asks that you immediately correct your Bait-to-Plate listing for PanaPesca, which identifies Zhejiang Industrial Group Co. Ltd. (“Zhejiang Industrial”) as a processor for PanaPesca.
Turning now to the specific points raised in your Oct. 15 email, with respect to the dead crew member on Dong Yu 1519, we want to make clear that PanaPesca has no connection to that ship. PanaPesca does not source any product from deep sea Chinese fishing vessels like Dong Yu 1519. PanaPesca had provided you with information PanaPesca had received from Zhejiang Industrial (“Zhejiang Industrial”), which in recent years has handled export paperwork and logistics for PanaPesca, but has not been processing any product for PanaPesca. We understood from your reporting that a parent co. of Zhejiang Industrial might own the ship in question, so we contacted Zhejiang Industrial to inquire. We have provided you with the information Zhejiang Industrial provided to us. We have no further information concerning that matter.
With respect to where PanaPesca sources its squid, in recent years, PanaPesca has obtained illex squid from Argentine-flagged ships and NZ Arrow Squid from New Zealand-flagged ships. It has also sourced Dosidicus Gigas product from Peruvian local companies. At one time, PanaPesca had also sourced Todarodes Pacificus squid, caught by domestic in-shore Chinese fishing vessels, under a FIP (Fishery Improvement Product) program, but that program ended in early 2022. None of that Chinese product was sourced from the Chinese deep sea fishing vessels at issue in your investigation.
You asked about the “relationship” between Zhejiang Industrial, De Lai Men, and PanaPesca. As stated above, PanaPesca does not utilize Zhejiang Industrial (or any of its related companies) to process seafood, and has not done so since 2014. Instead, PanaPesca has been using De Lai Men, a processing plant in Zhoushan, China. PanaPesca recently stopped using De Lai Men, and now uses Yantai Ted Foods plant as its sole packer. All raw material for PanaPesca delivered to Yantai Ted Foods, and previously De Lai Men arrives accompanied by Certificates of Origin and Catch Certificates, which identify its source. For several years, Zhejiang Industrial’s role has been to handle logistics for product packed for PanaPesca by De Lai Men, which is why Zhejiang Industrial was listed as the exporter on the documentation you have reviewed. We are providing you with a copy of a Health Certificate for Argentine illex squid processed in June 2022 for PanaPesca at the De Lai Men plant, which shows that the processed product was released to Zhejiang Industrial, for shipment to PanaPesca.
With respect to your questions concerning potential “commingling” at processing plants, PanaPesca has no evidence that this has occurred with its products. PanaPesca requires documentation to ensure that Argentine illex squid, for example, is clearly identified as such from when it is caught to the processing plant to packing to shipping. As we have told you, PanaPesca also has representatives based in China who make frequent, unannounced visits to the processing plants, at which they speak with employees and management, and also spot-check the product being packed.
With respect to Xinjiang laborers, you stated in your email that you have no evidence that the processing plants PanaPesca utilizes has Xinjiang laborers, nor are you implying that they do. To be clear, in the last five years, the only plants PanaPesca has utilized are De Lai Men and now Yantai Ted Foods. PanaPesca does not have any information concerning any Zhejiang Industrial plants. As PanaPesca has stated, its representatives make frequent, unannounced visits to the plants processing for PanaPesca. Checking on working conditions at those plants is part of those representatives’ responsibility, and they are extremely thorough. PanaPesca’s representatives have uncovered no evidence that Xinjiang laborers are working at the two processing plants PanaPesca has been using.
Finally, we want to confirm that we only recently learned that you had emailed PanaPesca on March 7, 2023. At that time, that mailbox was the responsibility of a PanaPesca salesperson, who resigned from PanaPesca shortly thereafter. Your email was auto-forwarded to that person on March 7, and then deleted. (Upon learning of its existence from your reporting, our IT servicer was able to retrieve it.) We assure you that had PanaPesca’s senior management been notified of your email when it was sent, we would have responded promptly.
In conclusion, PanaPesca supports your efforts to address the abuses your reporting has uncovered. PanaPesca has committed significant resources to ensuring that its supply chain from ocean to table is safe and unblemished. We ask, as a result, the Outlaw Ocean Project cease identifying Zhejiang Industrial as a processor for PanaPesca. Thank you."
The Outlaw Ocean Project wrote Panapesca:
Hi Louis,
Thank you for your email and for PanaPesca’s continued engagement on the issues raised in our investigation. Some points, however, remain unclear and your email has raised further questions for us about PanaPesca’s supply chain.
-
You say that PanaPesca has sourced Dosidicus Gigas from “Peruvian local companies.” Can you clarify what you mean by this? Do these local companies get their seafood from ships that are flagged only to Peru, or ships flagged to other nations, including China? Are any of these Peruvian companies Chinese-owned?
-
You say that you have sourced Todarodes Pacificus squid from “domestic in-shore Chinese fishing vessels” under a Fishery Improvement Project (FIP) that ended in 2022. We see from researching this matter that this FIP covered the East China Sea and the Yellow Sea — a region with a lot of complexity about whose vessels have access to or sovereignty over the waters — and therefore an area where illegal fishing is a pressing challenge. The FIP’s profile on Fishery Progress' website makes this point clear: “There are significant current catch verification uncertainties as to whether landings being attributed to the FIP’s Chinese domestic Yellow Sea fisheries may instead be originating from international areas or potentially from closed times and areas.” Here too the presence of forced labor and human rights abuses on Chinese vessels remains a concern, even for vessels operating on those bodies of water. Can you share with us the names of the ships that supplied you with squid via this program, and the steps that Panapesca took while participating in this program to ensure that the seafood coming off of these vessels was not tied to IUU and forced labor?
-
We were provided with the six packing lists that PanaPesca gave to The Boston Globe, the relevant editor of which verified in writing with you that the receipts were provided on record. In the accompanying email, PanaPesca said that those documents indicate that PanaPesca imported product from Zhejiang Industrial Group which was packed in De Lai Men, but can you provide documentation that shows where you sourced the raw materials?
-
Can we clarify and confirm the following things that you’ve mentioned in previously emails:
(a) Yantai Ted Foods is currently the sole Chinese squid packer and processor for PanaPesca, a role previously held by De Lai Men;
(b) in that prior relationship, De Lai Men was supplied raw material (squid) by Zhejiang Industrial, in addition to receiving financial support from that company;
(c) the physical movement of product involved Zhejiang Industrial taking custody of PanaPesca-destined squid from vessels at port, and handling cold chain logistics to delivery at De Lai Men as well as after processing and packing;
(d) prior to delivery of raw material to De Lai Men and following receipt of packed PanaPesca product from De Lai Men, Zhejiang Industrial stored the squid in its own cold storage facilities;
(e) PanaPesca requires chain of custody documentation that can trace product back through each stage of the supply chain, and all sites in the chain of custody, including Zhejiang Industrial, are subject to “frequent, unannounced visits” by PanaPesca representatives;
(f) as a result of visits from PanaPesca representatives and chain of custody documentation, PanaPesca is confident that no commingling by Zhejiang Industrial of raw material from vessels supplying PanaPesca and vessels of interest to our investigation has occurred since 2018.
-
You mention that your company “now uses Yantai Ted Foods as its sole packer.” When exactly did PanaPesca start using Yantai Ted Foods?
-
Does Zhejiang Industrial also provide raw material to Yantai Ted Foods and take receipt of packed product, per the previous arrangement with De Lai Men?
Thank you for your time and attention on this. I recognise that this is a very difficult issue to solve, but it feels like the evidence is strong and that if we don’t ask these questions, then industry players won’t in turn ask their suppliers to answer them or to address problems that will otherwise continue in the industry.
Regards,
Ian The Outlaw Ocean Project
Louis Helbling from the office of Corporate Affairs emailed on behalf of Panapesca:
"Dear Mr. Urbina,
We are writing on behalf of PanaPesca USA in response to your October 24 email, which responded to our October 19 email.
PanaPesca has sourced Dosidicus Gigas raw material from local Peruvian companies which are not Chinese-owned, to the best of PanaPesca’s knowledge. Those Peruvian companies, in turn, source the seafood from local fishing boats.
While you state that the Fishery Improvement Project (FIP) covered a wide region, PanaPesca’s participation in the FIP only involved sourcing products from local, in-shore boats.
The six packing lists PanaPesca provided to The Boston Globe referred to shipments over a number of years, dating back to 2014. At the time of the older shipments, it was PanaPesca’s practice to obtain Certificates of Origin, showing the origin of the product. Starting in 2022, PanaPesca has required Catch Certificates as well, in order to have more information and closer control of the source of the product. We note that the U.S. authorities are not yet requiring these certificates, but PanaPesca aims to do more than what is required.
As we previously reported, Yantai Ted Foods is currently PanaPesca’s sole Chinese squid packer and processor. PanaPesca first began utilizing Yantai Ted Foods in 2013. After pausing for a few years, PanaPesca resumed doing business with Yantai Ted Foods in 2019. Most recently, Yantai Ted Foods became PanaPesca’s sole Chinese squid supplier. You asked whether Zhejiang Industrial has provided raw material to Yantai Ted Foods and/or takes receipt of product packed y Yantai Ted Foods. The answer is no, Zhejiang Industrial has no involvement with Yantai Ted Foods at any stage of processing and packing for PanaPesca.
Before PanaPesca began dealing exclusively with Yantai Ted Foods earlier this year, PanaPesca had also been utilizing De Lai Men to process and pack product for PanaPesca. De La Men was supplied the raw material (squid to be processed and packed) by Zhejiang Industrial. That is the financial support we had mentioned, because De Lai Men did not have the financial ability to buy the raw material in the quantities required by PanaPesca. Prior to delivery of the raw material to De Lai Men for processing, the product would be held in storage by Zhejiang Industrial and delivered as needed to De Lai Men. Once processed and packed, De Lai Men (not Zhejiang Industrial) would hold the product in storage until it was ready to be loaded and shipped. To reiterate, PanaPesca is no longer utilizing De Lai Men, and Zhejiang Industrial has no involvement with Yantai Ted Foods, PanaPesca’s current processor and packer.
As noted in our Oct. 19 email, PanaPesca supports your efforts to address the abuses your reporting has uncovered. PanaPesca has committed significant resources to ensuring that its supply chain from ocean to table is safe and unblemished. We renew our request that the Outlaw Ocean Project cease identifying Zhejiang Industrial as a processor for PanaPesca. Thank you."
The Outlaw Ocean Project wrote Panapesca:
"Mr. Helbling,
Thanks again for continuing to engage with us. It's much appreciated. Many of your answers help clarify things and we will be sure to publish them as part of the dialogue. On your note, we want to make two important clarifying points.
First, we describe Panapesca USA on our website as an "importer" of products from Zhejiang Industrial Group. This, I believe, you concede, is accurate. Second, you state that Zhejiang Industrial Group supplied raw squid to De Lai Men for processing. It is important to note the issues with Zhejiang Industrial Group derive from its sourcing of raw unprocessed squid from vessels connected with human rights, labor and environmental concerns. In other words, the issue is with the raw squid it receives, not with its processing of the same. If it supplied raw squid to De Lai Men for processing, then De Lai Men, too, is tainted by this supply line, as is, ultimately, Panapesca.
Thanks again for being so thorough and responsive. Ian"
Louis Helbling from the office of Corporate Affairs emailed on behalf of Panapesca:
"Mr. Urbina,
Thank you for the quick response this morning, as I am responding in kind, as this should close any outstanding issues.
It is important to note that we are/were not an “importer” of products from Zhejiang Industrial. All PanaPesca product was sourced from De Lai Mein and Zhejiang Industrial was simply the invoicing arm. We would need to correct this, as this is a critical distinction for PanaPesca.
Finally, raw material has never been sourced from the vessels that you have exposed, from Zhejiang Industrial. Neither PanaPesca nor De Lai Mein should be included or involved in the supply lines from your investigation.
Please correct the record, forward me a copy, and always feel free to reach out to me with any further questions."
The Outlaw Ocean Project wrote Panapesca:
Mr. Helbling,
Thank you for your response to our previous email and questions. I can sense from your recent reply that you are ready to bring the discussion to a close. I certainly understand as the interactions are time consuming and we are genuinely trying to be respectful of your time. We too are eager to finish up the discussion on this subject so we can turn to other topics. We can only do so, however, when we fully understand the terms and replies. And, unfortunately, some of your wording and the distincts you are making still remain unclear to us.
First, you state that PanaPesca has never been an "importer" of products from Zhejiang Industrial. Yet, trade information from Import Genius and ███ that derives from bills of lading data and customs records lists PanaPesca as the consignee/importer of squid products and Zhejiang Industrial is explicitly listed as the shipper/exporter up to 2023. You can see this data here. You also state that Zhejiang Industrial did at some point provide raw materials (which you characterize as 'financial support') to De Lai Men for processing and packaging before being exported by Zhejiang Industrial to PanaPesca. Some of these statements come from previous emails you have sent us. You can review those here.
Can you clarify your distinction that PanaPesca does not import from Zhejiang Industrial in light of this data? How would you describe the relationship between Zhejiang Industrial Group and Panapesca USA?
Second, trade records for Yantai Ted Foods do not indicate any exports to PanaPesca USA since 2020. However, we do not have full visibility on the exporter of shipments to PanaPesca USA beyond the logistics company handling the shipment. Furthermore, trade records indicate that Zhejiang Industrial is listed as the exporter of numerous shipments to PanaPesca USA between 2022 and 2023.
Can you confirm if a third party is handling Yantai Ted Foods' exports to PanaPesca and, if so, who? Additionally, can you confirm when exactly Yantai Ted Foods became the sole Chinese squid supplier of PanaPesca USA?
Third, in your most recent email (November 28), you claim that Zhejiang Industrial is just the invoicing arm of De Lai Men. However, in your email from November 27, 2023, you note that De Lai Men was supplied raw material by Zhejiang Industrial and that this raw material was also held in storage facilities at Zhejiang Industrial. This suggests that Zhejiang Industrial is not just responsible for invoicing, but also actively provided raw material and cold storage services for De Lai Men.
Can you clarify where all of the raw materials supplied by Zhejiang Industrial to De Lai Men to meet PanaPesca’s order requirements was sourced?
You previously provided a “Health Certificate for Argentine illex squid processed in June 2022 for PanaPesca at the De Lai Men plant”, however the file size was too small, rendering the document illegible. Could you send a clearer copy?
Finally, to reiterate, in our Bait-to-Plate tool, PanaPesca is listed as an importer of Zhejiang Industrial Group. Given the information you have provided us and publicly available trade data, that relationship appears to be accurate.
To recap our understanding of the facts: Zhejiang Industrial Group is supplied raw squid by numerous vessels with histories of labor and IUU issues, according to research compiled by The Outlaw Ocean Project. According to Panapesca USA, Zhejiang Industrial Group supplied raw squid to De Lai Men for processing for Panapesca, as De Lai Men did not have the financial capacity to do this. The logistics of storing and then exporting the processed squid to Panapesca were handled by Zhejiang Industrial Group, according to trade records and packing receipts provided by Panapesca.
Again, we are eager to be respectful of your time. Equally, we want to understand what we are unveiling in our investigation and we seek your input in that process. So, we will continue sending questions. As we’ve mentioned before, our investigation into the use of forced labor in China’s seafood processing industry is ongoing. We are looking into other types of forced labor concerns in other areas of seafood supply chains which may mean we will need to be in touch with you about those findings in the coming weeks.
Thank you,
Ian Urbina The Outlaw Ocean Project