The Chain of Custody Standard Review

The MSC Chain of Custody Standard assures consumers that seafood sold with the blue MSC ecolabel comes from fisheries that are MSC certified as sustainable. It also provides assurance that products sold with the Aquaculture Stewardship Council (ASC) label have come from ASC certified farms. 

To achieve certification to this Standard, supply chain companies must demonstrate that certified seafood products are separated from non-certified products as they make their journey through the supply chain before sale to the public.

Why are we reviewing our Standard?

There have been significant changes within our program and across wider seafood industry since our Chain of Custody Standard was last reviewed in 2019. 

These changes include the publication of the MSC Fisheries Standard (v3.1) and subsequent Fisheries Program Revisions, and introduction of the MSC Labour Eligibility Requirements, and the Aquaculture Stewardship Council (ASC) supplementary Chain of Custody module.

We have seen best practices evolve, advancements in digital technology and changes to regulatory requirements. We will also consider learnings from the Covid-19 pandemic and how supply chain companies and the MSC responded to this challenge.

These changes all provide opportunities to build on and improve our Chain of Custody program.

What will be revised?

The review will focus on the three versions of the MSC Chain of Custody Standard (Default, Group and Customer Facing Organisations (CFO)), and the Chain of Custody Certification Requirements. 

The MSC will also review the ASC Chain of Custody module requirements with the aim of improving alignment with the MSC Chain of Custody program where appropriate.  

Find out more about how we develop and revise our Standards. 

What are the objectives?

Through the review we aim to: 

• Address any challenges that have arisen from the implementation of the current Chain of Custody Standard to enhance credibility and legitimacy of our program. 
  
• Empower Chain of Custody certificate holders to take action against food fraud risks in the supply chain and demonstrate compliance with evolving traceability regulations. 
  
• Improve the accessibility of our Standard by removing unnecessary complexity in language and clarifying requirements for different supply chain actors.  
• Explore collaboration with other standard setters to efficiently satisfy market demand for scope extension. 

Key areas of revision

To achieve our objectives, the review will focus on the following key areas:

1. Implementation review of all three versions of the Standard: introducing revisions where the intent of our requirements is unclear or is not being met. 
2. Implementation review of the Chain of Custody Certification Requirements: to reflect any changes introduced to the Standard, and to enhance program credibility.
3. Chain of Custody Standard Accessibility review: addressing reported accessibility challenges while maintaining the integrity of the program. This includes clarifying which supply chain actors require certification.
4. ASC Chain of Custody module alignment: identifying where ASC module requirements could be incorporated into the Standard and Certification Requirements.
5. Fraud mitigation: identifying how MSC and ASC Chain of Custody certificate holders can better protect themselves from food fraud. This includes considering the role of recognised assurance mechanisms within the broader Chain of Custody program to help increase resilience against the risk of food fraud. 
6. Remote auditing: Developing a recommendation for the role of remote auditing within the CoC program, based on analysis of the use of remote audits during the COVID-19 pandemic, and reviewing best practice.
   
7. Strengthening traceability: Addressing traceability challenges observed at the intersection between the MSC Fishery Program and the MSC Chain of Custody program. By providing more guidance to support CABs during the fishery assessment in determining where the Chain of Custody certificate should begin based on the scope of a fishery and associated traceability systems in place. This also includes outlining information that the fishery should share with the first purchaser in the supply chain to demonstrate that the product is MSC certified.
   
8. Facilitating Scope and Eligibility Extension whilst delivering efficiencies: recognising the value of mutual recognition and stronger relations with other providers of supply chain standards, this includes identifying whether new processes can be introduced or existing processes can be made more efficient. 
   

Review timeline

The Chain of Custody Standard Review began in September 2023 and is expected to be completed by early 2027.

Any revised program documents will be effective six months after they have been published, and will apply to existing Chain of Custody certificate holders and those entering the MSC program for the first time.

Key milestones

• September 2023 - Terms of Reference published
• Late 2023 - Research phase begins and targeted consultations held
• 2024/25 - Policy development and testing through targeted consultations and pilot tests
• Early 2026 - Mock audits and 60-day public consultation on draft revised Standard
• Early 2027 - Publication of revised Standard and associated program documents (subject to approval from the MSC Board of Trustees)
• Late 2027 - Revised Standard in effect

If you have any questions about transitioning to the updated requirements, please contact your MSC representative, ASC representative, or your CAB. 

Take part in the review

Stakeholders are at the heart of our review and help identify issues, develop solutions and test the possible impacts of any proposed changes.

All stakeholders will have an opportunity to provide feedback on the proposed revisions to the Standard through a public consultation. A 60-day public consultation will be held in early 2026.

Contact us

If you have any questions about the review please contact [email protected] or your regional MSC representative.