MSC - Marine Stewardship Council Consultation Document Mass Balance CoC Standard

Transcription

1 MSC - Marine Stewardship Cuncil Cnsultatin Dcument Mass Balance CC Standard Cnsultatin Dates 1 March t 30 April 2017 MSC Cntact Wendy Banta FOR CONSULTATION Executive summary Key Pints - MSC is develping a Mass Balance Chain f Custdy (CC) Standard. The Standard will be generic, hwever initially it is designed fr use by fish feed mills which seek certificatin against the new ASC Feed Standard. The Mass Balance Standard is fr business-tbusiness use nly. - MSC and ASC are cllabrating clsely t develp bth standards t ensure they functin effectively tgether and t streamline the audit prcesses. 2. Purpse f the cnsultatin The purpse f the cnsultatin is t btain feedback n the first draft f the MSC Mass Balance Standard, including hw it can be effectively aligned with the Aquaculture Stewardship Cuncil (ASC) Feed Standard. 3. Backgrund The MSC Mass Balance Standard is designed t be generic in its main cntent. Hwever, the key driver fr the Standard currently is the develpment f the ASC Feed Standard (ASC-FS). The Mass Balance Standard will apply t the fish feed mills in a business-t-business cntext nly, but it may be applied t ther sectrs (such as seaweed) in the future. The MSC Mass Balance Standard and the ASC-FS are being develped in separate but parallel prcesses, with clse cmmunicatin and crdinatin between MSC and ASC. Fr further details n the drivers and early develpment f the Mass Balance Standard, refer t the riginal prject Terms f Reference frm July Cnsideratins ASC is develping the ASC-FS fr certificatin f feed mills t supply respnsible feed t ASC certified aquaculture farms. Eventually all ASC certified aquaculture farms must use ASC certified feed. The ASC-FS aims t incentivise feed mills t surce respnsible raw materials ver time, partly by requiring increased vlumes f marine ingredients surced frm MSC (r equivalent) certified fisheries. MSC is develping the Mass Balance Standard (Appendix A) which will supprt the ASC-FS by prviding a basis fr the physical mixing f MSC-certified and apprved marine ingredients 1 with nncertified/nn-apprved marine ingredients at ASC-FS certified feed mills. Mass balance is necessary fr feed mills which d nt currently segregate certified and nn-certified materials due t lgistical challenges in the manufacturing prcess. Mass balance is necessary t catalyse the uptake f the ASC-FS, and thereby ver time create enugh certified raw material vlume t wrk twards a segregatin chain f custdy mdel. The tw standards are being develped separately in parallel prcesses by ASC and MSC respectively, with clse cmmunicatin and cllabratin between MSC and ASC t ensure the standards functin effectively tgether. The audit prcesses against bth will be aligned and streamlined. The ASC-FS will require feed mills t meet the MSC Mass Balance Standard fr mixing f certified/apprved and nn-certified/nn-apprved marine ingredients in rder t becme certified against the ASC-FS. 5. Ptential interactins with ther wrk This new draft standard has ptential interactins with the CC Prgram Review 2018 f standard imprvements and als a revaluatin f hw Illegally Unregulated Unreprted (IUU) fish can be prevented 1 See Appendices A.3 and B.3 (fr example, IFFO RS and IFFO RS CC). Cnsultatin Dcument Mass Balance CC Standard 1

2 frm entering a certified supply chain. While MSC is cntinuing wrk n the IUU prject and it is related t the Fishery Traceability prgram, this area is nt specifically part f the March April 2017 cnsultatin. 6. Next steps All cnsultatin feedback will be annymised and published in a reprt n the MSC Prgram Imprvements website after the cnsultatin clses. This will als be ed t all respndents. During the draft Mass Balance Standard public cnsultatin in March April 2017, MSC and ASC will be actively seeking feedback frm key stakehlders thrugh phne calls, s, wrkshps and webinars. The Mass Balance Standard and the ASC Feed Standard will als be pilted in a jint prcess with interested feed mills wh wish t participate in trialling the new standards. Feedback frm all cnsultatin activities and pilts will be cnsidered and incrprated where apprpriate t imprve the standards cntent and future implementatin. Cnsultatin nte Feed mills interested in participating in the pilt shuld respnd t MSC and ASC thrugh this cnsultatin fr mre infrmatin. 7. Wh can cmment? Hw d I give feedback? This cnsultatin is public and pen t all interested parties. The nline feedback survey allws yu t respnd t specific questins n this tpic. We als welcme any mre detailed cmments that yu wish t make n this cnsultatin which can be ed directly t: Wendy Banta, Supply Chain Standards Manager, at wendy.banta@msc.rg. Cnsultatin Dcument Mass Balance CC Standard 2

3 Appendix A DRAFT MSC Mass Balance Chain f Custdy Standard General intrductin The MSC Mass Balance Chain f Custdy (CC) Standard is being develped by MSC t supprt the fllwing high-level bjectives: T prvide the basis fr business-t-business (B2B) claims that culd be made by aquaculture feed supply chain cmpanies that are unable t segregate certified materials frm nn-certified materials, and therefre culd nt becme certified under the existing MSC CC Standard. The ASC Feed Standard fr feed mills (currently in develpment) wuld recgnise the MSC Mass Balance CC Standard as meeting its requirements fr traceability f marine ingredients in ASC cmpliant feeds. T prvide a CC slutin that culd als be applied in the future t ther marine-surced prduct sectrs n a similar basis, such as seaweed and nutraceutical supplements, if this is determined t be apprpriate. This relates t prviding supply chain traceability slutin t the MSC-ASC Seaweed Standard (als currently in develpment). Mre generally, t braden the MSC CC ffering t increase accessibility t the prgram fr use by aquaculture feed supply chains. This is part f a wider cncept t expand the ffering in bth directins f the CC mdel spectrum thrugh mass balance n ne end, and thrugh identity preservatin r digital traceability n the ther. Indirectly, t supprt the engagement f glbal reductin fisheries in the MSC prgram by prviding an incentive t becme certified r imprve twards future certificatin. The ASC Feed Standard will incentivise surcing frm certified sustainable fisheries, and the MSC Mass Balance CC Standard will ensure the required traceability fr marine ingredients. The mass balance apprach The mass balance apprach t claims has been develped by vluntary sustainability standards prgrams t allw cmpanies that are unable t segregate and trace certified ingredients within their prductin prcesses, fr a variety f reasns, t make claims t their custmers abut their surcing f certified material. The apprach is designed s that the mre certified material the cmpany surces, the greater the quantity f prduct that it can sell with an apprved claim. The intent is that this incentivises and rewards the surcing f increasing quantities f certified material withut the need t segregate and trace that material thrugh the prductin prcess. There are several variatins t this general mdel. The apprach taken in this standard is illustrated in Figure 1. Key elements f the mass balance apprach taken in this standard: MSC first defines the sustainability requirements fr the input material that will be recgnised as the basis fr making a mass balance claim. This material culd be frm MSC-certified sustainable fisheries, frm fisheries that are in transitin t MSC (ITM) r subject t Fishery Imprvement Plans (FIPs), r sme cmbinatin f these. This material is referred t in the standard as MSC Mass Balance Recgnised Marine Material. An rganisatin that is seeking mass balance certificatin must recrd the quantity f this material that it surces. The rganisatin can then make a mass balance claim fr the equivalent amunt f marine material cntained in its prducts. In line with MSC s general plicy n IUU fishing, in rder t access the MSC Mass Balance CC Standard the rganisatin must be able t shw that it des nt use marine material surced frm vessels listed n Reginal Fisheries Management Organisatins blacklists in any f its prducts that culd ptentially carry a mass balance claim. Cnsultatin Dcument Mass Balance CC Standard 3

4 Figure 1. The principle f mass balance claims Structure f the Standard The MSC Mass Balance Chain f Custdy Standard is structured arund five Principles. The intent is that these principles flw frm the statement f rganisatinal plicies, thrugh t the peratinal definitin and implementatin f thse plicies, and t the applicatin and cntrl f claims and labels under a mass balance system. Principle 1: Sustainable Surcing Plicy The rganisatin shall define and make public a general surcing plicy that cmmits t nt use f material surced frm vessels listed n Reginal Fisheries Management Organisatins (RFMO) blacklists. Principle 2: Specificatins and Targets fr Surcing Marine Ingredients The rganisatin shall specify and implement cntractual requirements with its suppliers f marine-surced ingredients. Principle 3: Marine-Surced Ingredients Management The rganisatin shall perate a stck cntrl system that ensures that all marine-surced ingredients it receives cmply with the rganisatin s cntract specificatins, and that the quantity f MSC Mass Balance Recgnised Marine Material it receives is recrded n delivery. Principle 4: MSC Mass Balance Calculatin, Labelling and Sales Data The rganisatin shall calculate and recrd the net Mass Balance f its MSC Mass Balance Recgnised Marine Material fr the preceding twelve mnths, at the end f each mnth. Sales f utputs assciated with a Mass Balance claim in the fllwing mnth may never exceed the rganisatin s net Mass Balance calculated at the end f the preceding mnth. 136 Principle 5: General MSC Management System Requirements The rganisatin shall perate a dcumented management system that cvers the implementatin f the MSC Mass Balance Standard by it and its subcntractrs, as applicable, and the rganisatin s cmmunicatin with its CAB. Cnsultatin Dcument Mass Balance CC Standard 4

5 Scpe f applicatin This standard is ptentially applicable t any rganisatin that has a site (physical lcatin) handling and trading MSC Mass Balance Recgnised Marine Material fr business t business (nn cnsumer-facing) purpses. Hwever, it can nly be used in assciatin with additinal scpe-specific guidance n its applicatin t specific categries f rganisatin and fr specific categries f material, t be determined by MSC n a case-by-case basis. Appendix B f this draft standard prvides a prvisinal example f such scpe-specific guidance, fr applicatin t aquaculture feed. The ASC Feed Standard The draft MSC Mass Balance Chain f Custdy Standard is being develped in parallel with the develpment f the ASC Feed Standard by the Aquaculture Stewardship Cuncil (ASC). The ASC Feed Standard defines requirements fr the certificatin f aquaculture feed mills and their prducts, fr supply t ASC certified aquaculture farms. The requirements f the ASC Feed Standard are referenced in MSC s scpe-specific guidance fr the applicatin f the MSC Mass Balance Standard t aquaculture feed (Appendix B). The MSC Mass Balance Chain f Custdy Standard and the ASC Feed Standard will cntinue t be develped in parallel, t ensure that they are mutually cmpatible. Once bth standards have been finalised it is expected that a cmbined MSC/ASC dcument will be develped t facilitate the jint implementatin f the tw standards by feed mills wishing t supply feed cntaining marine material t ASC-certified aquaculture farms. Cnsultatin Dcument Mass Balance CC Standard 5

6 MSC Mass Balance Chain f Custdy Standard DRAFT 1.0 Terms and Definitins Site: A discrete physical lcatin. (Frm MSC-MSCI Vcabulary, V1.1, 20 th February 2015). Cmpliant Prduct: A prduct within the scpe f a certified rganisatin s chain f custdy cntrl prgramme which is ptentially eligible t be cvered by r carry a chain f custdy cntrlled claim r label. Cntract Prcessr: An rganisatin that is cntracted by a certified rganisatin (including a subsidiary r affiliate f the certified rganisatin) wherein the prduct is altered in sme way. Specifically, the prcessr des nt wn the prduct and the prcessr prcesses the prduct n instructin frm the certified rganisatin (usually the wner f the prduct). This definitin excludes cntract prcessrs that take wnership f the prduct, since they are required t have their wn chain f custdy certificatin. (Frm MSC-MSCI Vcabulary, V1.1, 20 th February 2015). Marine Material: Material frm marine surces. Marine-Surced Ingredients: Ingredients that cnsist f, cntain, r are derived frm marine material. Mass Balance Designated Prduct: A cmpliant prduct that has been designated t carry a mass balance claim/label. Nte that in a mass balance system nly a limited prprtin f cmpliant prducts will actually be designated t carry mass balance claims/labels. MSC Mass Balance Recgnised Marine Ingredients: Ingredients that cnsist f, cntain, r are derived frm MSC Mass Balance Recgnised Marine Material. MSC Mass Balance Recgnised Marine Material: Marine material frm a surce that MSC recgnises as achieving an acceptable level f sustainability, fr the purpse f making a mass balance claim. The surces that MSC recgnises are specified separately fr the applicatin f the MSC Mass Balance Standard t particular types f marine material. 164 Organisatin: The entity that seeks certificatin fr its prductin under this standard. An rganisatin may be a cmpany, crpratin, firm, enterprise, authrity r institutin, r part r cmbinatin theref, whether incrprated r nt, public r private that has its wn functins and administratin. (Frm ISO 14001:2004). Cnsultatin Dcument Mass Balance CC Standard 6

7 165 Principle 1: Organisatin Surcing Plicy The rganisatin shall define and make public a general surcing plicy that cmmits the rganisatin t nt use f material surced frm vessels listed n Reginal Fisheries Management Organisatins (RFMO) blacklists. Cnsultatin nte: This Principle builds n the requirement specified in paragraph f the current MSC Chain f Custdy Standard: Default Versin, Versin 4.0, 20 th February Cmments are sught n whether additinal cmmitments shuld be specified fr inclusin in the Mass Balance Chain f Custdy Standard, fr example t exclude uncertified marine material surced frm cuntries that have been pre-identified by the Eurpean Unin as nncperating cuntries (issued with a s-called yellw card ) and r identified by the Eurpean Unin as nn-cperating cuntries (issued with a s-called red card ). 1.1 The rganisatin shall have a written and publicly available plicy in place that: Cnsultatin questin: Hw shuld this be made publically available? cmmits the rganisatin t avid the use f material surced frm vessels listed n Reginal Fisheries Management Organisatins (RFMO) blacklists expresses the rganisatin s intent t surce certified MSC Mass Balance Recgnised Marine Ingredients as available. Cnsultatin nte: The MSC Mass Balance Standard can nly be used in assciatin with scpe-specific guidance n its applicatin fr specific categries f prductin. This guidance includes definitins fr MSC Mass Balance Recgnised Marine Material fr ingredients used within the specified scpe f applicatin. See Appendix B.1 fr the categries applicable fr the manufacture f aquaculture feed. 1.2 The plicy referred t in 1.1 shall have been cmmunicated t all staff and all suppliers. Principle 2: Marine-Surced Ingredients Surcing Specificatins The rganisatin shall specify and implement cntractual requirements with its suppliers f marine-surced ingredients in rder t implement its surcing plicy. 2.1 The rganisatin shall have cntractual agreements in place with all f its suppliers f marine-surced ingredients that require that all such ingredients that are supplied t it shall be cvered by an MSC-recgnised chain f custdy certificate r equivalent that: prvides a credible guarantee that the ingredient des nt cntain material frm vessels listed n Reginal Fisheries Management Organisatins (RFMO) blacklists, and, Cnsultatin Dcument Mass Balance CC Standard 7

8 2.1.2 if applicable, specifies that any deliveries f MSC Mass Balance Recgnised Marine Ingredients shall be labelled with r therwise linked t dcumented infrmatin abut the quantity f the ingredient that is MSC Mass Balance Recgnised Marine Material, and, requires that all deliveries f marine-sured ingredients shall be labelled with r therwise linked t the fllwing accmpanying infrmatin: a. Ingredient name/unique identifier b. Quantity c. The supplier s name d. The chain f custdy certificate cde(s) (r equivalent) which cver the ingredient and prvides the specified guarantees e. The date f shipment NOTE: The cnditins that chain f custdy certificatin schemes must meet in rder t satisfy these requirements fr aquaculture feed are given in Appendix A.2 (in relatin t IUU fishing) and Appendix B.2 (in relatin t MSC Mass Balance Recgnised Marine Ingredients). Chain f custdy certificatin schemes that MSC currently recgnises as meeting these requirements are listed in Appendix A.3 (in relatin t IUU fishing nly), and in Appendix B.3 (fr IUU fishing and fr labelling f MSC Mass Balance Recgnised Marine Material). Chain f custdy schemes that are nt listed in Appendix A.3 r B.3 may apply t MSC fr assessment fr equivalence in rder t be added t the applicable list(s). 2.2 The rganisatin shall maintain an up-t-date listing f all f the marine-surced ingredients it currently uses fr its prductin, tgether with the names f the suppliers and their chain f custdy certificate numbers r equivalent. Principle 3: Marine-Surced Ingredients Management The rganisatin shall perate a stck cntrl system that ensures that all marine-surced ingredients it receives cmply with the rganisatin s cntract specificatins, and that the quantity f MSC Mass Balance Recgnised Marine Material it receives is recrded n delivery. 3.1 The rganisatin shall have a dcumented system in place t recrd the quantity f all marine-surced ingredients received 2, including: a. Ingredient name/unique identifier b. Date f physical receipt c. Quantity received (including cnversin if required int kg/mt) 2 The Standard fcuses n the date f receipt fr the purpse f calculating mnthly summaries and as the basis fr the input side f the mass balance calculatin. It is assumed that any timing differences between the quantities received, and the quantities actually used fr prductin are nt material in the cntext f the claims that may be made abut the mass balance system. Cnsultatin Dcument Mass Balance CC Standard 8

9 d. The quantity f the ingredient that is MSC Mass Balance Recgnised Marine Material, if applicable (including cnversin if required int kg/mt) e. The supplier s name f. The chain f custdy certificate cde (r equivalent) which cvers the ingredient 3.2 The rganisatin shall have a system in place t calculate and recrd at the end f each calendar mnth: a. The ttal weight f MSC Mass Balance Recgnised Marine Ingredients it has received ver the mnth, and b. The ttal weight f MSC Mass Balance Recgnised Marine Material cntained in these ingredients ver the mnth. 3.3 Recrds shall be accurate, cmplete, and unaltered. 3.4 Where recrds have been changed, these changes shall have been clearly dcumented including the date and name r initials f the persn that made the changes. 3.5 Organisatins taking physical pssessin f marine-surced ingredients shall have a prcess in place t verify that the ingredients meet all relevant sectins f this standard at the pint f delivery, and befre they can be used fr prductin. Guidance 3.5 Organisatins with marine-surced ingredients in stck at the time f the certificatin audit must be able t demnstrate that these ingredients are cvered by a chain f custdy certificate that meets the applicable requirements f this standard. The certificatin bdy must verify that gds received are cvered by a valid certificate, are crrectly labelled, specify their ingredient cntent, and have been crrectly recrded in the rganisatin s gds received recrd system. 3.6 The rganisatin shall have a system in place t cntrl the use f any marineingredients received that d nt cmply with the required specificatins, that includes the fllwing elements: a. The nn-cmpliant ingredients shall be placed in a designated area, where they are excluded frm further prcessing until their status has been assessed. b. If the ingredient des nt cmply with MSC s requirements t exclude material assciated r at risk f being assciated with IUU fishing, it shall be returned t the supplier. c. If the ingredient cmplies with MSC s requirements t exclude material assciated with IUU fishing but des nt meet ther specificatins it may be included in the prductin prcess, but the marine material it cntains shall nt be recrded as MSC Mass Balance Recgnised Marine Material. d. The recrd f ingredients received shall be updated s that it accurately reflects the classificatin f the material as nt being MSC Mass Balance Cnsultatin Dcument Mass Balance CC Standard 9

10 Recgnised Marine Material, r the rejectin f the ingredient frm prductin, as applicable. Principle 4: Mass Balance Calculatin, Labelling and Sales Data The rganisatin shall calculate and recrd the net Mass Balance f its MSC Mass Balance Recgnised Marine Material fr the preceding twelve mnths, at the end f each mnth. Sales f utputs assciated with a Mass Balance claim in the fllwing mnth may never exceed the rganisatin s net Mass Balance calculated at the end f the preceding mnth. 4.1 The rganisatin shall have a dcumented system in place t recrd the weight f marine material cntained in each f its end prducts, which shall crrespnd t the ttal weight f the marine material in the prduct s ingredients at the time f its/their use in the manufacture f the end prduct, calculated as a percentage f the prduct s final weight, cnverted int kg/mt as required. Cnsultatin nte: This requirement specifies that the quantity f marine material used shall be determined at the pint that the ingredient is used t manufacture the end prduct. If an ingredient has been prcessed after it has been supplied t the rganisatin but prir t its use t manufacture an end prduct (equivalent t the mixing bwl stage in fd manufacture) it is the weight after such prir prcessing that shall be used twards the determinatin f the amunt f marine material in the end prduct. The weight f water r waste that has been lst thrugh prcessing prir t this pint shall nt be cunted. Cnsultatin nte: The weight f water added and/r vlatile ingredients lst in the manufacture f the end prduct itself shall nt be cnsidered fr the purpse f this calculatin. DRAFTING NOTE This requirement is based n the determinatin f quantity defined in REGULATION (EU) N 1169/2011 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL f 25 Octber 2011, ANNEX VIII: QUANTITATIVE INDICATION OF INGREDIENTS, paragraph 3. Hwever, the dergatins described in paragraph 4 f the EU Regulatin shall nt apply. 4.2 If the prcessing f an MSC Mass Balance Recgnised Marine Ingredient prir t its use t manufacture an end prduct is likely t result in a change f mre than 5% by weight between the time f its delivery t the site and the time f its use, fr example due t the extractin r additin f water, r remval f waste, then the weight difference fr such prir prcessing shall be determined and recrded, and shall be used as a cnversin rati fr the calculatin f Mass Balance Input Mass as specified in paragraph 4.4, belw. If there is n such prcessing prir t use, r if such prcessing wuld nt be expected t result in a change f mre than 5% by weight, then n such cnversin factr needs t be determined. Cnsultatin Dcument Mass Balance CC Standard 10

11 Cnsultatin nte: MSC will prvide guidance n request as t whether a cnversin rati needs t be calculated fr the applicatin f the MSC Mass Balance Standard in specific scpe applicatins. In the case f Aquaculture Feed Mills, n such cnversin is required. DRAFTING NOTE The Mass Balance Input Cnversin Rati culd apply, fr example, in the case f a prduct cntaining seaweed, if the seaweed is supplied t a manufacturing plant when wet, and is then dried prir t its use in the manufacture f a Mass Balance Designated Prduct. In such a case the Input Mass wuld be the dried weight f seaweed, rather than its riginal wet weight at the time it is supplied t the manufacturing site. The intent is that this apprach gives a fairer basis fr claiming credit fr the sustainability f ingredients that may be mixed with ther marine ingredients that are nt cnverted in the same way. The calculatin f a cnversin rati allws data n the weight f MSC Mass Balance Recgnised Marine Material at the time f its supply t the site t be used as the basis fr calculating the Input Mass, withut having t keep MSC-Recgnised and nn-msc-recgnised ingredients separate after they arrived n site. 4.3 The rganisatin shall have a dcumented system in place t recrd the quantities f all f its marine-surced prduct sales that have been supplied frm its site, including: a. Prduct name, including a unique identifier that indicates whether the prduct was sld as a Mass Balance Designated Prduct b. Dates f sale and supply frm the rganisatin s site c. Quantity supplied (including cnversin if required int kg/mt) d. The ttal weight f the marine material within the prduct, calculated in accrdance with paragraph 4.1, abve. e. The custmer name, cmpany address and delivery address (if different t cmpany address) f. The chain f custdy certificate cde that cvers the prduct. 4.4 The rganisatin shall have a dcumented system in place t calculate and recrd at the end f each calendar mnth the ttal weight f marine material within the prducts that have been supplied frm its site ver the mnth, calculated in accrdance with the requirements specified in paragraph 4.1, abve. Mass Balance Calculatin 4.5 The rganisatin shall have a dcumented system in place t calculate and recrd at the end f each calendar mnth: Cnsultatin Dcument Mass Balance CC Standard 11

12 Guidance 4.5.a This is the Input Mass Guidance 4.5.b This is the Output Mass Guidance 4.5.c a. The ttal weight f MSC Balance Recgnised Marine Material within the ingredients it has received ver the previus twelve mnths, crrected t take accunt fr the ingredient prcessing cnversin rati as specified in paragraph 4.2 abve, if applicable. b. The ttal weight f marine material in the prducts that it has supplied as Mass Balance Designated Prducts ver the previus twelve mnths. c. The value f the Input Mass minus the Output Mass ver the previus twelve mnths. This is the net Mass Balance 4.6 The net Mass Balance calculated in Criterin 4.5 abve is the maximum mass f utput that may be supplied in assciatin with a Mass Balance claim in the fllwing mnth. This figure shall nt be negative. Mass Balance Claims and Labelling 4.7 Any prduct that is sld as a Mass Balance Designated Prduct shall be labelled with a mass balance statement and the applicable mass balance Chain f Custdy certificate number. N prduct sld withut carrying the mass balance statement and assciated certificate number may be assciated with any mass balance claim. Guidance 4.7 Where it is impssible r impractical t apply a physical label t the prduct the rganisatin will need t demnstrate hw the prduct can be verifiably linked with assciated traceability r inventry recrds that identify its Mass Balance Designated Prduct status. 4.8 Once a prduct has been designated as a Mass Balance Designated Prduct, it shall be readily and reliably identifiable as such at all subsequent stages f strage, prcessing, packing, labelling, selling and delivery t a custmer. 4.9 The rganisatin shall perate a system that ensures packaging, labels, and ther materials identifying prducts as Mass Balance Designated Prducts can nly be used fr Mass Balance Designated Prducts The rganisatin shall treat Mass Balance Designated Prducts and nn-mass Balance Designated Prducts as separate prduct lines fr the purpses f invicing, sales and distributin recrds. Cnsultatin Dcument Mass Balance CC Standard 12

13 4.11 When sld, all Mass Balance Designated Prducts shall be identifiable as such n the line item f the related invice The rganisatin shall nly label, prmte r make any ther claims abut its surcing, prductin r prducts in assciatin with a Mass Balance statement if it has been granted apprval t d s under the terms f the MSC licence agreement (eclabel@msc.rg). Principle 5: Management System Requirements The rganisatin shall perate a dcumented management system that cvers the implementatin f the MSC Mass Balance Standard by it and its subcntractrs, as applicable, and the rganisatin s cmmunicatin with its CAB Management and training The rganisatin shall perate a management system, dcumented in a frmal manual r equivalent written prcedures, that addresses all requirements in this standard including specifying what recrds are kept and assigning respnsibilities fr its implementatin. Cnsultatin questin: Des the management system need t be frmally dcumented? Or instead shuld this clause be the same as the current MSC CC Default Standard, The rganisatin shall perate a management system that addresses all requirements in this standard? The rganisatin shall ensure that respnsible persnnel are trained and cmpetent in rder t ensure cnfrmity with this standard The rganisatin shall maintain recrds that demnstrate cnfrmity with this standard fr a minimum f 3 years, r fr the full duratin f the certified prducts shelf life if lnger than 3 years The rganisatin shall appint an individual cntact persn wh will be respnsible fr all cntact with the CAB and fr respnding t any requests fr dcumentatin r infrmatin related t CC cnfrmity Reprting changes The rganisatin shall infrm their CAB in writing r by within 10 days f the fllwing changes: New cntact persn within the rganisatin, as specified in Marine-surced ingredients received frm a new certified supplier A new type f marine-surced ingredient received The rganisatin shall receive written apprval frm their CAB befre making the fllwing changes: Cnsultatin Dcument Mass Balance CC Standard 13

14 Undertaking a new activity with respect t certified prducts, which is nt already included in the scpe f certificatin Using a new subcntractr that des cntract prcessing r packing/repacking fr certified prducts Subcntractrs, transprt and cntract prcessing The rganisatin shall be able t demnstrate that all subcntractrs handling certified prduct cmply with the relevant requirements f this standard The rganisatin shall maintain an up-t-date recrd f the names and addresses f all subcntractrs handling certified prducts r any material that may be used as ingredients fr certified prducts, excluding transprt cmpanies The rganisatin shall infrm any nn-certified cntract prcessrs that they will be required t have an n-site audit by the CAB t verify cmpliance with relevant sectins f this Standard prir t use f the cntract prcessr and at least nce per year afterwards If subcntracted strage facilities are used, the rganisatin shall have the ability t request relevant prduct recrds frm subcntractr strage facilities and t allw CABs access t certified prducts r any material that may be used as ingredients fr certified prducts at any pint in time The rganisatin shall have a signed agreement with all subcntractrs that transfrm, prcess, r repack certified prducts r any material that may be used as ingredients fr certified prducts, which cvers the fllwing pints: The subcntractr shall have systems in place t ensure traceability, segregatin, and identificatin f certified prducts r any material that may be used as ingredients fr certified prducts at every stage f handling; and The subcntractr will allw the MSC, the CAB, and the MSC s accreditatin bdy t have access t the premises and any recrds related t certified prducts r any material that may be used as ingredients fr certified prducts upn request Organisatins that use cntract prcessrs r perfrm cntract prcessing f certified prducts r any material that may be used as ingredients fr certified prducts shall maintain recrds f all such cntract-prcessed ingredients r certified prducts, including: Weight and prduct details received; Weight and prduct details dispatched; Dates f dispatch and receipt. Cnsultatin Dcument Mass Balance CC Standard 14

15 Certified cntract prcessrs shall recrd the name and CC cde fr all certificate hlders fr whm cntract prcessing f certified prducts r material that may be used as ingredients fr certified prducts has been prvided since the previus audit Requests fr traceability and supply chain assurance The rganisatin shall cperate with all MSC and CAB requests fr chain f custdy infrmatin r purchase recrds fr marine-surced ingredients r sales recrds fr certified marine-surced prducts Dcuments shall be prvided within 10 days f request Organisatins shall allw the MSC, the CAB r a representative frm the accreditatin bdy t cllect samples f marine-surced ingredients r certified marine-surced prducts frm their site fr the purpses f DNA r ther prduct authenticatin testing Where a prduct authenticatin test identifies the marine-surced ingredient r a certified marine-surced prduct as a differing frm the specificatins cvered by the scpe f its Chain f Custdy certificatin the rganisatin shall: Investigate the ptential surce f the issue Present the CAB with findings frm this investigatin and, where nn- cnfrmities are fund, a crrective actin plan t address these. Cperate with further sampling and investigatin. Cnsultatin Dcument Mass Balance CC Standard 15

16 168 Appendices Appendix A: Exclusin f Material Assciated with IUU Fishing A.1. Guidance n MSC Surcing Requirements in relatin t IUU Fishing MSC requires that the rganisatin implements measures t avid the use f material surced frm IUU fishing. This refers t material surced frm: vessels listed n Reginal Fisheries Management Organisatins (RFMO) blacklists. A cnslidated list f such IUU-identified vessels is maintained at A.2. Chain f Custdy Requirements All ingredients supplied t the rganisatin that cntain marine-surced material must be cvered by a chain f custdy certificate which prvides a credible guarantee that the ingredient excludes any material frm the surces listed in Appendix A1. A range f appraches are cnsidered t prvide an acceptable guarantee that such material has been excluded frm its ingredients: The ingredient culd be surced directly frm and be cvered by a certificate issued t a fishery that is certified t a prductin standard that ensures that the specified unacceptable surces have been excluded. The ingredient culd be surced frm and be cvered by a chain f custdy certificate issued t a prcessr r ther supplier whse wn surces are certified as excluding any material frm the specified unacceptable surces. The ingredient culd be surced frm a fishery r ther supplier and be cvered by a chain f custdy certificate that guarantees that any material supplied has been subject t a risk assessment, and that there is an acceptably lw risk that the ingredient cntains any material frm the specified unacceptable surces. Any cmbinatin f the abve. A.3. Chain f Custdy Certificates that MSC Recgnises as Meeting the Requirements f Appendix A1 and A2. MSC currently recgnises material cvered by the fllwing chain f custdy certificates (r equivalent) as meeting the requirements specified in Appendices A.1 and A.2: Material cvered by an IFFO RS Factry certificate Material cvered by an IFFO RS Chain f Custdy certificate Material cvered by an MSC Chain f Custdy certificate NOTE: This list is fr illustrative purpses nly at this stage f drafting. MSC will review and cnfirm which existing CC r similar schemes currently prvide a credible guarantee that material frm the specified unacceptable surces has been excluded frm the supplied ingredients. If a supplier surces material that is cvered by a chain f custdy certificate that is nt n this list, the supplier may encurage the relevant scheme wner t apply t MSC fr recgnitin f certificates issued under the scheme. Appendix B: Scpe Specific Guidance fr the Applicatin f the MSC Mass Balance Standard fr Fish Feed Manufacture B.1. MSC Mass Balance Recgnised Marine Material fr Aquaculture Feed Cnsultatin Dcument Mass Balance CC Standard 16

17 The requirements fr marine material that is recgnised as an input fr the MSC Mass Balance calculatin when applied t the manufacture f fish feed are defined in the ASC Feed Standard. The ASC Feed Standard recgnises marine material at fur different levels f sustainability. The ASC Feed Standard specifies its wn requirements requiring that the amunt f marine material at each f these levels increases ver time twards higher levels f sustainability. Thus, the ASC Feed Standard requires that rganisatins recrd and reprt the amunt f material they surce frm surces at each f these fur levels f sustainability. Hwever, material at all fur levels is cnsidered t be MSC Mass Balance Recgnised Material, and s fr the purpses f the Mass Balance calculatin the rganisatin needs t reprt nly the ttal amunt f material at all fur levels in cmbinatin, and nt the amunt f material at each separate sustainability level. B.2. Requirements fr Chain f Custdy Certificatin f MSC Mass Balance Recgnised Marine Material fr Aquaculture Feed 1. In rder t be recgnised by MSC as an acceptable chain f custdy certificate fr the identificatin f MSC Mass Balance Recgnised Marine Material fr Aquaculture Feed, the certificate must be issued under a scheme that meets the fllwing requirements: 1.1 The applicable standards fr the scheme (including all relevant surce, chain f custdy, and/r risk assessment standards) must be available t the public fr dwnlad frm the internet at n cst. 1.2 The scheme must be perated: EITHER: exclusively by certificatin bdies that are accredited by an IAF-member Natinal Accreditatin Bdy as perating the scheme in cmpliance with the requirements f ISO OR: exclusively by ISEAL Member rganisatins within the scpe f their ISEAL member prgramme. 1.3 MSC and/r its agents must have full access t any reprts prduced by the scheme r its agents that are relevant t the demnstratin f the certificate hlder s cmpliance with the scheme s requirements. 1.4 The scheme must have been assessed by MSC as meeting the requirements f Appendix A and Appendix B f this Standard, as applicable. 1.5 The scheme must have paid any applicable fees t cver the csts f such MSC assessment. 2. In additin, in rder fr a certificate issued under the scheme t be recgnised by MSC the scheme must require that hlders f this certificate type: Must be able t demnstrate that all f their supplies f marine ingredients are frm surces that cmply with the requirements specified in Appendix A.1 Must keep recrds f all the marine-surced material supplied t them fr the previus three years, which includes: The name, address and cntact details f the supplier A detailed specificatin f the material supplied The date and quantity f material supplied Cnsultatin Dcument Mass Balance CC Standard 17

18 Must peridically take and keep representative samples f all f their supplies f marine ingredients and finished prducts, in line with applicable Gd Manufacturing Practice (GMP) standards. Samples shall be: Preserved and prtected against destructin (rdents, insects, etc.), deteriratin (misture, muld, etc.) r adulteratin (e.g. in a chest freezer). Kept fr a minimum f three years. In the case f material supplied frm a fishing vessel, must keep recrds that include: Name f vessel, registratin number, call sign, legal wner, name and address. Prf f authrisatin t engage in the specific fishing activity. Time f discharge t facility. Species and quantity discharged. Lcatin r place(s) and dates f fishing activity where catch riginated. NOTE: Lcatin descriptin shuld be standardised, fllwing FAO-defined fishing areas. Fishing methd used. Must specify n the prduct and/r in accmpanying dcumentatin that can be linked t a specific delivery f the prduct, fr every cnsignment f its prduct that is sld as being cvered by an MSC-recgnised chain f custdy certificate: The prprtin f the prduct that is frm surces certified as meeting the requirements fr MSC Mass Balance Recgnised Material as specified in Appendix B1. B.3. List f Certificatin Schemes Currently Recgnised as meeting Chain f Custdy Requirements fr MSC Mass Balance Recgnised Marine Material fr Aquaculture Feed At present n schemes are frmally recgnised by MSC as meeting the requirements specified in Appendices B.1 and B.2. It is expected that in future IFFO RS Factry, IFFO RS Chain f Custdy and MSC Chain f Custdy schemes will be mdified s that they meet the specified requirements Appendix C: MSC Recgnitin f Chain f Custdy Certificatin Schemes T be develped Cnsultatin Dcument Mass Balance CC Standard 18