MSC Chain of CustodyMarine Stewardship Council Chain of Custody

The Marine Stewardship Council (MSC) Chain of Custody (CoC) Standard is a traceability program designed to ensure that seafood sold with the MSC blue ecolabel comes from a fishery that has been certified to the MSC Fisheries Standard for sustainable fishing. While the Fisheries Standard focuses on the health of fish stocks and the management of the marine environment, the Chain of Custody Standard focus is entirely on the supply chain. It provides a mechanism for tracking seafood products through every stage of processing, distribution, and sale, ensuring that certified sustainable seafood is not mixed with or replaced by non-certified product 1.

For a product to carry the MSC blue label, every business in the supply chain that takes legal ownership of the seafood must hold a valid Chain of Custody certificate. This creates an unbroken chain of accountability from the boat to the plate. If a single link in the chain—such as a processor, a wholesaler, or a re-packer—is not certified, the product loses its right to be sold as MSC-certified sustainable seafood. This rigor is what maintains consumer trust in the label and supports the market for sustainable fishing practices.

Generally, any organisation that takes legal ownership of MSC-certified seafood and wishes to sell it as MSC-certified or use the MSC ecolabel must be certified. This includes a wide range of businesses across the global seafood supply chain 4.

• Primary processors who receive fish directly from the fishery.
• Secondary processors who further process, fillet, or package seafood.
• Traders and wholesalers who buy and sell certified products.
• Distributors and logistics providers who take ownership of the goods.
• Catering and food service companies that serve MSC-certified seafood.
• Retailers who package or process fish in-store (e.g., fresh fish counters).

Organisations that do not take legal ownership—such as freight forwarders or third-party storage facilities that only handle sealed containers—may not require their own certification, provided they are covered by the owner's certification and management system. However, they are still subject to the traceability and segregation requirements of the standard.

To accommodate the diverse nature of the seafood industry, the MSC provides three versions of the Chain of Custody Standard. Each version is tailored to different business models and operational scales 2.

1. Default Version (v5.1)

The Default version is the most common and applies to single-site or multi-site organisations where each site is managed individually or under a central quality management system. It is designed for processors, traders, and wholesalers who handle certified products in a standard commercial environment 1.

2. Group Version (v2.1)

The Group version is intended for organisations with many small sites, such as a large restaurant chain, a franchise, or a group of independent fishmongers under a central office. The central office takes responsibility for the management system and internal audits, while the individual sites are audited by the certification body on a sampling basis 3.

3. Consumer-Facing Organisation (CFO) Version (v2.1)

The CFO version is specifically for businesses selling seafood directly to the final consumer, such as restaurants, fish and chip shops, and supermarket fish counters. It focuses on the point of sale and the need to communicate the certified status to the customer, while ensuring that the internal handling of the product prevents mix-ups 2.

The MSC Chain of Custody Standard is built on five core principles that must be met by every certified organisation. These principles provide the framework for a robust traceability system 3.

1. **Certified products are purchased from certified suppliers:** Organisations must verify the certification status of their suppliers and ensure that the products they receive are indeed certified. This involves checking the MSC database and ensuring the supplier's certificate is valid and covers the relevant species.
2. **Certified products are identifiable:** Certified seafood must be clearly marked at all times. This includes labelling on crates, bins, and pallets during storage and processing, as well as clear identification in the ERP or inventory system.
3. **Certified products are segregated:** Certified and non-certified products must be physically separated. This prevents accidental mixing or substitution. Segregation can be achieved through dedicated storage areas, specific production times, or clearly defined physical barriers.
4. **Certified products are traceable and volumes are recorded:** Every batch of certified seafood must be traceable from receipt to sale. Organisations must maintain accurate records of the quantities of certified seafood purchased, processed, and sold, allowing for a mass-balance reconciliation.
5. **The organisation's management system addresses the requirements:** The business must have a documented management system that includes staff training, record-keeping procedures, and a process for handling non-conforming products. This ensures that the requirements are consistently met over time.

One of the most critical technical aspects of the MSC CoC Standard is the requirement for physical segregation. Unlike some other sustainability schemes that allow for 'mass balance' at the product level (where certified and non-certified products are mixed and a percentage is sold as certified), the MSC generally requires that the physical product carrying the label is truly from a certified source 4.

In the MSC context, 'mass balance' refers to the administrative reconciliation of inputs and outputs. An auditor will check that the volume of MSC-certified salmon sold does not exceed the volume of MSC-certified salmon purchased, accounting for yield factors. However, this administrative check does not replace the requirement for physical segregation during production. If a processor runs a batch of certified cod followed by a batch of non-certified cod, they must ensure the line is cleared and the products are never mixed.

For manufacturers using highly integrated systems, this means the batch-record and audit-trail must explicitly show the transition between certified and non-certified streams, often supported by cleaning logs or 'break' timestamps in the production record.

The MSC blue ecolabel is a registered trademark and its use is strictly controlled. Certified organisations must sign a license agreement with MSC International (MSCI) before they can use the label on products, menus, or promotional materials.

• **Approval Process:** Every piece of artwork featuring the MSC label must be submitted to the MSCI for approval before printing.
• **Label Elements:** The label must include the MSC blue fish logo, the trademark 'Certified Sustainable Seafood', and the organisation's unique Chain of Custody code.
• **Species Verification:** The label can only be applied to products containing seafood from a fishery that was certified at the time of harvest.
• **Minimum Seafood Content:** For a product to carry the label, 95% of the total seafood content must be MSC-certified.

Failure to follow these rules can lead to the suspension of the CoC certificate and legal action for trademark infringement. Organisations often use their quality management system to track label approvals and ensure that only authorised versions of packaging are used in production.

MSC does not perform the audits itself. Instead, it relies on a network of accredited independent certification bodies (CABs). These CABs are themselves monitored by Assurance Services International (ASI) to ensure consistency and impartiality 4.

The Audit Process

• **Pre-audit:** The organisation prepares its management system and records.
• **On-site Audit:** The auditor visits the site, inspects storage areas, observes production, interviews staff, and reviews records.
• **Reporting:** The auditor identifies any non-conformities that must be addressed.
• **Certification Decision:** Once non-conformities are closed, the CAB issues the certificate.

Chain of Custody certificates are typically valid for three years, subject to annual surveillance audits. In some cases, high-risk organisations or those with previous non-conformities may be subject to unannounced audits.

To satisfy the traceability requirements of Principle 4, a manufacturer's ERP or warehouse management system must maintain detailed records. These records are the primary evidence used during an audit to prove that no mixing or substitution occurred.

The system should also store copies of supplier coa and coc documents, which often carry the MSC claim for specific shipments. Modern systems use serial-traceability to automate the link between the receipt and the final sale, reducing the risk of human error in mass-balance calculations.

Principle 5 requires a documented management system. This is not just about having a manual on a shelf; it is about ensuring that the MSC requirements are integrated into the daily operations of the business. Key components include:

• **Staff Training:** All personnel involved in handling certified seafood must be trained on the importance of segregation and identification. Training-records must be maintained and updated regularly.
• **Non-Conforming Product:** There must be a clear procedure for what to do if certified product is accidentally mixed with non-certified product. This usually involves removing the MSC claim from the affected batch.
• **Subcontractor Management:** If the organisation uses third-party processors or warehouses, they must ensure these subcontractors are either certified themselves or covered under the organisation's own scope.

During audits, certain areas frequently emerge as points of failure. Understanding these pitfalls can help organisations prepare more effectively.

• **Inadequate Supplier Verification:** Failing to check the MSC database to ensure a supplier's certificate has not expired or been suspended.
• **Poor Identification in Storage:** Leaving bins or crates of fish unmarked, leading to confusion during busy production shifts.
• **Mass-Balance Discrepancies:** Failing to account for moisture loss or trim waste in yield calculations, leading to an apparent 'creation' of certified fish.
• **Missing CoC Code on Invoices:** The standard requires that the MSC claim and the organisation's CoC code be clearly stated on every invoice and delivery note for certified products.

The V5 platform is designed to automate the heavy lifting of traceability and record-keeping required by the MSC Chain of Custody Standard. By integrating these requirements into the core manufacturing workflow, V5 helps ensure that compliance is a byproduct of production, not a separate administrative burden.

Key features include automated electronic-batch-record generation, real-time yield monitoring to support mass-balance reconciliation, and a centralized document vault for storing supplier certificates and ecolabel approvals. In the event of a quality issue, V5's mock-recall tools can trace an MSC-certified batch back to the fishery in minutes, providing the high level of supply chain assurance required by modern retailers.