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Direct Marketing
“Direct marketing is selling your own catch to a buyer at a point farther down the distribution chain than a primary processor.”
As we’ll see, this can be pretty simple… but it can also get rather complex.
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What Does a Direct Marketer Do?
Direct Marketers don’t eliminate the middleman - they become the middleman!
You’re still a fisherman but now you also have to:• process or otherwise prepare your fish for sale;• package, ship or otherwise deliver your fish; • arrange sales or attract retail customers;• collect payment on your sales; and• deal with all the extras like fish tickets, licenses,
permits, and fisheries taxes.
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Direct Marketing
GrowerAnd/or
Harvester
GrowerAnd/or
Harvester
PrimaryProcessorPrimary
Processor
Further ProcessorAnd
Manufacturer
Further ProcessorAnd
Manufacturer
WholesalerWholesaler ConsumerConsumer
FoodServiceFood
Service
RetailerRetailerBrokersBrokers
The Seafood Marketing Chain
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Direct Marketing
GrowerAnd/or
Harvester
GrowerAnd/or
Harvester
PrimaryProcessorPrimary
Processor
Further ProcessorAnd
Manufacturer
Further ProcessorAnd
Manufacturer
WholesalerWholesaler ConsumerConsumer
FoodServiceFood
Service
RetailerRetailerBrokersBrokers
The Direct Marketing Seafood Chain
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OK – Please Bear With Us Revenue – wants to tax the fish
Fisheries Business License
Direct Market Fisheries Business License
Fish & Game – wants to count fish “Intent to Operate”
First buyer Catcher seller Buyer exporter Catcher processor Catcher exporter Salmon roe recovery Fish Transporter
Environmental Conservation – food safety Seafood Processing Permit
Direct Market Processing Permit Direct Market Vessel Direct Market Land-Based Processor
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Other Agencies
US Environmental Protection Agency If you have a DEC Direct Market Shoreside facility
you may need a National Pollutant Discharge Elimination System (NPDES) permit if you are discharging waste into a waterway.
National Marine Fisheries Service Federal Processing Permit – needed if you’re
catching groundfish harvested in federal waters.
Food and Drug Administration
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Types of Direct Market Operations
Catcher-Seller
Direct Market Fisheries Business Catcher Exporter
Catcher-Processor <65’ LOA (Direct Market Vessel)
Direct Market Land-Based Processor
Using Custom Processor
Shellfish Shipper
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Catcher Seller
The most basic direct marketing option
Limited to the following activities Selling your own unprocessed catch at dockside off
your vessel to the public (not for resale); or
Selling to restaurants, grocery stores or fish markets holding a valid DEC processing waiver
Selling bait for commercial harvesting
Permits Required You must be a licensed commercial fisherman holding
a valid limited entry or interim use permit
You must have a valid Catcher Seller permit issued by ADF&G (there is no cost for this permit)
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Catcher / Seller - Terminology
What does “unprocessed” mean? Your catch is unprocessed if you only gill or gut
seafood, head or gut groundfish or decapitate shrimp to avoid decomposition.
If you butcher, freeze, and package your catch you are processing. That is not allowed under a Catcher / Seller permit
What is a DEC exemption? By regulation [18 AAC 31.200(b)(D)] DEC may grant a
local retail market or food service establishment a written exemption from processing licensing requirements, which allows them to receive up to 500 pounds of raw fish from a fisherman weekly.
Catcher / Sellers are allowed to sell to such establishments.
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Pros retail prices no processing permit needed fits existing fishing operations minimal start-up costs
Cons markets usually limited lost fishing time hard to sell all species & grades may conflict with processor relationships
Catcher / Seller Pros & Cons
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Moor in an accessible spot Clear signs and directions Keep boat shipshape & clean No pets (or rambunctious kids) Covered sales area Change – have enough, keep it handy
Packaging Be a “Good Scout” – helpful, courteous, trustworthy, clean, etc.
Tips for Dockside Sales
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Direct Market Fisheries Business
A “step up” from Catcher / SellerMore options / More complexity
If you sell your “processed” fish in general commerce, or
process your catch in any way…
You need a Direct Market Fisheries Business License
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Direct Market Fisheries Business
Permits Required - In addition to your limited entry or interim use permit to fish, you will need the following:
Alaska Fisheries Business License from Dept. of Revenue (DOR) -$25; and
Valid “Intent to Operate” on file with ADF&G – no cost;
and either a
Direct Marketing Vessel Permit from DEC - $325; or a
Direct Marketing Shore-based Permit from DEC - $200
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Direct Market - DEC Requirements
Read and understand the regulations yourself. Don’t depend
on the “rumor mill”
Develop a working relationship with DEC. They want you to succeed, but their first responsibility is the public’s
food safety
www.dec.state.ak.us/eh/fss/seafood/seafood.htm
www.seagrant.uaf.edu/bookstore/pubs/ASG-45.html
HACCP Plan –you will have to complete a Hazards and Critical Control Points analysis of your operation.
DEC Inspection – Your operation will be inspected for compliance by DEC.
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What is a “Direct Market Vessel”
DEC regs (18 AAC 34.500 – 525) define a Direct Market Vessel as one that is a.) less than 65’ LOA and b.) is permitted to process only its own catch onboard…
Butcher, freeze & package only on the fishing grounds…beyond ½ mile from shore
Inspected processing area able to be cleaned & sanitized
Approved marine sanitation device (head) required, along with handwash sink, soap, hand towels, etc.
Approved processing water sources required
HACCP plan required
www.seagrant.uaf.edu/bookstore/pubs/ASG-45.html
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What is a “Direct Market Shore-based” Facility
In 2005 DEC established a simplified set of regs (18 AAC 34.700 – 740) for direct marketers who wanted to process only their own catch onshore…
Limited to butchering, roe extraction, freezing & packaging only (doesn’t cover smoking, canning, etc.)
Inspected processing area able to be cleaned & sanitized
Approved sanitary systems required, inc. handwash sink, soap, hand towels, etc.
Approved processing water sources required
HACCP plan required
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Tips for Direct Market Facilities
Read & understand regulations
Regulations are “minimums” – exceed them
Space – as much as you can afford
Surfaces - non-porous/stainless metals, food grade plastics
Design for easy cleaning & sanitizing
Brighter is better
Assure safe water supply
Personnel hygiene
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OK! So what is a Catcher / Exporter?
Catching and exporting your own fish.
An ADF&G designation
Does not provide any exemption from DEC permit requirements
If you export your own product from Alaska you must have a Direct Market Vessel or Direct Market Shorebased permit…even if the fish is technically “unprocessed”, i.e live, whole, or dressed head-on
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Shellfish
No “Direct Marketer” category in regulation
License classifications are: Harvester, Shipper, Repacker, and Shucker / Packer
Consult with DEC to determine the precise requirements that apply to your operation
For DEC purposes “shellfish” means mollusks – clams, oysters, whelks, etc. & does not include shrimp or crab.
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Custom Processing
Having your fish custom processed by a licensed processor can ease your workload as a Direct Marketer.
But…if you retain ownership of the fish throughout, you will need to get and maintain F&G & Revenue licenses, do the record keeping and reporting, etc., etc.
There is an easier alternative…
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Custom Processing Simplified
Sell your fish to you processor...and buy back the processed product that you need to sell to your customers.
The processor covers all the licensing requirements, issuing fish tickets, going through facility inspections.
You save time, money and hassle…leaving you free to concentrate on fishing and your marketing efforts.
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Direct Market Business License Applications
ADF&G and DOR requirements are on a joint form titled:
“Alaska Fisheries Business License Application and Intent to Operate”
Available at: Department of Revenue – Tax DivisionFisheries Business LicensePO Box 110420Juneau, AK 99811-0420Ph. (907) 465-2320www.tax.state.ak.us/fish
Department of Fish & GamePO Box 115526Juneau, AK 99811-5526Ph. (907) 465-6131www.cf.adfg.state.ak.us
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Direct Market Business License Applications
DEC requirements are no longer on a joint form with ADF&G and DOR
You must complete the ADEC“Seafood Processor’s Permit Application”
Available at:
Department of Environmental ConservationSeafood Permits555 Cordova St., 5th FloorAnchorage, AK 99501Ph. (907) 269-7637 or 7638www.dec.state.ak.us/eh/forms.htm
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Getting Through the Direct Market Reg Maze
Are you selling just your own catch?
Not a Direct Marketer
Are you only selling off your boat or to a DEC exempt business under AS 18.AAC
31.200(b)(D)
You need an •ADF&G C/S
Are you selling product to a processor and then buying it
back?
You need:•No seafood processing permits.•Business license
Are you maintaining ownership of your product
and having it custom processed?
You need:•ADF&G IO•DOR DM FBL
Are you selling unprocessed product?
Are you selling product that you
processed?
You need:•ADF&G IO•DOR DM FBL C/E•DEC DM Processing Permit (vessel or shoreside)
You need:•ADF&G IO C/P•DOR DM FBL•DEC DM Permit (Vessel or Shorebased)
Is your vessel longer than 65 feet?
Are you harvesting tuna?
Are you selling clams, mussels, or scallops (not including the
shucked scallop abductor muscle)?
You need:•ADF&G IO C/P•DOR DM FBL•DEC Shucker/Packer Permit
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