Huynh Chanh Thi, a Vietnamese fisherman, informed a state newspaper at the beginning of December 2025 that January will be different. The restriction that had prohibited him from landing the majority of his catch would no longer be in effect for the first time in months as the peak skipjack season approached. “Everyone will take their boats out to sea,” he stated, “instead of abandoning them like in the past.” There is genuine relief in that quote. The previous year had been extremely challenging for coastal fishing towns along Vietnam’s south-central coast; this wasn’t because the fish weren’t there, but rather because the government said they were the wrong size.
Vietnam’s Decree 37/2024 set a minimum size requirement of 500 millimeters for skipjack tuna in order to save young fish and align the nation’s fisheries management with global conservation norms. The math was the issue. Only 5 to 8 percent of average Vietnamese skipjack hauls actually reach that level, according to VASEP.
Fishermen were literally pulling nets and seeing the majority of what they caught become useless on paper since the remaining 92 to 95 percent were too small to land legally. The fish could not be purchased by processing companies. Undersized catches were no longer certified by ports. Boats ceased to depart. In reality, the rule effectively shut down the nation’s skipjack business, despite its good intentions from a conservation perspective.
When the suspension was announced in December 2025, it immediately relieved fishermen and gave Vietnam’s tuna processing industry something to work with as the season got underway. It was referred to by VASEP as a “major step.” However, American fish importers are aware that the narrative doesn’t end there.
The U.S. Marine Mammal Protection Act import prohibition, which went into force on January 1, 2026, is a more serious and irreversible issue that runs concurrently with the domestic size-rule drama. About 2,500 fisheries in 135 nations were included in NOAA’s August 2025 comparability findings. Of those, 240 fisheries from 46 countries were denied comparability status, which means that their goods are no longer allowed to enter the US without a current Certificate of Admissibility.
Twelve fisheries were denied to Vietnam. Tuna, swordfish, grouper, mackerel, mullet, crab, and squid are among the impacted species. Vietnam sent around $270 million worth of tuna to the US market in 2024. A large amount of that came from fishing techniques that don’t adhere to MMPA standards for reducing marine mammal bycatch, especially some gillnet and purse seine operations.
Practically speaking, this means that U.S. importers have a supply issue on top of a documentation issue. The importer of record must now submit a COA via CBP’s Automated Commercial Environment before to the arrival of any shipment from a flagged HTS code category. The shipment is refused entry in the absence of a valid COA. In January 2026, NOAA emphasized that the restriction still applies to commodities that departed Vietnamese ports before January 1 but arrived subsequently, as enforcement is based on predicted time of arrival rather than departure date.
In order to get goods into the United States before the deadline, many Vietnamese exporters reportedly attempted to speed up shipments through December. Now that the rush has passed, importers are figuring out which of their Vietnamese suppliers have fisheries documentation that complies with regulations.
Since NOAA’s guidelines outlining enforcement processes wasn’t released until after the ban had already gone into effect, it’s still unknown how well the Certificate of Admissibility process will work at scale. For American wholesalers and canners who have constructed their supply chains around Vietnamese skipjack, there is also a practical sourcing question: where does the replacement volume come from? The list of straightforward replacements is reduced because Indonesia, Ecuador, and the Philippines are subject to the same MMPA scrutiny in various ways.
