Background

Currently, all operators that take ownership of Marine Stewardship Council (MSC) certified products must be certified against the MSC’s Chain of Custody (CoC) standard, which requires an onsite audit and assessment by an independent, accredited conformity assessment body (CAB). This process helps to ensure that every operator in the supply chain complies with the seafood traceability standards and that all the products bearing the MSC ecolabel originated in a MSC certified fishery.

Feedback from stakeholders suggests that the current CoC requirements need to be adjusted to be more accessible for food service operators, such as restaurants, fresh fish counters, caterers, or traders. Some food service operators have voiced concerns about the high costs and complex process required for CoC certification, particularly for those companies who perceive themselves as low risk (for example, they only source MSC certified products, or they don’t transform MSC products during ownership).

In response to these concerns, MSC is undertaking an internal project to identify possible alternative solutions that will improve the accessibility of CoC certification in the foodservice sector, without compromising the credibility of the standard or the MSC ecolabel.

Key accessibility challenges for a set of operators have been identified. This information has been collated based on input from MSC outreach and direct feedback from CoC certificate holders (particularly restaurants and large catering companies) who have provided MSC with comments about the current CoC standards and requirements.

Restaurant chains: Typically certified under Group CoC. Chain restaurants have provided feedback about CoC requirements, and cite the following as primary barriers to accessibility:

1)      Group certification is considered too complex and prescriptive to be feasible.

2)      Requirements don’t accommodate varying levels of risk (e.g. some restaurants have highly 'centralised' purchasing and distribution policies).

3)      Costs (both for audits and logo licensing) can be high, given the low volume of MSC product compared to overall menus.

4)      Availability of product is an issue.

5)      Language is technically complex.

Caterers: Caterers are operators who prepare meals consumed outside of the home. Caterers provide food and/or personnel onsite for different types of businesses and institutions, such as hospitals, offices, school systems, etc.  Caterers often operate at multiple sites and thus are typically certified through group certification. Some of the main challenges that caterers face with regards to CoC certification include:

1)      Group certification is too prescriptive to account for the variability of sites and activities.

2)      Costs and complexity of group certification is not justified by the low risk level posed by caterers and the limited number of MSC products they can sell.

3)      Internal audit requirements are prescriptive and frequency is too high to be practical.

4)      Requirements around scope changes are too difficult for caterers to comply with.

5)      Record keeping requirements are too complex and an administrative challenge.

6)      Challenging to manage personnel working offsite in compliance with CoC requirements.

Box Movers: This category includes operators responsible of receiving, holding and dispatching seafood. Their key challenges with accessibility include:

1)      Don’t understand the relevance of certification because they consider their business low-risk (e.g some box movers don’t even have product onsite).

2)      Significant negative impacts on upstream customers if box movers cannot get certified, especially for US food service market.

3)      Costs of certification and complexity of requirements are considered too difficult given the relatively low level of risk.

4)      MSC requirements can be repetitive with other systems already in place to track boxes (i.e. tracing via batch codes).

Traders: These are defined as operators buying and selling seafood. Traders may work for themselves or other companies, and may handle the product themselves or subcontract all handling. Under current requirements, traders must have CoC certification because they take ownership of the product, although they may never physically handle the product. Common barriers to accessibility include:

1)      Don’t understand the relevance of CoC certification, particularly for traders who don’t handle products.

2)      Onsite audits are considered time-consuming and costly for desk-based traders, given the level of risk.

3)      Re-certification requirement after 3 years is considered unnecessary if nothing changes.

Fresh fish counters at retailers: These include sections within retailers dedicated to selling fresh seafood products; fish may be sold loose or pre-packed and may be processed (e.g. portioned or prepared) within the store. Under the current system, fish counters can be covered under single site or group CoC, depending on whether the retailer is independent or part of a chain. Key accessibility challenges cited for fresh fish counters at retailers include:

1)      CoC  standards (e.g. Group CoC) are too complex for operators who sell mainly non-MSC seafood.

2)      Lack of year-round availability of MSC certified seafood.

3)      High cost of audits and logo licensing.

4)      Requirements around scope changes aren’t feasible for fresh fish counters.

5)      Some retailers source fish locally, no centralised supply system.