2. Purpose of the consultation. 3. Background. MSC - Marine Stewardship Council Consultation Document Consumer-Facing Organisation (CFO) Standard

Transcription

1 MSC - Marine Stewardship Council Consultation Document Consumer-Facing Organisation (CFO) Standard Consultation Dates 1 30 September 2017 MSC Contact Shen Yan Liow FOR CONSULTATION 1 1. Executive summary This consultation document seeks stakeholder feedback on proposals to clarify the eligibility for companies that can be certified against the MSC Consumer-Facing Organisation (CFO) Chain of Custody Standard. Stakeholder feedback suggests that the current eligibility criteria is ambiguous, specifically on the concepts of common management and centralised purchasing control. The proposed revisions to the CFO CoC Standard v1.0 aim to ensure accurate interpretation and application on the management requirements for companies with multiple sites and rectify other known inconsistencies in the standard. Key points - Clarified common management and central purchasing requirements have been clarified for companies operating across multiple sites - Known areas of inconsistency and ambiguity have been improved and streamlined - Addition of clause to align central management requirements with CFO certification eligibility and their responsibilities for all sites 2. Purpose of the consultation To seek stakeholder views on the proposed changes to the CFO Standard. 3. Background In 2015, the MSC published a new version of the Chain of Custody (CoC) standard the CFO version designed to cater for and better reflect business operations at the end of supply chain such as caterers, restaurant chains, fishmongers and retailers with fresh fish counters. This version applies to companies with a single or any number of sites that sell MSC and/or ASC certified seafood directly to final consumers. For companies with more than one site, there are additional requirements to demonstrate maintenance of common management by a designated central office to ensure conformity across all sites. The MSC has since received stakeholder feedback on the current eligibility criteria for common management and centralised purchasing control required for companies with multiple sites. Consumerfacing companies expressed uncertainties on the MSC s intent, and have questioned their potential eligibility to access and become certified against the CFO Standard. Concerns raised: Whether site/store level purchasing is permitted, and if such purchasing must be authorised by the central office Whether the central office must control not only suppliers, but also certified product lists Whether all site level purchase and traceability records be kept centrally Whether there are different traceability requirements between operations sites and consumer-facing sites These concerns have been discussed within the MSC, with certification bodies and the MSC Technical Advisory Board. In addition, desk-based research has been conducted to learn how certified CFOs and interested applicants are structured and operate seafood buying to gauge whether the criteria should be changed. This work has pointed towards a need to improve specific aspects of the current standard by restructuring, changing wording and introducing additional guidance to ensure clear interpretation and application. The original intent for eligibility has been upheld, and there should be no impacts for existing certified CFOs in qualifying for this version of the standard. Consultation Document Consumer-Facing Organisation CoC Standard 1

2 The proposed revisions to the CFO Standard are currently open for consultation and a summary is also available in Appendix A. The revisions should not raise or lower the bar for entry, but some changes to the standard requirements may require small adjustments by certified CFOs to meet specific clauses. 4. Considerations As the CFO Standard is new, the MSC Executive intends to only make small improvements during the CoC Program Review. Fundamentally, stakeholder feedback so far suggests the standard is significantly more accessible and fit-for-purpose. Therefore, all proposed changes will only be limited to help improve consistency and clarity in the standard s application. The eligibility criteria for the standard have been determined to ensure that only relevant organisations with homogenous, standardised, centralised operations can qualify. The main criteria are that: (a) the organisation sells to the final consumer; and (b) if companies handle certified seafood in more than one site, there is a shared infrastructure (common management system) in place determined by the central office and enforced to all sites included in the certificate. Unlike the MSC Group CoC Standard, where there are more prescriptive management requirements for internal controls, the objective of the CFO Standard is that the central office has control and visibility at site-level operations through a common management system, and that product integrity can be maintained through such a system. The current CFO Standard, as well as the proposed revisions, will remain simple and outcome-based so that companies can easily integrate the standard into their existing systems and procedures. While the MSC has retained its simplicity, such as requiring an input-only system for traceability to reflect the nature of consumerfacing sales, other measures will be introduced to protect certified product integrity, such as ensuring that site-level purchase and handling of certified products are being managed and overseen by central office management. 5. Potential interactions with other work This workstream falls within the broader CoC Program Review in and follows the proposed improvements for the MSC Default CoC Standard closely, which is also currently open for public consultation. The relevant proposed changes to the Default Standard are reproduced in the draft CFO version presented here. 6. Next Steps The consultation draft of the standard will be available for comment online from 1 30 September All consultation feedback will be anonymised and published in a report on the MSC Program Improvements website after the consultation closes. This will also be ed to all respondents. Following this public consultation and based on the feedback received, the CFO Standard and corresponding audit requirements in the CoC Certification Requirements will be reviewed and developed for public consultation in Subject to final MSC Board of Trustees approval, it is anticipated that all revisions to the CFO Standard and certification requirements will be finalised for release in August Who can comment? How do I give feedback? This consultation is public and open to all interested parties. The online feedback survey allows you to respond to specific questions on this topic. We also welcome any more detailed comments that you wish to make on this consultation which can be ed directly to: standards@msc.org Consultation Document Consumer-Facing Organisation CoC Standard 2

3 Appendix A: Summary of proposed revisions Current CFO Standard 1 Criteria 4 Section E Eligibility for the CFO Standard For companies with more than one site, the organisation s central office shall maintain control of all sites including purchases of certified seafood from certified suppliers 2 Clauses Traceability of certified products Each site is required to demonstrate traceability of certified product from the point of sale/ serving back to a certified delivery 3 Clause Management requirements for companies with multiple sites Certified sale across the organisation should reflect the scope of certification Proposed improvements To clarify the criteria to ensure that only relevant organisations can become certified against the CFO version. The MSC s intent by developing this version for the end of supply chain was to enable CoC certification for companies with homogenous, standardised, centralised seafood operations and infrastructure. This version of the standard requires fewer additional internal processes and procedures for the purpose of CoC, unlike the Group Standard. The assumption being that companies with shared infrastructure and centralised purchasing controls already have a tighter framework in place that restricts menus/fish counter displays, staff, and seafood supply. To restructure clause 4.1 to introduce the distinctions between consumer-facing site and operations site much earlier on. Clauses 4.1 and 4.2 have also been streamlined to clearly outline traceability requirements based on the different site activities, as well as the required coordination at every stage of handling for companies with multiple sites. Whilst the MSC intends to simplify traceability by requiring input-only recording system, the improvements will ensure the language and requirements are more consistent. The clause has been restructured to outline more clearly the expectations of the MSC for companies with multiple sites. In addition, guidance was included and enhanced to support more consistent interpretation. Clause has been introduced to reflect the MSC s eligibility criteria, to reemphasise the interaction between central office and all sites and the overall outcomes they should achieve for example ensuring purchasing activities are within scope and the central office has visibility of site level traceability. Consultation Document Consumer-Facing Organisation CoC Standard 3

4 Appendix B: Draft Consumer-Facing Organisation Standard Introduction A. Responsibility for this Standard Responsibility for this standard is held by the Marine Stewardship Council. Readers should verify that they are using the latest copy of this (and other related documents). The definitive version of the standard is maintained on the MSC s website at Versions issued Version No. Date Description of amendment th February 2015 First publication. B. About this document This document contains mandatory requirements for Consumer-Facing Organisations seeking MSC Chain of Custody (CoC) certification. Non-mandatory guidance has been developed to help interpret and apply the requirements in this standard. C. General introduction Chain of Custody certification CoC certification provides credible assurance that products sold with the MSC ecolabel or trademarks originated from a certified fishery and can be traced throughout the supply chain to a certified source. Companies certified against the MSC CoC Standard are audited by a third-party accredited certification body and are subject to periodic surveillance audits over the three year period of a CoC certificate. Use of MSC s Chain of Custody by other standard setting-organisations The MSC CoC Standard is made available for use by selected organisations that operate certification schemes. At the time this standard was issued, the Aquaculture Stewardship Council (ASC) has elected to use the MSC CoC Standard for all certified seafood products originating from ASC-certified farms. This allows supply chain companies to handle both MSC-certified and ASC-certified seafood with a single CoC audit, although separate CoC certificates are issued, and each standard has distinct trademarks. If other certification schemes choose to also use the MSC CoC Standard in the future, this information will be published on the MSC website. Consultation Document Consumer-Facing Organisation CoC Standard 4

5 D. Scope and options for Chain of Custody certification Any organisation trading or handling products from a certified fishery or farm is eligible to have Chain of Custody (CoC) certification. CoC certification is a requirement for each organisation in the supply chain taking legal ownership of certified products that wishes to make a claim on the certified source, up until the point where products are packed into consumer-ready tamper-proof-packaging. The MSC has one Default Chain of Custody Standard and two variants: one for Group organisations and one for Consumer-Facing Organisations (CFOs). Further information on eligibility for each version can be found in the MSC CoC Certification Requirements (section 6.2) and in the introduction to each document. CoC Standard: Default Version This standard is applicable to any organisation that has a site (physical location) handling or trading certified products. The Default CoC Standard is also applicable to any organisation that has numerous sites handling certified products, but where each site is individually audited against the CoC Standard. In this case, a single certificate and CoC code is issued, and it is called a multi-site certificate. Examples of companies that might be certified against the Default CoC Standard include a trading company operating out of one office, or a processor with several factory locations. Some clauses of the standard (such as purchasing from certified suppliers) may not apply where the organisation is a farm or a fishery. CoC Standard: Group Version The Group version of the CoC Standard applies to any organisation handling certified products at many sites, where each site is not individually audited by the CAB. This can be more efficient than multi-site certification for organisations with many sites, or groups of organisations that join together. The organisation designates a central office function that establishes internal controls and is responsible for making sure every site complies with the CoC Standard. The CAB audits the central office and a sample of sites, rather than auditing every site. A single CoC code and certificate are shared across the group. Examples of organisations that might be certified against the Group CoC Standard might include a large wholesaler with several dozen warehouse locations, or a restaurant chain (having decided not to be certified against the CFO Standard). Some clauses of the Standard (such as purchasing from certified suppliers) may not apply where the organisation is a farm or a fishery. CoC Standard: Consumer-Facing Organisation (CFO) Version The CFO Version of the CoC Standard applies to any organisation that serves or sells seafood to the final consumer and meets other specific eligibility criteria. Consumer-Facing Organisations (CFOs) such as retail or foodservice can be single site or have numerous locations, and one CoC code is issued for all sites under the organisation s management system that handle or trade certified products. Similarly to Group CoC, the CAB audits a sample of the total number of sites in the certificate. Examples of CFOs include restaurants, restaurant chains, fishmongers, retailers with fish counters, and caterers. Consultation Document Consumer-Facing Organisation CoC Standard 5

6 E. Eligibility for CoC Standard: Consumer-Facing Organisation (CFO) Version Organisations are eligible to be certified against the CFO Version of the CoC Standard only if all the following applicable criteria are met: 1. The organisation sells and/or serves certified seafood exclusively or primarily to final consumers. 2. Any sites that carry out processing or repacking of certified seafood do so exclusively on behalf of the organisation. 3. If the organisation uses contract processors or repackers, these organisations have their own CoC certification. 4. If the applicant has more than one site handling certified seafood: a) All sites are under the control of a common management system, which determines the parameters for seafood supply, traceability infrastructure, staff procedures, and is maintained by the organisation s designated central office; and b) The central office has an ownership or franchise relationship with each site, or a temporary right to manage all sites and staff where certified seafood is handled to ensure conformity with the MSC standard; andthe central office has full visibility of purchases conducted at site level,, with controls to ensure that all sites can only order certified seafood from certified suppliers. Note: Some organisations may be eligible to use any one of the Default, Group or CFO Versions of the CoC Standard. Organisations are advised to check their eligibility against all CoC certification options (i.e., Default, Group, CFO) available in section 6.2 of the CoC Certification Requirements before discussing the best option with their CAB. F. Effective date Commented [SYL1]: Overall, keeping this highlevel and outcome based.key areas of concern on eligibility has been instead integrated into relevant clauses. All revisions proposed have not raised/ lower the bar for certification entry but simply to clarify eligibility and the MSC s intent. Deleted: operational Commented [SYL3]: Greater emphasis and alignment with CFO Standard language clause Commented [LF4]: Greater emphasis and alignment with CFO Standard language clause Commented [LF5]: More specificity to describe MSC s intent of purchases being controlled. Deleted: Purchases of certified seafood are controlled by the central office Deleted: will The effective date for version 1.0 of the CFO CoC Standard is 1 st September All CoC audits carried out from this date against the CFO CoC Standard must use this version of the standard. G. Review date The next planned review of this standard will commence within five years of publication. The CoC Standard review is conducted in accordance with the ISEAL Standard Setting Code. The MSC welcomes comments on the CoC Standard at any time and input will be incorporated into the next review process. Please submit comments by mail or to the contact details provided in this document. More information about the MSC policy development process and MSC Standard Setting Procedure can be found on the MSC Policy website and MSC website. Consultation Document Consumer-Facing Organisation CoC Standard 6

7 H. Normative documents FOR CONSULTATION 1-30 September 2017 Concepts, terms and phrases are defined in the MSC & MSCI Vocabulary. Consultation Document Consumer-Facing Organisation CoC Standard 7

8 CoC Standard: Consumer-Facing Organisation (CFO) Version Principle 1 Certified products are purchased from certified suppliers 1.1 The organisation shall have a process in place to ensure that all certified products are purchased from certified suppliers This process shall include using the scheme owner s website to verify the supplier s certificate is valid at the time of purchase, or at a minimum once a month if purchases are made more frequently. Guidance 1.1 Certified products refer to any seafood that originates from certified fisheries or farms and is identified as certified. This excludes seafood products in consumer-ready tamper-proof packaging (i.e., sealed and labelled products that will be sold to final consumers in the same form, such as individual cans of tuna). For a full definition of consumer-ready tamper-proof, refer to section 6.1 of the Chain of Custody Certification Requirements. A certified supplier can be a certified fishery or farm, or a supplier with a valid Chain of Custody (CoC) certificate. Where the organisation has multiple sites, controls to ensure that sites only purchase certified products from certified suppliers may include approved buying lists, controlled purchasing lists, or enterprise resource planning (ERP) systems that block non-certified suppliers. This does not imply that every certified purchase must be done by the central office. 1.2 Organisations handling physical products shall have a process in place to confirm the certified status of products upon receipt. Guidance 1.2 Documentation received with certified products needs to clearly identify the product as certified. This could include delivery notes, invoices, bills of lading, or electronic information from the supplier. This is to help ensure that if a supplier replaces certified seafood with non-certified seafood (e.g., if stock runs out), this will be detected by the receiving company. If a supplier uses an internal system (such as barcodes or product codes) to uniquely identify certified products on documents, the receiving company needs to understand the supplier s description in order to confirm the product is certified. If associated records do not clearly identify products as certified, it is not sufficient to rely only on physical product labelling (e.g., an MSC or ASC label on a box) to confirm the certified status. Commented [LF6]: Major change: Addition (new requirement) Rationale: This process is best-practice, as buyers should check frequently that their supplier s certificates are still valid, as these can become invalid from one day to the next. There is a new clause in the Default standard that will require companies to inform their customers if the certificate becomes invalid, but there still needs to be a way for buyers to protect themselves from forged (fake) certificates. Consultation question: Is monthly/at every purchase if purchases are made on a weekly or daily basis too frequent? Commented [LF7]: Medium change: Addition (new guidance) This has been added to link with eligibility criteria 4c) to give examples of the purchasing controls expected. This is an outcome-based standard, but examples provide applicants with guidance on how to meet the clause. Deleted: ecolabel Consultation Document Consumer-Facing Organisation CoC Standard 8

9 1.3 Organisations with certified products in stock at the time of the initial certification audit shall be able to demonstrate that these products were purchased from a certified supplier and comply with all relevant sections of this standard before they can be sold as certified. Guidance 1.3 Certified product in inventory at the time of initial certification will need to be traceable back to a certified supplier or fishery/farm, as per principle 4. The organisation will also need to demonstrate that any certified product in inventory is identifiable and segregated as per principles 2 and 3. Principle 2 Certified products are identifiable 2.1 Certified products shall be identified as certified at all stages of purchasing, receiving, storage, handling, labelling, display, and serving or selling. Guidance 2.1 It is recommended that certified products are identifiable as certified on the physical product as well as on the accompanying traceability records. This can be done by placing a sign or label on the package, box, or bag. Organisations can use a variety of methods to label or identify certified products, including acronyms (e.g., MSC or ASC ), the CoC code, or another internal system of identification. Where it is impossible or impractical to label physical products (e.g., loose fish stored in a designated space in the freezer) the organisation will need to demonstrate how the product can be linked with associated traceability or inventory records that specify the certified status. 2.2 The organisation shall operate a system that ensures packaging, labels, menus and other materials identified as certified can only be used for certified products. 2.3 The organisation shall only promote products as certified or use the ecolabel, logo, or other trademark(s) if it has been granted approval to do so under the terms of the licence agreement (ecolabel@msc.org). Guidance 2.3 Use of the acronyms (e.g., MSC or ASC ) or the full name of the standard (e.g., Marine Stewardship Council or Aquaculture Stewardship Council) on products or traceability records that are not consumer-facing (e.g., only for identification purposes) is allowed without a license agreement. Any other use of the ecolabel, logo, or other trademarks requires a license agreement with MSCI, the MSC s licensing function for MSC and ASC products. During an audit, the organisation may be asked to show evidence of approval to use trademarks. This can be done through showing the valid license agreement and/or evidence of approval s received from MSCI. Consultation Document Consumer-Facing Organisation CoC Standard 9

10 Principle 3 Certified products are segregated 3.1 There shall be no substitution of certified products with non-certified products. 3.2 Certified and non-certified products shall not be mixed if the organisation intends to sell the products as certified or with trademarks, except as in If non-certified seafood is used as an ingredient in certified products, the organisation shall follow the MSCI Certified Ingredient Percentage Rules, available on the MSC website. Guidance In consumer facing or business to consumer cases, non-certified seafood can be used as an ingredient in certified products. However, special restrictions apply, which are included in the MSCI Certified Ingredient Percentage Rules. 3.3 Products certified against different recognised certification schemes that share MSC CoC shall not be mixed if the organisation wishes to sell the product as certified, unless: The organisation has specific permission from MSCI, or The same product is certified against multiple recognised certification schemes that share MSC CoC. Commented [LF8]: Medium change: Modification Rationale: To clarify that this requirement only applies to consumer-facing products. In other words, the intention is to disallow a block of MSC IQF pollock to be 5% non-certified pollock. Deleted: some specific Deleted: prepared (i.e. constituted of more than one source) Guidance 3.3, and This applies to any other standard, such as the Aquaculture Stewardship Council (ASC), which uses the MSC CoC Standard for supply chain traceability. MSC certified fish and ASC certified fish cannot be mixed at any point in the supply chain if they are to be sold as certified. Clause refers to organisations that have specific permission from MSCI to combine MSC and ASC certified seafood in consumer-facing products with both trademarks. A current list of other recognised schemes sharing the MSC s CoC Standard can be found on the MSC website. Principle 4 Certified products are traceable and volumes are recorded 4.1 The organisation shall have a traceability system that allows: Any product sold as certified at a consumer-facing site to be traced from the point of sale or serving back to a certified delivery or purchase Any product handled as certified at an operations site to be traced from the point of output back to a certified delivery or purchase Transfer of certified product between sites to be traced. Consultation Document Consumer-Facing Organisation CoC Standard 10 Commented [SYL9]: Medium change: Modification Reworded, restructured and streamlined all traceability requirements at different levels (i.e. for Consumer-Facing site, operations site & central office) for easier reference and comparison. There is no change of intent. Deleted: Each site shall be able to demonstrate that certified products are traceable from the point of sale or serving back to a certified delivery. Deleted: back Deleted: back Deleted: Organisations with multiple sites, where there are certified product isare transfersed between sites, to trace any product shall be traceablefrom between initial purcahase and delivery to all consumer-facing sites.

11 Guidance 4.1 and A consumer-facing site is a discrete physical location (such as a restaurant location, fish counter, or catering site) that prepares, cooks, sells or serves certified seafood directly to a final consumer An operations site is any site that is involved in value-added processing, storage of business-to-business goods, or distribution of certified products and does not sell or serve certified seafood directly to final consumers. A CFO CoC certificate holder may have operations and consumer-facing sites included in their CoC certification. In some cases a site can be considered both a consumer-facing and operations site (e.g., a supermarket with a small warehouse for storing frozen goods). The consumer-facing site (i.e. restaurant or retail) needs to be able to demonstrate that products labelled as certified on the menu or fish counter can be linked back to a certified input (delivery) at the time of audit. This could be an invoice or delivery note from a certified supplier, or it could be an internal delivery note or transfer sheet demonstrating certified product was received from an internal operations site (i.e., distribution centre or storage) managed by the central office. During an audit at a consumer-facing site, traceability will usually be checked for any products currently served or labelled as certified. If no certified products are being sold or served at the time of the audit, the auditor may instead trace a certified product from storage back to a certified delivery. Commented [SYL10]: Brought forward the current Guidance to introduce the concept & definition of Consumer Facing site vs. Operations site earlier. With this we can better illustrate and clarify the difference for traceability requirement throughout Principle 4. Also provided further clarity here to illustrate internal distribution. Deleted: (such as a restaurant location or catering site). Deleted: B2B Deleted: packing or repacking Deleted: site Commented [LF12]: Added to make link clear with auditing intent that immediate traceability is only ever verified (not historic). Deleted: (operations site) 4.2 Traceability systems shall be able to link certified product at every stage between purchase and delivery to consumer-facing sites, including receipt, processing, repacking, storage and distribution. Guidance 4.2 If certified products are moved between or within sites, the traceability system needs to ensure products are fully traceable at every step back to purchase. This includes, for example, shipment from a distribution centre (operations site) to a restaurant (consumer-facing site), or handling within a processing site (operation site). 4.3 The organisation shall maintain records showing quantities of certified seafood purchased and received over any given period If certified and non-certified products of the same (or similar) species are handled at the same time, the organisation shall maintain records of non-certified seafood purchases or deliveries for these similar species. Commented [SYL13]: Medium change: Modification Reword clause 4.2 to be more align with Default Standard also to emphasise the integrity at every stage Consultation question: Is this clause duplicate and unnecessary, as the intent is essentially captured by 4.1? Deleted: If the organisation has multiple sites, and there are product transfers between sites, there shall be a traceability system that ensures certified products are traceable at every step of handling between initial purchase and delivery to a consumer-facing site. Deleted: During an audit, the certifier may check historical traceability records for any period over the previous 18 months to verify conformity with this requirement Guidance 4.3 and Volumes of certified product sold do not need to be recorded to comply with this requirement. However, if the organisation has a system to carry out an input/output reconciliation (comparing total volumes of certified fish received Consultation Document Consumer-Facing Organisation CoC Standard 11

12 and sold), this lowers the risk score and can affect the required auditing activities. Clause is intended to help the CAB confirm that only certified products are identified or labelled as certified. Similar species refers to seafood products that are made from closely related species (e.g., cod and haddock), or that are otherwise similar in physical appearance (e.g., whitefish fillets). 4.4 Traceability and volume records shall be accurate, complete, and unaltered Where records are changed, these changes shall be clearly documented including the date and name or initials of the person making the changes. Commented [LF14]: Medium change: Modification Providing more specific guidance. Deleted: visual Deleted:, such as different Guidance Where information or records provided by the organisation during audits or other requests is not consistent with information provided at a different point in time, the CAB may issue non-conformities. If records are altered by the organisation to reflect necessary adjustments (such as returned orders), these changes should be clearly recorded. 4.5 The organisation shall only sell as certified the products covered by its scope of certification. Guidance 4.5 The requirements for changes to scope that cover new species, activities or product certified against other recognised certification schemes that share MSC CoC are given in , and Principle 5 The organisation has a management system 5.1. Management and site control The organisation shall operate a management system that addresses all requirements in this standard. Guidance The management system includes the systems, policies and procedures used to ensure that the organisation complies with the CFO CoC Standard. The extent of documentation required for the management system may vary, depending on the size of the organisation, the type of activities, the complexity of processes, and the competency of personnel. For very small or straightforward operations, no written documentation may be needed as long as the responsible staff understand and can implement procedures related to the CoC Standard effectively. Consultation Document Consumer-Facing Organisation CoC Standard 12

13 5.1.2 The organisation shall appoint an individual (CoC 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. Guidance The CoC contact person is responsible for communicating with the CAB any certificate scope changes as per clause 5.3, and ensuring that the organisation responds to any requests for information or documentation. If the contact person changes, the CAB needs to be notified as per clause Commented [LF15]: Medium change: Modification, consistent with change to Default standard. Rationale: To make this generic, regardless of scheme. Deleted: MSC Deleted: MSC The organisation shall maintain records that demonstrate conformity with this standard for a minimum of 18 months. Guidance Records that demonstrate conformity with the CFO CoC Standard typically include purchase records of certified products, internal traceability records, internal staff procedures, and documentation of training completed If the organisation has multiple sites handling certified seafood, the organisation shall designate a central office which is responsible for overseeing and maintaining a common management system to ensure conformity across all sites. The central office shall: Guidance A common management system refers to a shared operational infrastructure in place determined by the central office and enforced to all sites included in the certificate that enables central office control and visibility of site-level operations regarding seafood supply, seafood labelling, traceability procedures, and staff. The CAB will evaluate that all sites are working to the same centrally determined protocols and procedures that ensure product integrity Have procedures in place to ensure that all sites handling certified seafood meet the requirements of this standard Have a system in place to ensure that all sites can only order certified seafood from certified suppliers, covered by its scope of certification Maintain an accurate list of all sites, which includes the address and contact details for each site, and distinguishes between consumer-facing and operations sites Provide a current and complete site list within five calendar days of receiving a written request from the MSC or the CAB Notify the CAB in writing in advance of increasing the number of sites by more than 50% since the previous audit. Commented [SYL16]: Medium change: Clause moved Brought this a level up, as clauses should be achieved by central office management Commented [LF17]: Medium change: Addition (new guidance) Common management system has not been defined, and there is some confusion as to what MSC intends by this concept. This is a guidance, and therefore companies will not be audited against this definition. Consultation questions: Is this definition helpful, realistic, and fit-for-purpose? Deleted: controlled Commented [SYL18]: Major change: Addition (new clause) This is a new clause but has always been the intent throughout the current CFO standard. This requirement makes it clear that a site-level process is required for the CFO to meet clause The purpose of this clause is to be more explicit on central office s need to monitor sites to prevent sourcing from product or supplier list outside its certificate scope. Commented [LF19]: Consultation question: This requirement has not been raised as an issue by stakeholders, but MSC would like to take the opportunity to consult on its rigour and effectiveness. Adding up to 50% of sites can be a significant increase without CAB verification or assessment that the CFO has sufficient control, especially given that these sites could be in other countries/regions. For example, a sushi chain could open with 20 certified stores in France, and add 3 stores in the UK, 3 in Belgium, and 3 in China to the certificate in one year without needing to request approval from the CAB. Should verification be required for adding a smaller % e.g. 20%? Or should there be a requirement that if there is overseas expansion it needs prior approval by the CAB? Consultation Document Consumer-Facing Organisation CoC Standard 13

14 Guidance For example, where an organisation has 100 sites, they would not need to contact the CAB beforehand if they add 50 sites or fewer between audits. If more than 50 sites are added since the previous audit, the CAB needs to be notified in writing and the CAB may decide to carry out additional audit activities Have a process to ensure that any sites that are no longer selling or serving certified seafood cannot continue to use the ecolabel, logo, or other trademarks. Guidance Clause is intended to help make sure that sites cannot continue to use the ecolabel, logo, or other trademarks on non-certified product; for example if one restaurant stops receiving MSC or ASC seafood. Where in contract catering an organisation loses one site, the organisation shall ensure relevant MSC/ASC materials are removed before another catering company takes over the site Training The organisation shall ensure that responsible personnel are competent to ensure conformity with this standard. Guidance Responsible personnel refers to individuals within an organisation who are responsible for making decisions or carrying out procedures related to the MSC CoC Standard. This might include staff working in the purchasing department, doing goods-in checks, and any individuals needing to identify, label, or select certified products. Regular training is very important to ensure that personnel follow internal procedures to ensure conformity with the CoC Standard. Training on CFO requirements can be incorporated into existing training programs where practical. The CAB will interview staff during audits to assess their level of competency and knowledge of the CoC Standard The organisation shall provide training to responsible personnel: Before the initial certification audit; As part of induction to new personnel; and At least annually after certification. Guidance After certification, training may need to be carried out more often than once a year to maintain competency; for example if staff turnover is very high. If the organisation is certified but there is a delay of several months before the Consultation Document Consumer-Facing Organisation CoC Standard 14

15 ecolabel or logo will be used, it is recommended that additional training is provided to staff just before use of the ecolabel/ logo on menus or product The organisation shall maintain records demonstrating that training has been carried out as per clause Reporting changes The organisation shall inform the CAB in writing or by within 10 days of the following changes: New CoC contact person within the organisation, as specified in Certified products received from a new certified supplier New certified species received. Guidance Notification by or writing needs to be sent to the CAB within 10 days of receiving a new certified species or within 10 days of receiving the first delivery of certified products from a new supplier. Commented [LF20]: Medium change: Modification, consistent with change to Default standard. Rationale: To make this generic, regardless of scheme Deleted: MSC The organisation shall receive written approval from their CAB before making the following changes: Undertaking a new activity with respect to certified products, which is not already included in the scope of certification. Guidance New activities include, for example, retail to consumer, repacking, or storage. A full list of activities can be found in Table 5 of the MSC CoC Certification Requirements Extending the scope of CoC to sell or handle products certified against different recognised certification schemes that share MSC CoC. Guidance For example, if the current CoC certificate covers only MSC-certified products, the organisation would need to receive approval from the CAB before selling ASC-certified products as certified Using a new subcontractor that does contract processing or packing/ repacking for certified products. Guidance If the organisation wishes to add a new storage subcontractor, this will need to be updated on the record of subcontractors as per 5.4.2, but the CAB can be notified at the next audit (no prior approval is needed). Consultation Document Consumer-Facing Organisation CoC Standard 15

16 5.4. Subcontractors The organisation shall be able to demonstrate that all subcontractors handling certified product comply with the relevant requirements of this standard The organisation shall maintain an up-to-date record of the names and addresses of all subcontractors handling certified products, excluding transport companies The organisation shall only use subcontractors that process or repack certified products if the subcontractor has a valid CoC certificate If subcontracted storage facilities are used, the organisation shall have the ability to request certified product records from subcontractor storage facilities and to allow CABs access to certified products at any point in time. Guidance A signed agreement is not needed for storage subcontractors, provided the organisation has the ability to request records (i.e., receipt and dispatch records) from the subcontracted storage facility. The organisation needs to also be able to grant the CAB access to the physical certified product at any point in time, even if it is currently being held in offsite third-party storage. If access to the storage site is restricted for any reason, the certified product may need to be taken offsite to be inspected by the CAB if there are product integrity concerns Non-conforming product Guidance 5.5 Non-conforming product relates to any product that is identified as certified or labelled with trademarks, but which cannot be proven to come from a certified source. Non-conforming product could be discovered internally by staff, by the supplier, or in some cases could be detected based on information received from the CAB, the MSC, or other parties. Where a certified product is ordered but the supplier delivers non-certified product, if this is discovered on receipt and the product is returned, the non-conforming process is not applicable The organisation shall have a process for managing non-conforming product that includes the following requirements: Immediately cease to sell any non-conforming product as certified, until the certified status has been verified in writing by the CAB Notify the CAB within two days of detecting the non-conforming product and provide the CAB with all necessary information to verify the origin of the non-conforming product Identify the reason the product is non-conforming and implement measures to prevent re-occurrence where necessary. Consultation Document Consumer-Facing Organisation CoC Standard 16

17 For any non-conforming product which cannot be verified as coming from a certified source, re-label or repack this product to ensure it is not sold as certified. Guidance If the product cannot be verified as coming from a certified supplier or fishery/ farm, it cannot be sold as certified or with trademarks Requests for traceability and supply chain assurance The organisation shall cooperate with all MSC and CAB requests for traceability documents or sales and purchase records for certified products Documents shall be provided within two days of request. Guidance Financial details may be removed but records need to be otherwise unaltered. Records are to be submitted in English if so requested by the MSC. If an extension is required, a request can be made in writing to the MSC, and if it is not approved, the original 10-day deadline must be met. If data is not submitted to the MSC within specified timeframes, the MSC may request that action be taken by the CAB, including issuing of nonconformities Organisations shall allow the MSC, the CAB or a representative from the accreditation body to collect samples of certified products for the purposes of DNA or other product authentication testing Where a product authentication test identifies the product as a different species or as originating from a different catch area than as identified, the organisation shall: a. Investigate the potential source of the issue. b. Present the CAB with findings from this investigation and, where nonconformities are found, a corrective action plan to address these. c. Cooperate with further sampling and investigation. Deleted: fishery Commented [SYL21]: Keeping consistent language as per Guidance 1.3 Deleted: certified Commented [LF22]: Major change: Modification, consistent with change to Default standard Rationale: Timeframe allowed has been reduced from ten calendar days to two working days in order to avoid delays for MSC investigations, supply chain reconciliations and tracebacks. Two working days is considered feasible given the quick turnaround needed for food safety concerns/product recalls. Consultation question: How quickly can your company provide traceability/sales/purchase documents, such as invoices, delivery notes, storage dockets, and internal transfer slips? Consultation Document Consumer-Facing Organisation CoC Standard 17