Licensing Licensing procedure for use of the Seafood from Norway country of origin mark outside Norway
Contents Introduction... 2 How to get a license... 3 License agreement... 4 Third party audit control... 5 Page 1 of 7
Introduction Companies processing Norwegian seafood outside of Norway have to apply for a license in order to get at right to use the country of origin mark, Seafood from Norway. Licensing is a requirement to ensure the value of the joint investments by the Norwegian seafood industry, to ensure only Norwegian seafood is labeled as Seafood from Norway. If your company have partners or own processing facilities outside of Norway, you can get a license to use the Seafood from Norway mark of origin on your products. This brochure summarizes the process to get a license. If you have any other questions, please contact us using license@seafood.no or +47 77 60 33 33. What is the value of using the Seafood from Norway mark of origin? The trademark Seafood from Norway is a symbol of origin quality for all Norwegian seafood, sustainably farmed or wild caught in our cold, clear waters. With the new trademark we want to portray what is unique about Norway, give associations to the rough climate nature in which our seafood is raised. Licensing enables companies outside of Norway to benefit from marketing investments made by the Norwegian Seafood Council (NSC) on behalf of Norwegian seafood. Page 2 of 7
How to get a license In order to use the Seafood from Norway mark of origin outside of Norway you have to enter into a license agreement. Step 1: License Application In the application, you are asked to provide general information about your company Norwegian seafood products intended to be labelled with the mark of origin. In the application, you are also asked to confirm whether your company complies with any certified management systems. Step 2: Exporter Declaration The declaration is to be signed by the Norwegian exporter(s) from whom you are buying Norwegian seafood. The purpose of the declaration is to confirm the value chain from the Norwegian exporter to the production facility outside Norway. Step 3: License Agreement Based on the license application exporter declaration, you will be forwarded a license agreement, to be signed returned to the NSC. Product labelling After signing the license agreement, all product packaging with the mark of origin shall be presented accepted by NSC in writing prior to commercial use. The mark of origin shall always be used together with the licensee's own trademark. Listed on seafood.no When the license agreement is in force, your company s right to use the mark of origin will be listed on www.seafood.no. Page 3 of 7
License agreement Below is a summary of the most important provisions included in the license agreement. For further details, please contact the NSC. The licensee guarantees That it will comply with any legal requirements applicable for its business in the country of operation, that it has necessary certificate(s) issued by the relevant national authority, which allows the licensee to produce /or import seafood. What is Norwegian seafood, what type of products can be labeled with the mark of origin? The mark of origin can only be used on products where Norwegian Seafood is the main ingredient. Products that contain, or are mixed with seafood of other territorial origin than Norway, will not be accepted. "Norwegian seafood" means seafood which originates from fish or other marine products as defined in art. 1 of the Norwegian Fish Export Act No 9 of 27 April 1990, which naturally inhabits the seawaters or freshwaters of Norway, is caught or farmed in compliance with Norwegian sectorial regulations, led on Norwegian l territory. Tracking systems, inspections audits Companies wanting the right to use the mark of origin must confirm that they have a tracking system in which can trace document products sold under the Seafood from Norway origin mark. The license holder s tracking system shall be documented, reliable verifiable. At least once a year, license holders must report to the NSC on their usage of the mark of origin. Additionally, the NSC will annually request third party audit of selected manufacturers. If the NSC has reason to believe that a company is in non-compliance with agreed terms, the NSC may at any time request a separate third party audit. Freedom of movement Products labeled under the license agreement can be exported sold within a customs union. This means that products can be exported between countries provided the countries are within the same customs union. If the country in which your facility is located is not part of a customs union, it will not be possible to export labeled products out of the country you are manufacturing in. Examples of customs unions are EU, Mercosur (Argentina, Brazil, Paraguay Uruguay) the Eurasian Economic Union (Russia, Belarus, Kazakhstan, Armenia Kyrgyzstan). Page 4 of 7
Criteria The mark of origin can only be used on/in connection with Norwegian Seafood products which are imported or bought from registered exporters of Norwegian Seafood, which may furnish export declarations /or Norwegian catch certificates. Duration of the license agreement The duration of the license agreement is three years. Thereafter the agreement can be prolonged by subsequent three year periods, unless earlier terminated by either party. The duration may be subject to adjustments depending on markets /or species. The NSC is the owner of the Seafood from Norway country of origin mark oversees the administration use of the mark. Conditions for licensing may be subject to change. Third party audit control The following is a summary of questions that a third party auditor may ask during the audit. Certified management systems Is the company certified against any of these stards? - Global Food Safety Initiative (GFSI)? - Marine Stewardship Council (MSC) chain of custody or Aquaculture Stewardship Council (ASC) chain of custody (MSC CoC or ASC CoC)? - Global G.A.P. Chain of Custody (Global G.A.P Coc) Identification tracking - Does the company have a list of suppliers of Norwegian seafood? - How are the Norwegian products identified registered when they arrive at the production facility? How is it recorded: Dates, quantities, species, name of supplier, batch number, barcode, storage destination, etc.? - How is the tracking maintained during production, how can the company document Norwegian origin for the products at every stage of the production process? - Can documentation be presented for all batches with Seafood from Norway -labeled seafood sold - including product name, species, weight customers? - Can the company document what type of raw material used for manufacturing of a finished product (See figure 1 traceability test)? Page 5 of 7
Figure 1: Traceability test. Input LOT/Batch ID Date (packing /or date of arrival) Physical Labelling of product (internally) Entry batch ID in own system (manual or electronic) responsible for ID? Storage Continued information flow from Input control Maintenance of ID with same or new ID code responsible for ID? Processing Continued information flow from Input control Maintenance of ID with same or new ID code Registration of batches entering processing Different IDs for different product types? responsible for ID? Quality quantity control Continued information flow from processing Maintenance of ID with same or new ID code Input output quantity control (mass balance) responsible for ID? Packing/ dispatch Continued information flow from quality control Maintenance of ID with same or new ID code Control of NORGE-label against ID responsible for ID? Separation - How does the company ensure Norwegian seafood is not mixed with non-norwegian seafood in your company? - How does the company ensure the mark of origin is used on Norwegian seafood products only? - In cases of similar fish species, or products, are they clearly labelled separated? If yes, how are these species /or products separated by production line or time? Production yield (Mass Balance Control) verification - Can you demonstrate that you can determine how raw material has been used in what quantities (input output reconciliation)? A calculation like this can be compared with making a balance sheet, where the sum of the fish entering the process (whole fish with head for instance) is equal to the fish leaving the process (Fillets, head, skin, trimmings, bones). These types of calculations ensure that you avoid nonconformities in terms of Norwegian seafood in the end-product. - Does the company have a list of the products in stock, with identification quantities? Training - Within your company, are responsibilities defined known regarding the traceability labelling of Norwegian seafood, is it documented that it is understood applied by the staff? - Have your employees received training in HACCP principles? If yes, how can you document it? Page 6 of 7
Record maintenance - Does the company have documents showing all products sold with the mark of origin can be tracked to a batch/delivery of Norwegian seafood? This can be batch number, catch certificate, invoice, etc. - Can the company document conversion factors used in reconciliation of supply produced goods? - For how long are such documents stored? (The requirement is set to three years). Traceability test input-output reconciliation - During an audit, the lead auditor will undertake a traceability test (Figure 1). In a traceability test, the auditor may look at your records to follow a product from goodsin to goods out (or vice versa). - Figure 1 shows a simplified production process of seafood, the critical check points that must be documented. In addition, it will be controlled how labeled seafood is being separated from other seafood. Nonconformity management The lead auditor will verify that the company has defined a limit level for when nonconformities shall be reported, that it exists a procedure for hling them. The procedure must consist of a method that can rectify close nonconformities as soon as they are identified, e.g. if input-output reconciliation has a nonconformity of more than five percent. The procedure should include: (1) A method to identify the nonconformity or the reason for it, (2) A timeline showing when the correcting actions shall be implemented, (3) A process for verification of the efficiency of the correcting actions (4) A description of the responsible person for carrying out the procedure. Audit costs duration Every year the NSC will request third party audits of selected manufacturers, costs of which will be borne by NSC. Only in cases where non-compliance is established, will NSC dem compensation for costs incurred in connection with the audit. A third party audit will usually take half to one a half day. Amongst others, the duration of the audit will depend on the complexity of the production number of species/products that will be marked with the mark of origin. Page 7 of 7