Within the set of tariff-related shocks, the preliminary results of the nineteenth administrative review (POR19) on shrimp, announced by the U.S. Department of Commerce (DOC) in June 2025, stand out as a key development. The preliminary AD duty rate of 35.29 per cent imposed on STAPIMEX and another twenty-two companies is assessed as the highest level seen in nearly two decades of Viet Nam’s participation in frozen shrimp reviews. This rate not only almost completely erases the price advantage of Vietnamese shrimp in the U.S. market, but also has a negative impact on the sentiment of importers and distributors, as well as on the production and investment plans of domestic enterprises. Even though the final results are only expected to be announced at the end of 2025, the risk of such a high duty has already forced many shrimp exporters to recalculate their market strategies, act more cautiously with new contracts and seriously consider shifting their focus to other markets.

In contrast, still within POR19, Thong Thuan Company received a preliminary duty rate of zero per cent. The very large gap between the group enjoying a 0 per cent rate and the group facing 35.29 per cent shows that DOC’s review process is becoming a substantive test of each company’s ability to manage costs, ensure data transparency and comply with procedural requirements. The shrimp industry is therefore entering a phase of strong differentiation: a small group has the conditions to maintain its position in the U.S. market, while the rest faces the risk of having their presence narrowed or losing the market altogether.

In stark contrast to the tense picture for shrimp, the pangasius (tra catfish) sector is in a more favourable position in the United States. The twentieth administrative review (POR20) resulted in a zero per cent duty for seven major Vietnamese enterprises. This is a final rate and functions as a “passport” allowing these companies to strengthen their presence in the U.S. amid intensifying competition for supply among exporting countries. Data for the first five months of 2025 show that pangasius exports to the United States rose by 7 per cent to about USD 142 million, clearly reflecting the positive impact of the review outcome. However, this advantage does not cover the entire sector. Companies not included in the group benefiting from individual rates still have to contend with the nationwide duty of USD 2.39 per kilogram, which significantly constrains their price competitiveness. Within the pangasius industry, the gap between enterprises that meet DOC’s requirements well and those that do not is becoming increasingly pronounced, leading to a stratification in market share and in access to higher-value segments in the U.S.

Alongside tariff measures, the new generation of non-tariff barriers from the United States is being assessed as a long-term, structural challenge for Vietnamese seafood. The Marine Mammal Protection Act (MMPA) is a particularly clear example. Under current notifications, from 1 January 2026 the United States will ban imports of seafood from twelve Vietnamese fisheries unless they are recognised as having marine mammal protection measures equivalent to U.S. standards, from rules on fishing gear and methods to monitoring and enforcement at sea. Preliminary estimates suggest that, if not addressed in time, this requirement could reduce export turnover by more than USD 500 million per year.

Unlike AD duties, which are primarily handled at the enterprise level through accounting records and cooperation in investigations, the MMPA is a barrier applied to an entire sector at the national level. Meeting the “equivalency” requirement will necessitate significant adjustments in the legal framework governing fisheries, sanctions against violations, the capacity to monitor fishing activities at sea and overall risk-control systems. Individual enterprises, regardless of their size, will find it difficult to resolve this on their own without leadership and coordination from state management authorities.

In parallel with the MMPA, requirements on combating illegal, unreported and unregulated (IUU) fishing and on forced labour are being increasingly emphasised in U.S. trade policy. A 2021 report by the U.S. International Trade Commission (USITC) identified Viet Nam among the countries with a risk of exporting products originating from IUU fishing into the U.S. market. This implies that many consignments of Vietnamese seafood, especially capture products, will face tighter scrutiny with respect to traceability, vessel documentation and working conditions for crew members.

At the same time, in Europe, the “yellow card” on IUU fishing imposed by the European Commission (EC) since 2017 has significantly altered the position of Viet Nam’s capture fisheries. The share of the EU in total exports of capture seafood has fallen from around 30–35 per cent before 2017 to only 9–10 per cent in recent years. The United States, which previously served as a “buffer market” when the EU tightened IUU controls, is now also deploying measures on origin verification, IUU and MMPA, causing the room for Vietnamese capture seafood to narrow simultaneously in both major markets. A clear general trend can be observed: developed markets are gradually shifting from tariff barriers to technical and sustainability standards as tools to regulate import flows.

The impact of these barriers varies by product group and is creating deep segmentation within the industry. For shrimp, the combination of a record-high preliminary AD rate under POR19 and the tightening of sustainability standards has pushed the sector into a difficult position. Keeping the U.S. as the core market means accepting high duty risks and substantial legal costs, while pivoting too quickly to other markets requires significant resources to develop products, build brands and establish new distribution channels. In a context where demand in the EU and CPTPP markets remains relatively stable, especially for value-added products, Vietnamese shrimp has an opportunity to restructure towards a higher share of processed items that meet stringent safety and sustainability standards, thereby reducing reliance on low-value frozen raw shrimp segments in the U.S.

For pangasius, the POR20 outcome offers encouraging prospects in the U.S. market, but at the same time calls for caution in maintaining market balance. The zero per cent duty advantage allows some enterprises to expand their market share; however, if the sector relies too heavily on the U.S., it becomes vulnerable to policy shifts or demand downturns. Exports of pangasius to the EU and China have not recovered as expected, indicating that challenges related to technical barriers, product positioning and purchasing power remain unresolved. To pursue sustainable development, the pangasius sector needs to both capitalise on the “bright spot” in the U.S. and gradually re-establish its position in the EU and China by improving quality, strengthening traceability and implementing long-term marketing strategies.

For capture seafood such as tuna, squid and octopus, the current context is a combination of multiple concurrent difficulties. Demand in both the U.S. and EU for some products has shown signs of stagnation or decline; raw material supply chains are being affected by weather volatility and fuel costs; and IUU, MMPA and labour-related controls are adding new layers of scrutiny. The ability of this product group to “pivot markets” is also more limited than for shrimp and pangasius, due to its close ties to natural conditions, fishing grounds and regulatory regimes. In this case, enhancing supply-chain transparency, investing in electronic traceability systems and improving fleet management and logbooks is almost a mandatory pathway if enterprises wish to maintain access to both key markets, the U.S. and the EU.

The year 2026 is expected to be a critical juncture in reshaping the position of Vietnamese seafood in the U.S. market. The final outcome of POR19 will determine the extent of Viet Nam’s shrimp presence in the years ahead. The full application of the MMPA from 1 January 2026 will test the effectiveness of efforts to reform institutions and fisheries management. If this barrier is not addressed in a timely manner, a significant portion of capture seafood exports to the United States will face the risk of being cut off.

Against this backdrop, the response needs to be defined at two levels. At the macro level, the immediate priority remains the removal of the EU’s IUU yellow card, as this is a prerequisite for restoring access to the EU market and at the same time a foundation for meeting U.S. requirements on catch origin. In parallel, technical exchanges and negotiations with the U.S. on the MMPA, based on a roadmap for improving fisheries management, vessel monitoring, gear and area regulations and enforcement mechanisms, need to be accelerated in order to seek an equivalency arrangement before import bans are applied more broadly.

At the enterprise level, investments in supply-chain transparency and traceability systems must be treated as part of a survival strategy, not an optional cost. Experience from POR20 in the pangasius sector shows that companies with transparent data, good cost management and strict compliance with investigation requirements are able to secure low, even zero, duty rates and thereby gain a clear competitive edge in the market. For shrimp, pangasius and especially capture seafood, building electronic traceability systems that link farms or fishing vessels with processing plants and end-customers is a fundamental condition for simultaneously satisfying U.S. and EU requirements.

Taken together, these developments show that the central challenge for Vietnamese seafood in the U.S. market no longer lies in nominal tariff rates or logistics costs, but in the ability to adapt to a new “rulebook” for trade in which environment, origin and labour have become core criteria. If the current pressures can be used as a catalyst to push forward fisheries management reform, strengthen compliance capacity and enhance supply-chain transparency, the Vietnamese seafood industry will not only be able to maintain its position in the United States, but also improve its resilience and competitiveness globally in the coming period.

Việt Thành