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Licensing procedure for use of the “Seafood from Norway” country … · are imported or bought from registered exporters of Norwegian Seafood, and which may furnish export declarations

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Page 1: Licensing procedure for use of the “Seafood from Norway” country … · are imported or bought from registered exporters of Norwegian Seafood, and which may furnish export declarations

Licensing

Licensing procedure for use of the “Seafood

from Norway” country of origin mark outside

Norway

Page 2: Licensing procedure for use of the “Seafood from Norway” country … · are imported or bought from registered exporters of Norwegian Seafood, and which may furnish export declarations

A practical guide to the “Seafood from Norway” licensing procedure / July 2017

Page 1 of 7

Contents

Introduction ........................................................................................................................................ 2

How to get a license ........................................................................................................................... 3

License agreement............................................................................................................................. 4

Third party audit and control ............................................................................................................. 5

Page 3: Licensing procedure for use of the “Seafood from Norway” country … · are imported or bought from registered exporters of Norwegian Seafood, and which may furnish export declarations

A practical guide to the “Seafood from Norway” licensing procedure / July 2017

Page 2 of 7

Introduction

Companies processing Norwegian seafood outside of Norway have to apply for a license in

order to get at right to use the country of origin mark,“Seafood from Norway”.

Licensing is a requirement to ensure the value of the joint investments by the Norwegian

seafood industry, and to ensure only Norwegian seafood is labeled as “Seafood from Norway”.

If your company have partners or own processing facilities outside of Norway, you can get a

license to use the “Seafood from Norway” mark of origin on your products.

This brochure summarizes the process to get a license. If you have any other questions, please

contact us using [email protected] or +47 77 60 33 33.

What is the value of using the “Seafood from Norway” mark of origin?

The trademark “Seafood from Norway” is a symbol of origin and quality for all Norwegian

seafood, sustainably farmed or wild caught in our cold, clear waters.

With the new trademark we want to portray what is unique about Norway, and give

associations to the rough climate and nature in which our seafood is raised.

Licensing enables companies outside of Norway to benefit from marketing investments

made by the Norwegian Seafood Council (NSC) on behalf of Norwegian seafood.

Page 4: Licensing procedure for use of the “Seafood from Norway” country … · are imported or bought from registered exporters of Norwegian Seafood, and which may furnish export declarations

A practical guide to the “Seafood from Norway” licensing procedure / July 2017

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How to get a license

In order to use the “Seafood from Norway” mark of origin outside of Norway you have to enter

into a license agreement.

Step 1: License Application

In the application, you are asked to provide general information about your company and

Norwegian seafood products intended to be labelled with the mark of origin.

In the application, you are also asked to confirm whether your company complies with any

certified management systems.

Step 2: Exporter Declaration

The declaration is to be signed by the Norwegian exporter(s) from whom you are buying

Norwegian seafood.

The purpose of the declaration is to confirm the value chain from the Norwegian exporter to

the production facility outside Norway.

Step 3: License Agreement

Based on the license application and exporter declaration, you will be forwarded a license

agreement, to be signed and returned to the NSC.

Product labelling

After signing the license agreement, all product packaging with the mark of origin shall be

presented and accepted by NSC in writing prior to commercial use.

The mark of origin shall always be used together with the licensee's own trademark.

Listed on seafood.no

When the license agreement is in force, your company’s right to use the mark of origin will

be listed on www.seafood.no.

Page 5: Licensing procedure for use of the “Seafood from Norway” country … · are imported or bought from registered exporters of Norwegian Seafood, and which may furnish export declarations

A practical guide to the “Seafood from Norway” licensing procedure / July 2017

Page 4 of 7

License agreement

Below is a summary of the most important provisions included in the license agreement. For

further details, please contact the NSC.

The licensee guarantees

That it will comply with any legal requirements applicable for its business in the country of

operation, and that it has necessary certificate(s) issued by the relevant national authority,

which allows the licensee to produce and/or import seafood.

What is Norwegian seafood, and what type of products can be labeled with the mark

of origin?

The mark of origin can only be used on products where Norwegian Seafood is the main

ingredient. Products that contain, or are mixed with seafood of other territorial origin than

Norway, will not be accepted.

"Norwegian seafood" means seafood which originates from fish or other marine products as

defined in art. 1 of the Norwegian Fish Export Act No 9 of 27 April 1990, and which

naturally inhabits the seawaters or freshwaters of Norway, and is caught or farmed in

compliance with Norwegian sectorial regulations, and landed on Norwegian land territory.

Tracking systems, inspections and audits

Companies wanting the right to use the mark of origin must confirm that they have a tracking

system in which can trace and document products sold under the “Seafood from Norway” origin

mark. The license holder’s tracking system shall be documented, reliable and verifiable.

At least once a year, license holders must report to the NSC on their usage of the mark of origin.

Additionally, the NSC will annually request third party audit of selected manufacturers. If the

NSC has reason to believe that a company is in non-compliance with agreed terms, the NSC

may at any time request a separate third party audit.

Freedom of movement

Products labeled under the license agreement can be exported and sold within a customs

union. This means that products can be exported between countries provided the countries are

within the same customs union.

If the country in which your facility is located is not part of a customs union, it will not be

possible to export labeled products out of the country you are manufacturing in. Examples of

customs unions are the EU, Mercosur (Argentina, Brazil, Paraguay and Uruguay) and the

Eurasian Economic Union (Russia, Belarus, Kazakhstan, Armenia and Kyrgyzstan).

Page 6: Licensing procedure for use of the “Seafood from Norway” country … · are imported or bought from registered exporters of Norwegian Seafood, and which may furnish export declarations

A practical guide to the “Seafood from Norway” licensing procedure / July 2017

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Criteria

The mark of origin can only be used on/in connection with Norwegian Seafood products which

are imported or bought from registered exporters of Norwegian Seafood, and which may furnish

export declarations and/or Norwegian catch certificates.

Duration of the license agreement

The duration of the license agreement is three years. Thereafter the agreement can be

prolonged by subsequent three year periods, unless earlier terminated by either party. The

duration may be subject to adjustments depending on markets and/or species.

The NSC is the owner of the “Seafood from Norway” country of origin mark and oversees the

administration and use of the mark. Conditions for licensing may be subject to change.

Third party audit and control

The following is a summary of questions that a third party auditor may ask during the audit.

Certified management systems

Is the company certified against any of these standards?

- Global Food Safety Initiative (GFSI)?

- Marine Stewardship Council (MSC) chain of custody or Aquaculture Stewardship

Council (ASC) chain of custody (MSC CoC or ASC CoC)?

- Global G.A.P. Chain of Custody (Global G.A.P Coc)

Identification and tracking

- Does the company have a list of suppliers of Norwegian seafood?

- How are the Norwegian products identified and registered when they arrive at the

production facility? How is it recorded: Dates, quantities, species, name of supplier,

batch number, barcode, storage destination, etc.?

- How is the tracking maintained during production, and how can the company

document Norwegian origin for the products at every stage of the production process?

- Can documentation be presented for all batches with ”Seafood from Norway”-labeled

seafood sold - including product name, species, weight and customers?

- Can the company document what type of raw material used for manufacturing of a

finished product (See figure 1 traceability test)?

Page 7: Licensing procedure for use of the “Seafood from Norway” country … · are imported or bought from registered exporters of Norwegian Seafood, and which may furnish export declarations

A practical guide to the “Seafood from Norway” licensing procedure / July 2017

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Figure 1: Traceability test.

Separation

- How does the company ensure Norwegian seafood is not mixed with non-Norwegian

seafood in your company?

- How does the company ensure the mark of origin is used on Norwegian seafood

products only?

- In cases of similar fish species, or products, are they clearly labelled and separated? If

yes, how are these species and/or products separated – by production line or time?

Production yield (Mass Balance Control) and verification

- Can you demonstrate that you can determine how raw material has been used and in

what quantities (input and output reconciliation)? A calculation like this can be

compared with making a balance sheet, where the sum of the fish entering the process

(whole fish with head for instance) is equal to the fish leaving the process (Fillets,

head, skin, trimmings, bones). These types of calculations ensure that you avoid

nonconformities in terms of Norwegian seafood in the end-product.

- Does the company have a list of the products in stock, with identification and

quantities?

Training

- Within your company, are responsibilities defined and known regarding the traceability

and labelling of Norwegian seafood, and is it documented that it is understood and

applied by the staff?

- Have your employees received training in HACCP principles? If yes, how can you

document it?

Input

•LOT/Batch ID

•Date (packing and/or date of arrival)

•Physical Labelling of product (internally)

•Entry batch ID in own system (manual or electronic)

•Trained staff and responsible for ID?

Storage

•Continued information flow from Input control

•Maintenance of ID with same or new ID code

•Trained staff and responsible for ID?

Processing

•Continued information flow from Input control

•Maintenance of ID with same or new ID code

•Registration of batches entering processing

•Different IDs for different product types?

•Trained staff and responsible for ID?

Quality and quantity control

•Continued information flow from processing

•Maintenance of ID with same or new ID code

•Input – output quantity control (mass balance)

•Trained staff and responsible for ID?

Packing/

dispatch

•Continued information flow from quality control

•Maintenance of ID with same or new ID code

•Control of NORGE-label against ID

•Trained staff and responsible for ID?

Page 8: Licensing procedure for use of the “Seafood from Norway” country … · are imported or bought from registered exporters of Norwegian Seafood, and which may furnish export declarations

A practical guide to the “Seafood from Norway” licensing procedure / July 2017

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Record maintenance

- Does the company have documents showing all products sold with the mark of origin

can be tracked to a batch/delivery of Norwegian seafood? This can be batch number,

catch certificate, invoice, etc.

- Can the company document conversion factors used in reconciliation of supply and

produced goods?

- For how long are such documents stored? (The requirement is set to three years).

Traceability test and input-output reconciliation

- During an audit, the lead auditor will undertake a traceability test (Figure 1). In a

traceability test, the auditor may look at your records to follow a product from “goods-

in” to “goods out” (or vice versa).

- Figure 1 shows a simplified production process of seafood, and the critical check

points that must be documented. In addition, it will be controlled how labeled seafood

is being separated from other seafood.

Nonconformity management

The lead auditor will verify that the company has defined a limit level for when nonconformities

shall be reported, and that it exists a procedure for handling them. The procedure must consist

of a method that can rectify and close nonconformities as soon as they are identified, e.g. if

input-output reconciliation has a nonconformity of more than five percent.

The procedure should include: (1) A method to identify the nonconformity or the reason for it,

(2) A timeline showing when the correcting actions shall be implemented, (3) A process for

verification of the efficiency of the correcting actions and (4) A description of the responsible

person for carrying out the procedure.

Audit costs and duration

Every year the NSC will request third party audits of selected manufacturers, costs of which will

be borne by NSC. Only in cases where non-compliance is established, will NSC demand

compensation for costs incurred in connection with the audit.

A third party audit will usually take half to one and a half day. Amongst others, the duration of

the audit will depend on the complexity of the production and number of species/products that

will be marked with the mark of origin.