MSC - Marine Stewardship Council Consultation Document ... · PDF fileMSC - Marine Stewardship Council Consultation Document – Mass Balance CoC Standard Consultation Dates 1 March

MSC - Marine Stewardship Council

Consultation Document – Mass Balance CoC Standard

Consultation Dates 1 March to 30 April 2017

MSC Contact Wendy Banta

FOR CONSULTATION

Consultation Document – Mass Balance CoC Standard 1

1

1. Executive summary 2

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4 5

2. Purpose of the consultation 6

7 The purpose of the consultation is to obtain feedback on the first draft of the MSC Mass Balance Standard, 8 including how it can be effectively aligned with the Aquaculture Stewardship Council (ASC) Feed Standard. 9 10

3. Background 11

12 The MSC Mass Balance Standard is designed to be generic in its main content. However, the key driver for 13 the Standard currently is the development of the ASC Feed Standard (ASC-FS). The Mass Balance Standard 14 will apply to the fish feed mills in a business-to-business context only, but it may be applied to other sectors 15 (such as seaweed) in the future. The MSC Mass Balance Standard and the ASC-FS are being developed in 16 separate but parallel processes, with close communication and coordination between MSC and ASC. For 17 further details on the drivers and early development of the Mass Balance Standard, refer to the original 18 project Terms of Reference from July 2016. 19 20

4. Considerations 21

22 ASC is developing the ASC-FS for certification of feed mills to supply responsible feed to ASC certified 23 aquaculture farms. Eventually all ASC certified aquaculture farms must use ASC certified feed. The ASC-FS 24 aims to incentivise feed mills to source responsible raw materials over time, partly by requiring increased 25 volumes of marine ingredients sourced from MSC (or equivalent) certified fisheries. 26 27 MSC is developing the Mass Balance Standard (Appendix A) which will support the ASC-FS by providing a 28 basis for the physical mixing of MSC-certified and approved marine ingredients 1 with non-29 certified/non-approved marine ingredients at ASC-FS certified feed mills. Mass balance is necessary for feed 30 mills which do not currently segregate certified and non-certified materials due to logistical challenges in the 31 manufacturing process. Mass balance is necessary to catalyse the uptake of the ASC-FS, and thereby over 32 time create enough certified raw material volume to work towards a segregation chain of custody model. 33 34 The two standards are being developed separately in parallel processes by ASC and MSC respectively, with 35 close communication and collaboration between MSC and ASC to ensure the standards function effectively 36 together. The audit processes against both will be aligned and streamlined. 37 38 The ASC-FS will require feed mills to meet the MSC Mass Balance Standard for mixing of certified/approved 39 and non-certified/non-approved marine ingredients in order to become certified against the ASC-FS. 40 41

5. Potential interactions with other work 42

43 This new draft standard has potential interactions with the CoC Program Review 2018 of standard 44 improvements and also a revaluation of how Illegally Unregulated Unreported (IUU) fish can be prevented 45

1 See Appendices A.3 and B.3 (for example, IFFO RS and IFFO RS CoC).

Key Points - MSC is developing a Mass Balance Chain of Custody (CoC) Standard. The Standard will be

generic, however initially it is designed for use by fish feed mills which seek certification against the new ASC Feed Standard. The Mass Balance Standard is for business-to-business use only.

- MSC and ASC are collaborating closely to develop both standards to ensure they function effectively together and to streamline the audit processes.

http://www.msc.org/

http://www.asc-aqua.org/index.cfm?act=tekst.item&iid=311&iids=313&lng=1

https://improvements.msc.org/database/mass-balance-coc-standard/consultations/terms-of-reference-consultation-july-2016/Terms-of-Reference-for-MSC-Mass-Balance-CoC-Standard-development.pdf

https://improvements.msc.org/database/coc-program-review-2017

FOR CONSULTATION – 1 March to 30 April 2017


from entering a certified supply chain. While MSC is continuing work on the IUU project and it is related to 46 the Fishery Traceability program, this area is not specifically part of the March–April 2017 consultation. 47 48

6. Next steps 49

50 All consultation feedback will be anonymised and published in a report on the MSC Program Improvements 51 website after the consultation closes. This will also be emailed to all respondents. 52 53 During the draft Mass Balance Standard public consultation in March–April 2017, MSC and ASC will be 54 actively seeking feedback from key stakeholders through phone calls, emails, workshops and webinars. The 55 Mass Balance Standard and the ASC Feed Standard will also be piloted in a joint process with interested 56 feed mills who wish to participate in trialling the new standards. Feedback from all consultation activities and 57 pilots will be considered and incorporated where appropriate to improve the standards content and future 58 implementation. 59 60

Consultation note

Feed mills interested in participating in the pilot should respond to MSC and ASC through this consultation for more information.

61 62

7. Who can comment? How do I give feedback? 63

64 This consultation is public and open to all interested parties. 65 66 The online feedback survey allows you to respond to specific questions on this topic. We also welcome any 67 more detailed comments that you wish to make on this consultation which can be emailed directly to: Wendy 68 Banta, Supply Chain Standards Manager, at [email protected]. 69 70

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https://improvements.msc.org/database/fishery-traceability

https://improvements.msc.org/database/mass-balance-coc-standard

https://www.surveymonkey.co.uk/r/29THZBW

mailto:[email protected]



Appendix A 74 75 DRAFT MSC Mass Balance Chain of Custody Standard 76 77 General introduction 78 The MSC Mass Balance Chain of Custody (CoC) Standard is being developed by MSC to support the 79 following high-level objectives: 80

To provide the basis for business-to-business (B2B) claims that could be made by aquaculture feed 81

supply chain companies that are unable to segregate certified materials from non-certified materials, and 82

therefore could not become certified under the existing MSC CoC Standard. The ASC Feed Standard 83

for feed mills (currently in development) would recognise the MSC Mass Balance CoC Standard as 84

meeting its requirements for traceability of marine ingredients in ASC compliant feeds. 85

To provide a CoC solution that could also be applied in the future to other marine-sourced product sectors 86

on a similar basis, such as seaweed and nutraceutical supplements, if this is determined to be 87

appropriate. This relates to providing supply chain traceability solution to the MSC-ASC Seaweed 88

Standard (also currently in development). 89

More generally, to broaden the MSC CoC offering to increase accessibility to the program for use by 90

aquaculture feed supply chains. This is part of a wider concept to expand the offering in both directions 91

of the CoC model spectrum – through mass balance on one end, and through identity preservation or 92

digital traceability on the other. 93

Indirectly, to support the engagement of global reduction fisheries in the MSC program by providing an 94

incentive to become certified or improve towards future certification. The ASC Feed Standard will 95

incentivise sourcing from certified sustainable fisheries, and the MSC Mass Balance CoC Standard will 96

ensure the required traceability for marine ingredients. 97

The mass balance approach 98 The mass balance approach to claims has been developed by voluntary sustainability standards programs 99 to allow companies that are unable to segregate and trace certified ingredients within their production 100 processes, for a variety of reasons, to make claims to their customers about their sourcing of certified material. 101 102 The approach is designed so that the more certified material the company sources, the greater the quantity 103 of product that it can sell with an approved claim. The intent is that this incentivises and rewards the sourcing 104 of increasing quantities of certified material without the need to segregate and trace that material through 105 the production process. 106 107 There are several variations to this general model. The approach taken in this standard is illustrated in 108 Figure 1. 109 110 Key elements of the mass balance approach taken in this standard: 111

MSC first defines the sustainability requirements for the input material that will be recognised as 112

the basis for making a mass balance claim. This material could be from MSC-certified sustainable 113

fisheries, from fisheries that are in transition to MSC (ITM) or subject to Fishery Improvement 114

Plans (FIPs), or some combination of these. This material is referred to in the standard as ‘MSC 115

Mass Balance Recognised Marine Material’. 116

An organisation that is seeking mass balance certification must record the quantity of this material 117

that it sources. 118

The organisation can then make a mass balance claim for the equivalent amount of marine 119

material contained in its products. 120

In line with MSC’s general policy on IUU fishing, in order to access the MSC Mass Balance CoC Standard 121 the organisation must be able to show that it does not use marine material sourced from vessels listed 122 on Regional Fisheries Management Organisations’ blacklists in any of its products that could potentially 123 carry a mass balance claim. 124

125 126



127 Figure 1. The principle of mass balance claims 128 129 130 Structure of the Standard 131 The MSC Mass Balance Chain of Custody Standard is structured around five Principles. The intent is that 132 these principles flow from the statement of organisational policies, through to the operational definition and 133 implementation of those policies, and to the application and control of claims and labels under a mass 134 balance system. 135

Principle 1: Sustainable Sourcing Policy

The organisation shall define and make public a general sourcing policy that commits to not use of material sourced from vessels listed on Regional Fisheries Management Organisations (RFMO) blacklists.

Principle 2: Specifications and Targets for Sourcing Marine Ingredients

The organisation shall specify and implement contractual requirements with its suppliers of marine-sourced ingredients.

Principle 3: Marine-Sourced Ingredients Management

The organisation shall operate a stock control system that ensures that all marine-sourced ingredients it receives comply with the organisation’s contract specifications, and that the quantity of MSC Mass Balance Recognised Marine Material it receives is recorded on delivery.

Principle 4: MSC Mass Balance Calculation, Labelling and Sales Data

The organisation shall calculate and record the net Mass Balance of its MSC Mass Balance Recognised Marine Material for the preceding twelve months, at the end of each month. Sales of outputs associated with a Mass Balance claim in the following month may never exceed the organisation’s net Mass Balance calculated at the end of the preceding month.

Principle 5: General MSC Management System Requirements

The organisation shall operate a documented management system that covers the implementation of the MSC Mass Balance Standard by it and its subcontractors, as applicable, and the organisation’s communication with its CAB.

136



Scope of application 137 This standard is potentially applicable to any organisation that has a site (physical location) handling and 138 trading MSC Mass Balance Recognised Marine Material for business to business (non consumer-facing) 139 purposes. However, it can only be used in association with additional scope-specific guidance on its 140 application to specific categories of organisation and for specific categories of material, to be determined by 141 MSC on a case-by-case basis. 142 143 Appendix B of this draft standard provides a provisional example of such scope-specific guidance, for 144 application to aquaculture feed. 145 146 The ASC Feed Standard 147 The draft MSC Mass Balance Chain of Custody Standard is being developed in parallel with the development 148 of the ASC Feed Standard by the Aquaculture Stewardship Council (ASC). The ASC Feed Standard defines 149 requirements for the certification of aquaculture feed mills and their products, for supply to ASC certified 150 aquaculture farms. 151 152 The requirements of the ASC Feed Standard are referenced in MSC’s scope-specific guidance for the 153 application of the MSC Mass Balance Standard to aquaculture feed (Appendix B). 154 155 The MSC Mass Balance Chain of Custody Standard and the ASC Feed Standard will continue to be 156 developed in parallel, to ensure that they are mutually compatible. Once both standards have been finalised 157 it is expected that a combined MSC/ASC document will be developed to facilitate the joint implementation of 158 the two standards by feed mills wishing to supply feed containing marine material to ASC-certified 159 aquaculture farms. 160

161



MSC Mass Balance Chain of Custody Standard – DRAFT 1.0 162

163

Terms and Definitions

Site: A discrete physical location. (From MSC-MSCI Vocabulary, V1.1, 20th February 2015).

Compliant Product: A product within the scope of a certified organisation’s chain of custody control programme which is potentially eligible to be covered by or carry a chain of custody controlled claim or label.

Contract Processor: An organisation that is contracted by a certified organisation (including a subsidiary or affiliate of the certified organisation) wherein the product is altered in some way. Specifically, the processor does not own the product and the processor processes the product on instruction from the certified organisation (usually the owner of the product). This definition excludes contract processors that take ownership of the product, since they are required to have their own chain of custody certification. (From MSC-MSCI Vocabulary, V1.1, 20th February 2015).

Marine Material: Material from marine sources.

Marine-Sourced Ingredients: Ingredients that consist of, contain, or are derived from marine material.

Mass Balance Designated Product: A compliant product that has been designated to carry a mass balance claim/label. Note that in a mass balance system only a limited proportion of compliant products will actually be designated to carry mass balance claims/labels.

MSC Mass Balance Recognised Marine Ingredients: Ingredients that consist of, contain, or are derived from MSC Mass Balance Recognised Marine Material.

MSC Mass Balance Recognised Marine Material: Marine material from a source that MSC recognises as achieving an acceptable level of sustainability, for the purpose of making a mass balance claim. The sources that MSC recognises are specified separately for the application of the MSC Mass Balance Standard to particular types of marine material.

Organisation: The entity that seeks certification for its production under this standard. An organisation may be a company, corporation, firm, enterprise, authority or institution, or part or combination thereof, whether incorporated or not, public or private that has its own functions and administration. (From ISO 14001:2004).

164



165

Principle 1: Organisation Sourcing Policy

The organisation shall define and make public a general sourcing policy that commits the organisation to not use of material sourced from vessels listed on Regional Fisheries Management Organisations (RFMO) blacklists.

Consultation note:

This Principle builds on the requirement specified in paragraph 5.3.6 of the current MSC

Chain of Custody Standard: Default Version, Version 4.0, 20th February 2015. Comments

are sought on whether additional commitments should be specified for inclusion in the Mass

Balance Chain of Custody Standard, for example to exclude uncertified marine material

sourced from countries that have been ‘pre-identified’ by the European Union as non-

cooperating countries (issued with a so-called ‘yellow card’) and or ‘identified’ by the

European Union as non-cooperating countries (issued with a so-called ‘red card’).

1.1 The organisation shall have a written and publicly available policy in place that:

Consultation question:

How should this be made publically available?

1.1.1 commits the organisation to avoid the use of material sourced from vessels

listed on Regional Fisheries Management Organisations (RFMO) blacklists.

1.1.2 expresses the organisation’s intent to source certified MSC Mass Balance

Recognised Marine Ingredients as available.

Consultation note:

The MSC Mass Balance Standard can only be used in association with scope-specific

guidance on its application for specific categories of production. This guidance includes

definitions for MSC Mass Balance Recognised Marine Material for ingredients used within

the specified scope of application. See Appendix B.1 for the categories applicable for the

manufacture of aquaculture feed.

1.2 The policy referred to in 1.1 shall have been communicated to all staff and all

suppliers.

Principle 2: Marine-Sourced Ingredients Sourcing Specifications

The organisation shall specify and implement contractual requirements with its suppliers of marine-sourced ingredients in order to implement its sourcing policy.

2.1 The organisation shall have contractual agreements in place with all of its

suppliers of marine-sourced ingredients that require that all such ingredients that

are supplied to it shall be covered by an MSC-recognised chain of custody

certificate or equivalent that:

2.1.1 provides a credible guarantee that the ingredient does not contain material

from vessels listed on Regional Fisheries Management Organisations (RFMO)

blacklists, and,



2.1.2 if applicable, specifies that any deliveries of MSC Mass Balance Recognised

Marine Ingredients shall be labelled with or otherwise linked to documented

information about the quantity of the ingredient that is MSC Mass Balance

Recognised Marine Material, and,

2.1.3 requires that all deliveries of marine-soured ingredients shall be labelled with

or otherwise linked to the following accompanying information:

a. Ingredient name/unique identifier

b. Quantity

c. The supplier’s name

d. The chain of custody certificate code(s) (or equivalent) which cover the

ingredient and provides the specified guarantees

e. The date of shipment

NOTE: The conditions that chain of custody certification schemes must meet in order to satisfy these requirements for aquaculture feed are given in Appendix A.2 (in relation to IUU fishing) and Appendix B.2 (in relation to MSC Mass Balance Recognised Marine Ingredients).

Chain of custody certification schemes that MSC currently recognises as meeting these requirements are listed in Appendix A.3 (in relation to IUU fishing only), and in Appendix B.3 (for IUU fishing and for labelling of MSC Mass Balance Recognised Marine Material).

Chain of custody schemes that are not listed in Appendix A.3 or B.3 may apply to MSC for assessment for equivalence in order to be added to the applicable list(s).

2.2 The organisation shall maintain an up-to-date listing of all of the marine-sourced

ingredients it currently uses for its production, together with the names of the

suppliers and their chain of custody certificate numbers or equivalent.

Principle 3: Marine-Sourced Ingredients Management

The organisation shall operate a stock control system that ensures that all marine-sourced ingredients it receives comply with the organisation’s contract specifications, and that the quantity of MSC Mass Balance Recognised Marine Material it receives is recorded on delivery.

3.1 The organisation shall have a documented system in place to record the quantity

of all marine-sourced ingredients received2, including:

a. Ingredient name/unique identifier

b. Date of physical receipt

c. Quantity received (including conversion if required into kg/mt)

2 The Standard focuses on the date of receipt for the purpose of calculating monthly summaries and as the basis for the input side of the mass balance calculation. It is assumed that any timing differences between the quantities received, and the quantities actually used for production are not material in the context of the claims that may be made about the mass balance system.



d. The quantity of the ingredient that is MSC Mass Balance Recognised Marine

Material, if applicable (including conversion if required into kg/mt)

e. The supplier’s name

f. The chain of custody certificate code (or equivalent) which covers the

ingredient

3.2 The organisation shall have a system in place to calculate and record at the end

of each calendar month:

a. The total weight of MSC Mass Balance Recognised Marine Ingredients it has

received over the month, and

b. The total weight of MSC Mass Balance Recognised Marine Material

contained in these ingredients over the month.

3.3 Records shall be accurate, complete, and unaltered.

3.4 Where records have been changed, these changes shall have been clearly

documented including the date and name or initials of the person that made the

changes.

3.5 Organisations taking physical possession of marine-sourced ingredients shall

have a process in place to verify that the ingredients meet all relevant sections of

this standard at the point of delivery, and before they can be used for production.

Guidance 3.5

Organisations with marine-sourced ingredients in stock at the time of the certification audit must be able to demonstrate that these ingredients are covered by a chain of custody certificate that meets the applicable requirements of this standard. The certification body must verify that goods received are covered by a valid certificate, are correctly labelled, specify their ingredient content, and have been correctly recorded in the organisation’s goods received record system.

3.6 The organisation shall have a system in place to control the use of any marine-

ingredients received that do not comply with the required specifications, that

includes the following elements:

a. The non-compliant ingredients shall be placed in a designated area, where

they are excluded from further processing until their status has been

assessed.

b. If the ingredient does not comply with MSC’s requirements to exclude

material associated or at risk of being associated with IUU fishing, it shall be

returned to the supplier.

c. If the ingredient complies with MSC’s requirements to exclude material

associated with IUU fishing but does not meet other specifications it may be

included in the production process, but the marine material it contains shall

not be recorded as MSC Mass Balance Recognised Marine Material.

d. The record of ingredients received shall be updated so that it accurately

reflects the classification of the material as not being MSC Mass Balance



Recognised Marine Material, or the rejection of the ingredient from

production, as applicable.

Principle 4: Mass Balance Calculation, Labelling and Sales Data

The organisation shall calculate and record the net Mass Balance of its MSC Mass Balance Recognised Marine Material for the preceding twelve months, at the end of each month. Sales of outputs associated with a Mass Balance claim in the following month may never exceed the organisation’s net Mass Balance calculated at the end of the preceding month.

4.1 The organisation shall have a documented system in place to record the weight of

marine material contained in each of its end products, which shall correspond to

the total weight of the marine material in the product’s ingredients at the time of

its/their use in the manufacture of the end product, calculated as a percentage of

the product’s final weight, converted into kg/mt as required.

Consultation note:

This requirement specifies that the quantity of marine material used shall be determined at

the point that the ingredient is used to manufacture the end product. If an ingredient has

been processed after it has been supplied to the organisation but prior to its use to

manufacture an end product (equivalent to the ‘mixing bowl stage’ in food manufacture) it is

the weight after such prior processing that shall be used towards the determination of the

amount of marine material in the end product. The weight of water or waste that has been

lost through processing prior to this point shall not be counted.

Consultation note:

The weight of water added and/or volatile ingredients lost in the manufacture of the end

product itself shall not be considered for the purpose of this calculation.

4.2 If the processing of an MSC Mass Balance Recognised Marine Ingredient prior to

its use to manufacture an end product is likely to result in a change of more than

5% by weight between the time of its delivery to the site and the time of its use,

for example due to the extraction or addition of water, or removal of waste, then

the weight difference for such prior processing shall be determined and recorded,

and shall be used as a conversion ratio for the calculation of Mass Balance Input

Mass as specified in paragraph 4.4, below.

If there is no such processing prior to use, or if such processing would not be expected to result in a change of more than 5% by weight, then no such conversion factor needs to be determined.

DRAFTING NOTE

This requirement is based on the determination of quantity defined in REGULATION (EU) No 1169/2011 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 25 October 2011, ANNEX VIII: QUANTITATIVE INDICATION OF INGREDIENTS, paragraph 3. However, the derogations described in paragraph 4 of the EU Regulation shall not apply.



Consultation note:

MSC will provide guidance on request as to whether a conversion ratio needs to be

calculated for the application of the MSC Mass Balance Standard in specific scope

applications. In the case of Aquaculture Feed Mills, no such conversion is required.

DRAFTING NOTE

The Mass Balance Input Conversion Ratio could apply, for example, in the case of a product containing seaweed, if the seaweed is supplied to a manufacturing plant when wet, and is then dried prior to its use in the manufacture of a Mass Balance Designated Product.

In such a case the Input Mass would be the dried weight of seaweed, rather than its original wet weight at the time it is supplied to the manufacturing site.

The intent is that this approach gives a fairer basis for claiming credit for the sustainability of ingredients that may be mixed with other marine ingredients that are not converted in the same way.

The calculation of a conversion ratio allows data on the weight of MSC Mass Balance Recognised Marine Material at the time of its supply to the site to be used as the basis for calculating the Input Mass, without having to keep MSC-Recognised and non-MSC-Recognised ingredients separate after they arrived on site.

4.3 The organisation shall have a documented system in place to record the

quantities of all of its marine-sourced product sales that have been supplied from

its site, including:

a. Product name, including a unique identifier that indicates whether the product

was sold as a Mass Balance Designated Product

b. Dates of sale and supply from the organisation’s site

c. Quantity supplied (including conversion if required into kg/mt)

d. The total weight of the marine material within the product, calculated in

accordance with paragraph 4.1, above.

e. The customer name, company address and delivery address (if different to

company address)

f. The chain of custody certificate code that covers the product.

4.4 The organisation shall have a documented system in place to calculate and

record at the end of each calendar month the total weight of marine material

within the products that have been supplied from its site over the month,

calculated in accordance with the requirements specified in paragraph 4.1, above.

Mass Balance Calculation

4.5 The organisation shall have a documented system in place to calculate and

record at the end of each calendar month:



a. The total weight of MSC Balance Recognised Marine Material within the

ingredients it has received over the previous twelve months, corrected to take

account for the ingredient processing conversion ratio as specified in

paragraph 4.2 above, if applicable.

Guidance 4.5.a

This is the Input Mass

b. The total weight of marine material in the products that it has supplied as

Mass Balance Designated Products over the previous twelve months.

Guidance 4.5.b

This is the Output Mass

c. The value of the Input Mass minus the Output Mass over the previous twelve

months.

Guidance 4.5.c

This is the net Mass Balance

4.6 The net Mass Balance calculated in Criterion 4.5 above is the maximum mass of

output that may be supplied in association with a Mass Balance claim in the

following month. This figure shall not be negative.

Mass Balance Claims and Labelling

4.7 Any product that is sold as a Mass Balance Designated Product shall be labelled

with a mass balance statement and the applicable mass balance Chain of

Custody certificate number. No product sold without carrying the mass balance

statement and associated certificate number may be associated with any mass

balance claim.

Guidance 4.7

Where it is impossible or impractical to apply a physical label to the product the organisation

will need to demonstrate how the product can be verifiably linked with associated traceability

or inventory records that identify its Mass Balance Designated Product status.

4.8 Once a product has been designated as a Mass Balance Designated Product, it

shall be readily and reliably identifiable as such at all subsequent stages of

storage, processing, packing, labelling, selling and delivery to a customer.

4.9 The organisation shall operate a system that ensures packaging, labels, and other

materials identifying products as Mass Balance Designated Products can only be

used for Mass Balance Designated Products.

4.10 The organisation shall treat Mass Balance Designated Products and non-Mass

Balance Designated Products as separate product lines for the purposes of

invoicing, sales and distribution records.



4.11 When sold, all Mass Balance Designated Products shall be identifiable as such on

the line item of the related invoice.

4.12 The organisation shall only label, promote or make any other claims about its

sourcing, production or products in association with a Mass Balance statement if it

has been granted approval to do so under the terms of the MSC licence

agreement ([email protected]).

Principle 5: Management System Requirements

The organisation shall operate a documented management system that covers the implementation of the MSC Mass Balance Standard by it and its subcontractors, as applicable, and the organisation’s communication with its CAB.

5.1. Management and training

5.1.1. The organisation shall operate a management system, documented in a formal

manual or equivalent written procedures, that addresses all requirements in

this standard including specifying what records are kept and assigning

responsibilities for its implementation.

Consultation question:

Does the management system need to be formally documented? Or instead should this

clause be the same as the current MSC CoC Default Standard, “The organisation shall

operate a management system that addresses all requirements in this standard”?

5.1.2. The organisation shall ensure that responsible personnel are trained and

competent in order to ensure conformity with this standard.

5.1.3. The organisation shall maintain records that demonstrate conformity with this

standard for a minimum of 3 years, or for the full duration of the certified

products’ shelf life if longer than 3 years.

5.1.4. The organisation shall appoint an individual contact person who will be

responsible for all contact with the CAB and for responding to any requests for

documentation or information related to CoC conformity.

5.2. Reporting changes

5.2.1. The organisation shall inform their CAB in writing or by email within 10 days of

the following changes:

5.2.1.1. New contact person within the organisation, as specified in 5.1.4

5.2.1.2. Marine-sourced ingredients received from a new certified supplier.

5.2.1.3. A new type of marine-sourced ingredient received.

5.2.2. The organisation shall receive written approval from their CAB before making

the following changes:

mailto:[email protected]



5.2.2.1. Undertaking a new activity with respect to certified products, which

is not already included in the scope of certification.

5.2.2.2. Using a new subcontractor that does contract processing or

packing/repacking for certified products.

5.3. Subcontractors, transport and contract processing

5.3.1. The organisation shall be able to demonstrate that all subcontractors handling

certified product comply with the relevant requirements of this standard.

5.3.2. The organisation shall maintain an up-to-date record of the names and

addresses of all subcontractors handling certified products or any material that

may be used as ingredients for certified products, excluding transport

companies.

5.3.3. The organisation shall inform any non-certified contract processors that they

will be required to have an on-site audit by the CAB to verify compliance with

relevant sections of this Standard prior to use of the contract processor and at

least once per year afterwards.

5.3.4. If subcontracted storage facilities are used, the organisation shall have the

ability to request relevant product records from subcontractor storage facilities

and to allow CABs access to certified products or any material that may be

used as ingredients for certified products at any point in time.

5.3.5. The organisation shall have a signed agreement with all subcontractors that

transform, process, or repack certified products or any material that may be

used as ingredients for certified products, which covers the following points:

5.3.5.1. The subcontractor shall have systems in place to ensure

traceability, segregation, and identification of certified products or

any material that may be used as ingredients for certified products

at every stage of handling; and

5.3.5.2. The subcontractor will allow the MSC, the CAB, and the MSC’s

accreditation body to have access to the premises and any records

related to certified products or any material that may be used as

ingredients for certified products upon request.

5.3.6. Organisations that use contract processors or perform contract processing of

certified products or any material that may be used as ingredients for certified

products shall maintain records of all such contract-processed ingredients or

certified products, including:

5.3.6.1. Weight and product details received;

5.3.6.2. Weight and product details dispatched;

5.3.6.3. Dates of dispatch and receipt.



5.3.7. Certified contract processors shall record the name and CoC code for all

certificate holders for whom contract processing of certified products or

material that may be used as ingredients for certified products has been

provided since the previous audit.

5.4. Requests for traceability and supply chain assurance

5.4.1. The organisation shall cooperate with all MSC and CAB requests for chain of

custody information or purchase records for marine-sourced ingredients or

sales records for certified marine-sourced products.

5.4.2. Documents shall be provided within 10 days of request.

5.4.3. Organisations shall allow the MSC, the CAB or a representative from the

accreditation body to collect samples of marine-sourced ingredients or certified

marine-sourced products from their site for the purposes of DNA or other

product authentication testing.

5.4.3.1. Where a product authentication test identifies the marine-sourced

ingredient or a certified marine-sourced product as a differing from

the specifications covered by the scope of its Chain of Custody

certification the organisation shall:

Investigate the potential source of the issue.

Present the CAB with findings from this investigation and, where non- conformities are found, a corrective action plan to

address these.

Cooperate with further sampling and investigation.

166 167



168

Appendices

Appendix A: Exclusion of Material Associated with IUU Fishing A.1. Guidance on MSC Sourcing Requirements in relation to IUU Fishing

MSC requires that the organisation implements measures to avoid the use of material sourced from IUU fishing. This refers to material sourced from:

vessels listed on Regional Fisheries Management Organisations (RFMO) blacklists.

A consolidated list of such IUU-identified vessels is maintained at http://iuu-vessels.org/iuu.

A.2. Chain of Custody Requirements

All ingredients supplied to the organisation that contain marine-sourced material must be covered by a chain of custody certificate which provides a credible guarantee that the ingredient excludes any material from the sources listed in Appendix A1.

A range of approaches are considered to provide an acceptable guarantee that such material has been excluded from its ingredients:

The ingredient could be sourced directly from and be covered by a certificate issued to a fishery that is certified to a production standard that ensures that the specified unacceptable sources have been excluded.

The ingredient could be sourced from and be covered by a chain of custody certificate issued to a processor or other supplier whose own sources are certified as excluding any material from the specified unacceptable sources.

The ingredient could be sourced from a fishery or other supplier and be covered by a chain of custody certificate that guarantees that any material supplied has been subject to a risk assessment, and that there is an acceptably low risk that the ingredient contains any material from the specified unacceptable sources.

Any combination of the above.

A.3. Chain of Custody Certificates that MSC Recognises as Meeting the Requirements of Appendix A1 and A2.

MSC currently recognises material covered by the following chain of custody certificates (or equivalent) as meeting the requirements specified in Appendices A.1 and A.2:

Material covered by an IFFO RS Factory certificate

Material covered by an IFFO RS Chain of Custody certificate

Material covered by an MSC Chain of Custody certificate

NOTE: This list is for illustrative purposes only at this stage of drafting. MSC will review and confirm which existing CoC or similar schemes currently provide a credible guarantee that material from the specified unacceptable sources has been excluded from the supplied ingredients.

If a supplier sources material that is covered by a chain of custody certificate that is not on this list, the supplier may encourage the relevant scheme owner to apply to MSC for recognition of certificates issued under the scheme. Appendix B: Scope Specific Guidance for the Application of the MSC Mass Balance Standard for Fish Feed Manufacture B.1. MSC Mass Balance Recognised Marine Material for Aquaculture Feed

http://iuu-vessels.org/iuu



The requirements for marine material that is recognised as an input for the MSC Mass Balance calculation when applied to the manufacture of fish feed are defined in the ASC Feed Standard.

The ASC Feed Standard recognises marine material at four different levels of sustainability. The ASC Feed Standard specifies its own requirements requiring that the amount of marine material at each of these levels increases over time towards ‘higher’ levels of sustainability. Thus, the ASC Feed Standard requires that organisations record and report the amount of material they source from sources at each of these four levels of sustainability.

However, material at all four levels is considered to be MSC Mass Balance Recognised Material, and so for the purposes of the Mass Balance calculation the organisation needs to report only the total amount of material at all four levels in combination, and not the amount of material at each separate sustainability level.

B.2. Requirements for Chain of Custody Certification of MSC Mass Balance Recognised Marine Material for Aquaculture Feed

1. In order to be recognised by MSC as an acceptable chain of custody certificate for the identification of MSC Mass Balance Recognised Marine Material for Aquaculture Feed, the certificate must be issued under a scheme that meets the following requirements:

1.1 The applicable standards for the scheme (including all relevant source, chain of custody, and/or risk assessment standards) must be available to the public for download from the internet at no cost.

1.2 The scheme must be operated:

EITHER: exclusively by certification bodies that are accredited by an IAF-member National Accreditation Body as operating the scheme in compliance with the requirements of ISO 17065.

OR: exclusively by ISEAL Member organisations within the scope of their ISEAL member programme.

1.3 MSC and/or its agents must have full access to any reports produced by the scheme or its agents that are relevant to the demonstration of the certificate holder’s compliance with the scheme’s requirements.

1.4 The scheme must have been assessed by MSC as meeting the requirements of Appendix A and Appendix B of this Standard, as applicable.

1.5 The scheme must have paid any applicable fees to cover the costs of such MSC assessment.

2. In addition, in order for a certificate issued under the scheme to be recognised by MSC the scheme must require that holders of this certificate type:

Must be able to demonstrate that all of their supplies of marine ingredients are from sources that comply with the requirements specified in Appendix A.1

Must keep records of all the marine-sourced material supplied to them for the previous three years, which includes:

o The name, address and contact details of the supplier

o A detailed specification of the material supplied

o The date and quantity of material supplied



Must periodically take and keep representative samples of all of their supplies of marine ingredients and finished products, in line with applicable Good Manufacturing Practice (GMP) standards. Samples shall be:

o Preserved and protected against destruction (rodents, insects, etc.), deterioration (moisture, mould, etc.) or adulteration (e.g. in a chest freezer).

o Kept for a minimum of three years.

In the case of material supplied from a fishing vessel, must keep records that include:

o Name of vessel, registration number, call sign, legal owner, name and address.

o Proof of authorisation to engage in the specific fishing activity.

o Time of discharge to facility.

o Species and quantity discharged.

o Location or place(s) and dates of fishing activity where catch originated.

NOTE: Location description should be standardised, following FAO-defined fishing areas.

o Fishing method used.

Must specify on the product and/or in accompanying documentation that can be linked to a specific delivery of the product, for every consignment of its product that is sold as being covered by an MSC-recognised chain of custody certificate:

o The proportion of the product that is from sources certified as meeting the requirements for MSC Mass Balance Recognised Material as specified in Appendix B1.

B.3. List of Certification Schemes Currently Recognised as meeting Chain of Custody Requirements for MSC Mass Balance Recognised Marine Material for Aquaculture Feed

At present no schemes are formally recognised by MSC as meeting the requirements specified in Appendices B.1 and B.2.

It is expected that in future IFFO RS Factory, IFFO RS Chain of Custody and MSC Chain of Custody schemes will be modified so that they meet the specified requirements.

Appendix C: MSC Recognition of Chain of Custody Certification Schemes

To be developed

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