Did the China Investigation Have Impact?

The short answer is, in large measure, yes. But in some ways, no.

The report prompted U.S. federal agencies to ban imports, seafood sellers to sever ties with plants, a CEO to resign, and legislators to adjust laws, pressure companies, and hold hearings. Dozens of news organizations also began collaborating with OO ( Outlaw Ocean Project ) to expand the reporting. These are important developments.

But auditing and certification organizations have largely stonewalled, as have seafood companies and grocers. The industry has stepped back from answering questions about the core problems identified in the investigation. Companies have tried to redirect attention toward symptoms and away from root causes, typically by highlighting vague palliative actions and declining to provide specifics. 

Federal Agencies & Lawmakers

The U.S. government has taken several big steps. In June 2024, the Department of Homeland Security (DHS), citing ties to the use of state-sponsored forced labor, added a large Chinese seafood company called Shandong Meijia Group, and two of its subsidiaries, to a federal list that prohibits further imports to the U.S. Shandong Meijia was one of ten companies that the OO investigation identified as using Uyghur-forced labor. In July, the DHS added seafood to its list of high-priority sectors for enforcement of the Uyghur Forced Labor Prevention Act (UFLPA). Undercurrent News and Seafood Source reported on the action. 

Members of the U.S. Congress also got involved. In its version of the National Defense Authorization Act (NDAA) for 2025, the Senate introduced new language “prohibiting procurement and commissary sales of seafood originating or processed in China.” The NDAA is the federal law that funds the Defense Department. The Senate action came partially in reaction to a Politico piece by the OO team. The story for the first time revealed ties between state-sponsored Chinese labor to seafood being served in federal prisons, public schools, and U.S. Congressional cafeterias.

A variety of U.S. lawmakers called attention to seafood imports from China and the need to re-examine the industry. This included calls for enhanced screening of seafood coming from China, expanded import monitoring that would include all seafood coming into the country, and bans on imports from two Chinese provinces identified in the investigation as hubs of forced Uyghur and North Korean labor in seafood-processing plants. U.S. lawmakers also sent letters to Sysco and Costco inquiring how these companies will ensure that future audits will adequately prevent seafood tied to Xinjiang (Uyghur) and North Korean forced labor from entering the U.S. The investigation highlighted how much of the seafood consumed in the U.S. and Europe (including some fished in domestic waters) is tainted by Chinese forced labor, because it gets processed in plants there that rely on Uyghur or North Korean workers. Along the same lines, the investigation covered the extent to which another portion of banned seafood is discreetly entering the U.S. market. The reporting explained that despite a ban on the importation of Russian seafood into the U.S., large amounts of pollock caught in Russian waters get funneled through plants in China, where they are relabeled as of Chinese origin. In response to the investigation, the Biden administration issued an executive order closing a loophole that had allowed that to occur. 

More than 200 Chinese squid ships anchored in the bay of Ulleung Island, South Korea, in May 2019 on their way to or from fishing North Korean waters, a practice prohibited by the U.N. (Fábio Nascimento / The Outlaw Ocean Project)

Congress also held hearings that touched on the OO investigation. The first took place in October and was hosted by the bipartisan Congressional Executive Committee on China, which was created by the White House and Congress. OO was asked to testify at this event. This hearing focused on the presence of seafood made with forced labor on Chinese ships and in China’s processing factories throughout the U.S. supply chain. The second hearing took place in April 2024. Hosted by the same committee, it brought lawmakers together to discuss the ways that social audits have failed to identify and prevent forced labor in factories in China.

U.S. State Department officials who produce the annual “Trafficking in Persons” report and U.S. Department of Labor officials who produce the annual update to the federal “List of Goods Produced by Child Labor or Forced Labor” held several meetings with OO investigators to discuss our methodology and findings. Along the same lines, the OO team also held a half dozen meetings to debrief officials at the U.S. Department of Homeland Security in charge of enforcing the Uyghur Forced Labor Prevention Act, officials at U.S. Customs and Border Protection responsible for issuing Withhold Release Orders, and officials at the Office of Foreign Assets Control who oversee the implementation of targeted sanctions for human rights infractions.

In March 2024, members of the European Parliament sent a letter to the European Commission and the President of the European Parliament. The action was a response to a part of the investigation that OO reported on in Le Monde, which revealed ties to seafood produced by North Koreans and a European company that supplies the European Parliament. A response from the president of the European Parliament confirmed that seafood tied to Chinese plants using North Korean labor was supplied to cafeterias in European Parliament buildings. The letter also said that the relationship with the Chinese plant was reportedly terminated immediately.

The investigation was also cited during discussions in the E.U. parliament in October 2023, where lawmakers eventually voted in favor of a resolution urging China to be more transparent about its distant-water fishing fleet and its processing plants. The rapporteur of the resolution, Pierre Karleskind (France), cited the investigation in his opening remarks. Caroline Roose (France)highlighted the reporting on the use of Uyghur forced labor in Chinese seafood processing factories supplying EU companies, and public institutions, including the European Commission. Barry Andrews (Ireland) underscored how the journalism revealed how flaws in the audits used by companies enabled seafood tainted by human rights abuses to end up on the shelves of European grocery stores including Aldi, Lidl and Tesco. Izaskun Bilbao Barandica (Spain)added that the investigation highlighted the urgent need to address human rights concerns in China’s fishing industry.

Negotiators from the E.U. Parliament and Council also reached a provisional agreement on new rules to ban products made with forced labor from the E.U. market. At Parliament’s insistence, the European Commission will draw up a list of particular economic sectors in specific geographical areas where state-imposed forced labor exists. Industry publications pointed out that this provisional agreement comes after the OO investigation revealed state sponsored forced labor in Chinese seafood plants with significant buyers in the U.S. and E.U.

The Canadian government, on the other hand, has been relatively inactive. In response to the investigation, NGOs submitted legal petitions to the Canadian government calling for it to impose sanctions against seafood companies tied to Uyghur forced labor and to prohibit imports from these companies. While the U.S. has not imposed targeted sanctions as of yet, relevant authorities have begun the process of banning imports from companies tied to the investigation. The Canadian government has made no indication it will do the same. Human-rights advocates in Canada have said this silence and inaction from the Canadian government could create a potential backdoor through which imports rejected by the U.S. might re-route to Canada without issue.

The Press

The OO investigation and subsequent coverage of its repercussions has run in 145 news outlets, 45 countries, and 21 languages. The global reach of this journalism is a major reason for its ongoing impact and is the result of an usual level of cooperation and trust by hundreds of editors and reporters. On its own, that’s a huge accomplishment.

How did this global collaboration evolve? Initially, magazine, newspaper, and television news venues around the world agreed to re-publish the core reporting that was originally produced by OO in partnership with the New Yorker magazine. The country-specific tailoring of this reporting usually involved mining our trade data and company specifics so that we could mold the original story to better speak to a particular readership. 

Subsequently, we began working with editors and reporters in various countries and at industry outlets. We sifted and provided additional trade data for them and also trained their reporters on how to use the investigation’s two main tools. The Bait-to-Plate tool allowed them to tie particular ships and plants to sellers. The Discussion tool allowed them to see what we previously asked of companies or agencies. Both tools empowered them to improve and expand on our work. Before long, stories were appearing where reporters that we had not assisted were using these tools on their own to smart effect. The industry press — led by Seafood Source, UnderCurrent News, and IntraFish — played an especially important role because they covered the topics incrementally, with expertise, and inside sources, as the best beat reporting tends to do.

Awards don’t really constitute impact, except as they indicate that leaders in the journalism profession are taking note and showing support for the reporting. So far, the OO investigation has won a long list of awards for this investigation including: the Overseas Press Club Award, the RFK Human Rights Book & Journalism Award, the Sigma Delta Chi Award for Excellence in Journalism, the Osborn Elliott Prize for Excellence in Journalism on Asia, the Excellence in Financial Journalism Award, the Digital Media Award Americas, and the Best in Business Award. 

(Hat tip to the New Yorker and specifically Nimal Eames-Scott, David Remnick, and Mike Luo, for a year’s worth of tireless work with us on this project and the collaborative way the magazine allowed us to share the reporting with other outlets.)

Within China and Korea

Reporting on what is happening within China or North Korea is a tough task, and estimating the impact there is somewhat speculative. A variety of news outlets reported that the Chinese government initially claimed that there was no forced labor in the seafood plants and that the reporting was pure fabrication. As we released footage proving the existence of Uyghurs and North Koreans, the Chinese no longer voiced those claims. 

Seafood Source reported that the Chinese government, which criticized the OO investigation publicly, also responded by announcing plans to begin monitoring its distant-water fishing fleet more “systematically” and “scientifically.” SeafoodSource said that the likely reason for the speedy and aggressive commitment is that many firms named in the investigation “are likely to face increased scrutiny from U.S. and other countries’ authorities.” The Chinese government released its “White Book“, an annual policy paper stating the country’s policy goals tied to its distant-water fishing fleet. The publication included new regulations related to labor. Specifically, Chinese officials added language about “protecting the legitimate rights and interests of distant-water fishing crew members” and plans to “severely crack down on illegal fishing activities.” 

Shortly thereafter, in April 2024, the Chinese government detailed specific protections for foreign crews working on Chinese distant-water fishing vessels in a notice from the Ministry of Agriculture and Rural Affairs. The document (Chinese version, English version) set requirements for crew contracts that include clearly defined pay and working conditions. The measures require distant-water fishing enterprises to guarantee equal treatment and protection of foreign workers, as well as stronger workplace safeguards. 

Subsequent reports indicated that the seafood industry was feeling severe impacts due to the revelations. The NK Daily, which is the best investigative-news venue related to North Korea, reported on high-level meetings between Pyongyang and Beijing about how to avoid a drop in foreign revenue due to stepped up U.S. sanctions or more Western companies severing ties to Chinese processing plants. Seafood Source reported that the director of a major processing operation in northern China said the investigation has led to a significant decrease in U.S. demand for seafood from China as companies cut ties with plants identified as using forced labor. The Daily NK also reported that North Korea was considering plans to replace senior officials who run seafood plants in China and who regularly sexually assault workers. In South Korea, three large online retailers — Lotte Mart, Coupang, and Market Kurly — stopped selling Chinese seafood brands that the investigation cited as tied to North Korean and Uyghur workers, according to Chosun Daily, the largest newspaper in South Korea.

Illegal and Unsustainable Fishing

A major part of the OO investigation focussed not on human rights but marine concerns. Specifically, we revealed a pattern of fishing-related crimes by Chinese ships including the targeting of protected species, fishing without licenses, incursions into foreign and prohibited waters, and the use of prohibited fishing gear. Some of the revelations included violations of Chinese laws by their own ships. For example: over 100 of the Chinese squid ships investigated have gone dark by turning off their locational transponders for over a week, often disappearing from view as they approached other countries’ waters. 

The broader revelation was that supply-chain traceability, often certified by bodies such as the Marine Stewardship Council (MSC) and the Aquaculture Stewardship Council (ASC), suffers from gaps that emerge in the many handoffs of catch between fishing boats, carrier ships, processing plants, and exporters. Most of the information about what occurs on the fishing vessel where the seafood is caught is unverifiable, self reported, and often backfilled by processors after the catch has already been dropped off on land. When the catch reaches the processing plant it is often co-mingled with that of other ships, making it impossible for buyers to know the true origin of their seafood.

North Korean workers process seafood in late 2023 at a factory in China called Dandong Taifeng, which exports to the U.S. and E.U. (The Outlaw Ocean Project)

Among the impacts from this part of the reporting was a letter citing the investigation that was sent to President Joe Biden in March 2024 by a bipartisan group of 26 U.S. lawmakers urging him and the administration to take increased action against illegal, unreported, and unregulated fishing (IUU). Officials at the National Oceanic and Atmospheric Administration (NOAA) also said that in their effort to revamp the Seafood Import Monitoring Program (SIMP) they would look more closely at human rights abuses and how to better track this type of illegality tied to U.S. imports. NOAA also said it would withdraw proposals to expand the Seafood Import Monitoring Program to include squid and other species for coverage so that the agency could take more time to study the issue. Citing the OO investigation, U.S. lawmakers wrote that NOAA’s decision was “unacceptable,” because now more than ever SIMP needed to accelerate and strengthen its oversight role. 

Whether the Chinese government will confront the ships that are breaking its own laws remains unclear. So too is whether MSC and other certification bodies will address these systemic gaps in traceability and U.S. grocers will address their lack of tracking of ships that supply them. 

Improvements in the treatment and tracking of labor conditions in seafood supply chains and the ships and plants that make it up will also help companies and governments to police rules related to illegal fishing. Nonetheless, the overwhelming reaction by the media, governments, and industry stakeholders to the OO investigation has been focused on the human-rights issues and not the fishing illegalities that we unveiled.

Organizations That Oversee Global Fisheries

Regional fishery management organizations are international governing bodies that oversee a particular region of the high seas or highly migratory species. Some of these organizations took note of the OO investigation. Many of the Chinese squid ships that were the focus of the OO reporting operate in the waters near South America. The relevant oversight organization is called  the South Pacific Regional Fisheries Management Organization (SPRFMO). In February 2024, this body approved proposals on improving work conditions, eliminating human rights abuses, and establishing more stringent labor standards on fishing vessels operating in the South Pacific. This change will pertain to the waters surrounding countries like Ecuador, Chile, and Peru, where Chinese squid ships are most active. The regulatory changes also followed a letter sent to the organization by over thirty major seafood companies, including ones mentioned in our reporting like Cotsco, Aldi, Sysco France, High Liner Foods and Lund’s Fisheries. The letter urged the body to help improve how workers on fishing vessels are treated.

A second fisheries organization that reacted to the OO investigation was the Western & Central Pacific Fisheries Commission (WCPFC). It oversees a large swath of the Pacific Ocean and the fish stocks within a region that includes the waters around southeast Asia. Much of the abuse documented on Chinese fishing ships was aimed at foreign crew, typically from Indonesia. In the most recent discussion of the commission’s Labour Standards Intersessional Working Group, a body within the organization that reviews labor rights and the treatment of crew onboard fishing vessels, China expressed that it introduced new regulations in April covering non-nationals working on the ships of its distant-water fleet.

The Private Sector

The initial response from companies varied broadly. Many grocers, such as Walmart and Costco, and seafood suppliers, such as Ruggiero Seafood and Ocean Beauty Seafoods, declined to answer our original inquiries. Others engaged robustly at first. While the press spotlight was focused on them, seafood companies and grocers responded to the crisis by performing triage. They emphasized that they were taking the findings seriously and investigating. More than a dozen companies severed ties to plants using forced labor. In the U.S., major grocery chains such as Albertsons and Ahold Delhaize cut ties with Chinese seafood processors after being presented with evidence that tied products on their shelves to forced labor. After we presented our findings to High Liner Foods, a major seafood company based in Canada, the CEO abruptly resigned. Elsewhere, companies in Japan, South Korea, France, and the United Kingdom took action. The Aquaculture Stewardship Council (ASC), which certifies marine and other standards at plants and fish farms, announced that it was ceasing operations in China partly due to concerns about the inability to properly inspect plants for forced labor. 

These seemed like substantive first steps. 

But virtually all these companies soon went into public-relations lockdown mode. They stopped answering questions from reporters, advocates, and researchers. Questions such as: You mentioned you are investigating. What did you find? Have you identified which other plants within your supply chain are relying on state sponsored forced labor? If unannounced spot checks are forbidden at most plants in China, how do you intend to police this issue more effectively? 

Publicly discussing Uyghurs, North Koreans, or human-rights is taboo in China. Inspectors from certification bodies or company auditors know that if they flag these issues, they will likely be kicked out of the country or not be allowed back to the plant. When asked how it intends to fix these problems in such a context, the industry has mainly responded with silence. 

Is it possible that some companies have genuinely confronted these immensely difficult challenges and found better ways to ensure that they can keep operating in China while preventing their supply chains from being tainted by illegal fishing and forced labor? Certainly. But the public has no way of knowing. 

Two examples don’t inspire confidence. 

The first started with a tip from a seafood-industry source based in China, who alerted us that one of the biggest Chinese processing plants, called Roncheng Haibo, which had previously been tied to the use of state-sponsored forced labor from Xinjiang, had seemingly changed its name and was still supplying major companies in the U.S.. “Ruggiero Seafood is up to their old tricks,” wrote the source, drawing attention to a company that said it had cut ties with Chishan Group following the investigation. “They continue to source seafood in China through the Chishan Group,” the source added. They asked to remain anonymous because they are based in China and could face repercussions for having assisted the investigation. The allegation was especially important because the owner of Roncheng Haibo is the Chishan Group, which was the focus of a video we produced. This parent company was also the focus of a Global Magnitsky petition. The source said that Rongcheng Haibo had changed its name to Shandong Nabaixian Seafood and continued to send seafood to Ruggiero under the new name.

We took a look at Shandong Nabaixian and found that it was listed in a Chinese business directory with the same email address and phone number that appeared in Haibo’s listing. The address was slightly different but appeared to be located in the same complex as Haibo. Records also indicate that Shandong Nabaixan was formed shortly after the publication of the OO investigation. Trade records show that Ruggiero has imported 59 times from Nabaixian since December 2023. 

Satellite imagery and corporate records also show that both of these addresses, though written differently, lead to the same location: namely, the Haibo headquarters in Rongcheng, in China’s Shandong province. Other records also seem to corroborate the source’s claim: Invoice numbers documented on bills of lading by Simple Seafood, an American customer of Haibo Seafood, seem to indicate Nabaixian is simply picking up where Haibo left off. The last invoice number on a Haibo shipment to Simple Seafood, in July 2023, was BL23020. The first invoice number for Simple Seafood on a Nabaixian shipment, in January 2024, was BL23021. No other Haibo or Simple Seafood customers correspond to this sequencing, according to trade records. Searches on China’s Baidu search engine also show that Haibo’s parent, the Chishan Group, have been using the brand Nabaixian for at least seven years; a reference to the brand from 2016 was found on Chishan’s website, and they sought a logo for the brand in 2017.

A map showing the proximity of Haibo, which claimed its plant is on Eshishan Road, and Nabaixian, which is listed as being on Longyue Road North.

Asked about the matter, Haibo strongly denied a connection between the plants. “Rongcheng Haibo has no relationship with Shandong Nabaixian,” a Haibo spokeswoman named Cindy replied. Shandong Nabaixian is not owned by the Chisan Group and the companies were based at two distinct locations, she added, explaining further that the Chishan Group previously had the “Nabaixian” brand. But Haibo cannot prevent other companies from using “Nabaixian” as their company name upon registration, she said. 

We reached out to Ruggiero Seafood and asked them about receiving seafood from Shandong Nabaixian and if Ruggiero had decided to renew a supply relationship with Chishan Group, despite earlier announcing they were cutting ties to the organization. The company did not respond. We also contacted representatives at Shandong Nabaixian and the Chishan Group with questions about Nabaixians’s relationship to Haibo and Chishan Group, but did not receive a response.

It remains unclear whether the problems found at Haibo also exist at Nabaixian. The larger concern here, however, is the core allegation from the source. Name-changing speaks to the whack-a-mole nature of investigating this industry. It also speaks to the futility of focussing on symptoms rather than core causes. 

The second anecdote stems from the recent publication of the 2024 Human Rights Report by Ahold Delhaize, the owner of major grocery chains including Giant and Stop & Shop. The report includes a case study focused on the OO investigation about human-rights violations in the company’s supply chain. Ahold Delhaize immediately followed up with their direct suppliers to “conduct a full investigation, determine whether the brands receive products from the facilities mentioned, and take appropriate action.” The report went on to note, “We are also actively engaging with the social audit and seafood programs involved.”

While commendable that Ahold Delhaize publicly engaged with the investigation’s findings, the vague wording in the company report is problematic. It leaves the impression that their engagement is more performative than substantive. What specifically are the “appropriate actions” that Ahold Delhaize’s suppliers have taken? How is Ahold Delhaize “actively engaging” with the auditing and certification bodies that overlooked the presence of state-sponsored forced labor? 

After Ahold Delhaize published their report, we asked them these very questions. Their written reply was a further vaguely-worded reassurance that they were working with auditors and that they had contacted their suppliers and “asked them to conduct a full investigation, determine whether Ahold Delhaize brands received products from the facilities mentioned, and, to the extent that issues were found, take appropriate action to address the allegations.” Ahold Delhaize added that all of their suppliers had expressed their commitment to human rights and taken appropriate actions. But Ahold Delhaize, again, offered no detail on what those actions were.     

Civil Society

NGOs have swung into high gear. A half dozen human rights groups have submitted legal petitions in the U.S., Canada. and the U.K. seeking formal sanctions against seven Chinese companies that were revealed as being tied to Uyghur forced labor. These petitions were submitted to the relevant authorities in the U.S, U.K., and Canada. In the U.S., a bipartisan group of lawmakers supported the petition by sending a letter to the U.S. Treasury and State Departments, calling on them to impose Global Magnitsky Human Rights Accountability Act sanctions on the Chinese companies named in the petition. Several human rights NGOs have said they plan to file another legal petition in Canada and the U.S. in the next few months. That petition will call for formal sanctions against almost a dozen companies tied to the Chinese squid-fishing industry and implicated in illegal fishing and human-rights abuses.

The reporting has played a vital role in bolstering global civil society efforts to advocate for mandatory human rights due diligence laws and import bans in major G7 and G20 countries, according to lawyers at the Human Trafficking Legal Center in Washington DC. Recent developments on that front include the adoption of import restrictions on forced labor tainted goods in Mexico, Canada, and the EU. The EU is also building a forced labor risk ‘database‘ that is supposed to be completed in the next three years.

In September 2019 in the waters of Gambia, OO reporters visited the Victory 205, a Chinese-owned ship that was caught fishing illegally and where workers faced decrepit conditions. (Fábio Nascimento / The Outlaw Ocean Project)

In November 2023, two additional legal filings were submitted by NGOs. Both called on the U.S. Customs and Border Protection to prevent squid that our investigation had tied to two Chinese distant-water fishing vessels from entering the country. At the time of writing, Customs and Border Protection is still reviewing the two petitions. Customs and Border Protection also received a formal letter from the Committee for Human Rights in North Korea, a human rights and advocacy organization, calling for an immediate halt of shipments of seafood from nearly a dozen Chinese companies that were found to be using North Korean labor, in violation of U.S. law and U.N. sanctions.

Human-rights and environmental NGOs, including SeaChoice, Freedom United, and Transitional Justice Working Group, have also used the OO investigation’s findings to conduct independent outreach to companies in search of answers to how they plan on dealing with the revelations made. In May 2024, SeaChoice launched a campaign to urge major North American grocers to stop human-rights abuse and environmental harms in their seafood supply chains. Then, in July, Freedom United and Transitional Justice Working Group sent letters to thirteen major seafood distributors and retailers requesting an update on their internal investigations into how their supply chains are exposed to North Korean and Uyghur forced labor. The letters were signed by a total of eighteen human-rights–focused NGOs.

Several NGOs have also begun preparing shareholder actions. In December 2023, Oxfam filed a shareholder resolution with Walmart citing the investigation and calling on the company to publish human-rights impact assessments that examine the actual and potential human-rights impacts of high-risk commodities in the company’s supply chains. Since then, several other NGOs have asked OO for documents and data, as part of what they described as an assessment of other targets for similar pressure campaigns aimed at a broader swath of publicly traded grocery chains and major seafood companies.

Will the industry continue biding its time? Unclear. But so far companies are remaining hush publicly, seeking to update NGOs or reporters only ever in “off record” conversations, but not publicly explaining their actions or plans. They are also largely relying on audits and certifications that researchers have repeatedly found do not work in democratic settings, much less China. 

What Next?

Surely, the true test of impact is not measured by what has happened in a mere 6 months since initial launch. Real change takes longer and we will continue to track this on the investigation’s Impact page. 

The OO reporting on this matter is also far from complete. We are soon to publish another story in the investigation of China as the superpower of seafood. That piece explains that China not only controls most of the world’s high-seas fishing and on-land processing capacity but also operates hundreds of ships in the national waters of poorer global south nations. The ships fly those countries’ flags but are “beneficially owned” by Chinese companies. (Beneficial ownership refers to companies or individuals that primarily profit from an entity.)

Will the industry reverse course? Stonewalling the press and NGOs is a winning strategy for the industry in the short run. Investigators have lots to do and will probably move on. Editors and reporters have to shift to their next set of journalistic targets. 

And yet stonewalling is a losing strategy for the industry in the long run. Why? Because it’s only a matter of time before seafood companies operating in China have to face a next wave of costly scandals. If it’s not Uyghur or North Korean workers, it will likely be some other form of forced labor — perhaps involving children, prison inmates, or Tibetans — that the next investigation reveals in this global supply chain. 

A guest post by
Austin Brush