The additional requirements, which are being introduced following a series of development steps including a public consultation period, are part of a new suite of assurance procedures and tools that reflect responsible practice and including provision for use of digital traceability and innovative product authentication techniques.
Currently, processors, traders and other supply chain companies handling ASC certified products are audited against the Marine Stewardship Council (MSC) chain of custody standard. The new requirements set out in ASC’s CoC module are additional to the MSC CoC Standard and apply only to ASC farmed seafood products.
Once the new module is effective, companies will be required to undertake a streamlined audit against both the MSC CoC Standard and the new ASC CoC module. The process is not anticipated to be onerous for CoC certified businesses or new applicants, with a maximum of nine additional clauses to be addressed at audit and a minimum of two, depending on individual company circumstances. The module was significantly revised in response to public consultation feedback to minimise impacts on supply chain companies and auditors.
“Our aim is to improve the integrity of ASC certified products, to apply a risk-based approach to potential integrity issues in the supply chain, and to strengthen response procedures when issues occur,” said Wendy Banta, head of supply chain assurance, in a press release.
The new requirements will form part of ASC CoC audits starting from 30 May 2023. The one-year period until the effective date will allow certificate holders and conformity assessment bodies (CABs) who are responsible for undertaking audits, to prepare for implementation.
The additional requirements include the need for supply chain companies involved in processing, contract processing, packing or repacking, to be certified by a Global Food Safety Initiative (GFSI) recognised scheme, or to have ISO 22000 certification. There is an exemption for small companies with an annual turnover less than €2 million, trading less than 200 tonnes of seafood, or employing less than 50 seafood-related business staff. Exempted small companies must still comply with food safety regulations and are encouraged to work towards certification through improver programmes for GFSI-recognised schemes.
ASC CoC certificate holders will be required to carry out a fraud vulnerability assessment to increase awareness and attention to areas of potential risk for seafood fraud, and the ASC module provides guidance to help undertake this process. Requirements related to organisation and product compliance with applicable laws and regulations and conformity with ASC requirements are also incorporated.
First buyer checks have been included to address risk early in the supply chain, which means that companies sourcing directly from ASC certified farms must check there is no gap in CoC certification coverage between the farm and themselves, and that only eligible products are traded as certified.
Another part of the module is the requirement for certifiers to moderately increase use of unannounced audits to get a more accurate picture of daily operations. Certificate holders will be selected using an unannounced audit risk calculator developed by ASC, factoring in a tiered approach to specific risks that were supported in public consultation, such as a history of suspension or investigation, previous non-conformities, country of operation, species and type of activity.
An important new addition is a defined list of ineligibility criteria to allow ASC and certifiers to disconnect from companies involved in unacceptable practices such as illegal or fraudulent activities, or unethical behaviour. There must be proof that a criterion applies.
“We are confident that the new package of requirements in the ASC Chain of Custody module will provide greater value and a higher level of assurance to programme participants and customers who rely on the ASC logo,” said Banta.