IFFO RS / MSC Standards Comparison Project

IFFO RS / MSC Standards Comparison Project A comparison of the IFFO (The Marine Ingredients Organisation) RS Standard and Marine Stewardship Council Principles and Criteria for certification of feed used in aquaculture. Beatriz Méndez On behalf of The Marine Conservation Society April 2014 1

Table of Contents 0. Introduction... 3 1. Standards Overview... 4 1.1 Marine Stewardship Council (MSC)... 4 1.2 IFFO RS... 4 2. Unit of certification... 5 2.1 MSC... 5 2.2 IFFO RS... 5 3. Governance... 6 3.1 MSC... 6 3.2 IFFO RS... 6 4. Criteria for certification... 7 4.1 MSC... 7 4.2 IFFO RS... 8 4.3 IFFO IP (Improvers Programme)... 9 5. Chain of custody... 10 5.1 MSC... 10 5.2 IFFO RS... 11 6. Timeline for review and consultation process... 12 6.1 MSC... 12 6.2 IFFO RS... 12 7. Accounting for the ecological importance of forage species... 13 7.1 MSC Low Trophic Level (LTL) Requirements... 13 7.2 IFFO RS... 16 8. Summary... 17 9. Summary table... 18 10. References... 22 2

0. Introduction The continuing development of the global aquaculture industry and the supporting fishmeal and fish oil markets has created a need for industry to demonstrate its commitment to the responsible sourcing of raw materials and the safe production of ingredients for aquaculture, agriculture and directly in the production of consumer products. There is also concern over the long term sustainability of global fisheries, including fisheries that supply fishmeal and fish oil to aquaculture. With regard to marine proteins and oils used in aquaculture there are two main certification standards for sustainable and responsible supply; The Marine Stewardship Council (MSC) and the IFFO Global Standard for Responsible Supply (IFFO RS), which is the focus of this comparison report. The MSC (Marine Stewardship Council) runs a consumer facing eco-label fisheries program, working with partners to transform the world s seafood markets and promote sustainable fishing practices. It has developed standards for sustainable fishing practices and seafood traceability. This standard was the first one of its kind and is the most widely recognised standard covering fisheries, although at present there are only very small volumes of wholefish from MSC certified fisheries being made available for fishmeal and fish oil production. The standard when combined with the Chain of Custody standard is designed to permit the final vendor to label individual fish products as sustainable. The IFFO RS mission is to assist marine ingredient producers to demonstrate to stakeholders their commitment to responsible practices in the areas of raw material procurement and feed safety. In order to achieve this, IFFO, via its Technical Advisory Committee developed a Global Standard and Certification Programme for the Responsible Supply of fishmeal and fish oil (IFFO RS). It is a business to business standard covering responsible raw material sourcing and good manufacturing practice. The IFFO RS achieved ISO65 accreditation through its Certification Body in September 2012. 3

1. Standards Overview 1.1 Marine Stewardship Council (MSC) MSC is based upon a set of Principles and Criteria for sustainable fishing (MSC_Fishery_Standard_v1.1.pdf 1)[1]used as a standard in a third party, independent and voluntary certification programme. These were developed by means of an extensive, international consultative process through which the views of stakeholders in fisheries were gathered. According to the defined Principles, a sustainable fishery should be based upon: The maintenance and re-establishment of healthy populations of targeted species; The maintenance of the integrity of ecosystems; The maintenance and development of effective fisheries management systems that include all relevant biological, technological, economic, social, environmental and commercial aspects; Compliance with relevant local and national local laws and standards and international understandings and agreements. These Principles are designed to recognise that management efforts are most likely to be successful in accomplishing the goals of conservation and sustainable use of marine resources when there is a full co-operation among the full range of fisheries stakeholders, including those who are dependent on fishing for their food and livelihood. 1.2 IFFO RS The Marine Ingredients Organization (IFFO) has developed a Global Standard and Certification Programme for the responsible supply of fishmeal and fish oil (IFFO-RS-Standard-Issue-1-5- Eng.pdf2)[2]which defines the requirements for certification and the criteria for the sourcing and manufacturing of fishmeal and fish oil. This document is focused on the responsible sourcing, production and traceability of material that is legal, safe and fished responsibly. 1[1] http://www.msc.org/documents/scheme-documents/mscstandards/msc_environmental_standard_for_sustainable_fishing.pdf/view. 2[2] http://www.iffo.net/iffo-rs-standard 4

The RS Standard is based upon the following objectives To ensure that whole fish used must come from fisheries managed according to the FAO Code of conduct for responsible fisheries. To ensure no Illegal, Unreported and Unregulated (IUU) fishery raw materials are used. To ensure pure and safe products are produced under a recognised quality management system, thereby demonstrating freedom from potentially unsafe and illegal materials. To ensure full traceability throughout production and the supply chain. 2. Unit of certification The unit of certification refers to the product or service being certified, the two standards are compared below. 2.1 MSC The scope of the MSC Principles and Criteria relates to marine fisheries activities up to, but not beyond the point at which the fish are landed. However, MSC-accredited certifiers may be informed of serious concerns associated with post-landing practices. Issues involving allocation of quotas and access to marine resources are considered to be beyond the scope of these Principles and Criteria. The Principles and Criteria apply only to wild-capture fisheries (including, but not limited to shellfish, crustaceans and cephalopods). Aquaculture and the harvest of other species are not included. The Aquaculture Stewardship Council (ASC) which is the sister standard to the MSC standard, covers farmed fish and crustacean. In contrast to the global Principles of the MSC, each different species group within ASC has its own standard, some of which are being finalised at the time of writing this report. Currently all the different standards have a longterm requirement for marine ingredients to come from MSC certified fisheries, but in the interim some of the ASC species standards recognise IFFO RS. 2.2 IFFO RS The unit of certification for the IFFO RS standard is the fishmeal factory. A key standard requirement is that the factory must be able to demonstrate full traceability of RS compliant product throughout the production process right up to the factory gate, and back to an approved raw material source. However, from this despatch point the supply chain for IFFO RS certified fishmeal and fish oil can be complex with many links resulting in a long and sometimes complicated distribution chain. This then runs the potential risk of the certified fishmeal and fish oil being mixed with non-certified material. 5

To ensure the IFFO RS fishmeal and fish oil identity is protected and to ensure certified product reaches the end user, the IFFO RS Technical Advisory Committee has developed a Chain of Custody standard.3[3] 3. Governance 3.1 MSC The MSC is an International non-profit organisation committed to the values of independence, transparency, impartiality and stakeholder participation. They uphold these values through their governance structure, credibility and by encouraging people to get involved. The MSC is governed by a Board of Trustees that it is advised by a Technical Advisory Board and the Stakeholder Council. MSC staff carries out the work of the MSC offices and report to the Board of Trustees. The head office is in London and also serves as the regional office for Europe, the Middle East and Africa. They have two further regional offices serving the Americas and Asia Pacific. MSC Local Offices around the world provide additional local support. The participation of others is crucial to the transparency and credibility of the MSC. Their structure involves a wide range of stakeholders with different views. The Board of Trustees, Technical Advisory Board and Stakeholder Council include representatives from industry, environmental groups and science and from different geographical regions. 3.2 IFFO RS In 2014 the multi-stakeholder Technical Advisory Committee for the standard became the IFFO RS Governing Board and its remit is the continuous development and application of the Standard. This Board comprises representatives of fishmeal and fish oil producers, traders, fish feed producers, fish farmers, fish processors, retailers, environmental NGOs and the IFFO Technical Director. 3[3] http://www.iffo.net/iffo-rs-coc-standard 6

4. Criteria for certification 4.1 MSC MSC have a mission to adhere to global best practice and are a science based metric driven standard. MSC is also consistent with all of the following international norms: The Code of Conduct for Responsible Fishing (UN FAO) Guidelines for the Ecolabelling of Fish and Fishery Products from Marine Capture Fisheries (UN FAO) The Code of Good Practice for Setting Social and Environmental Standards (ISEAL) World Trade Organisation Technical Barriers to Trade Agreement As a standard setter, MSC are also fully compliant with the ISO 17065: Requirements for bodies certifying products, processes and services. The following Principles represent the overarching philosophical basis for this initiative in stewardship of marine resources. They form the basis for detailed criteria which will be used to evaluate each fishery seeking certification under the MSC programme. The three Principles that form the MSC standard are: PRINCIPLE 1: Sustainable fish stocks. A fishery must be conducted in a manner that does not lead to over-fishing or depletion of the exploited populations and, for those populations that are depleted (but are still above a limit reference point) the fishery must be conducted in a manner that demonstrably leads to their recovery. PRINCIPLE 2: Minimising environmental impact. Fishing operations should allow for the maintenance of the structure, productivity, function and diversity of the ecosystem (including habitat and associated dependent and ecologically related species) on which the fishery depends. PRINCIPLE 3: Effective management. The fishery is subject to an effective management system that respects local, national and international laws and standards and incorporates institutional and operational frameworks that require use of the resource to be responsible and sustainable. 7

4.2 IFFO RS IFFO recognises the importance of responsible sourcing, responsible production and responsible supply practices. Many of its members have already implemented third party assurances such as ISO 9000, HACCP systems and feed ingredient assurance programs. The IFFO RS Certification Program is designed to build upon each of these positive developments and allow members visibly to demonstrate their commitment to good practice. A third party inspection and certification program has been established to ensure the integrity and transparency of its implementation. The Certification Program which has been designed to allow certification to meet the requirements of the ISO/IEC Guide 65:1996 - General requirements for bodies operating product certification programs, has obtained ISO 65 accreditation. A unique Certification Mark IFFO Assured has been developed which can be used to signify compliance to the IFFO Standard. ISO65 accreditation has been adopted by the majority of standards owners as a consistent and transparent way of operating certification schemes. It is also frequent requirement of the major retailers to demonstrate a well-managed standard. There are a number of key eligibility criteria that applicants must achieve to be certified: Be members of IFFO or a full member of a producer organisation that is a member of IFFO. Be compliant with the rights and duties of IFFO membership. For responsible sourcing Demonstrate commitment to sourcing fishery material from legal, reported and regulated fisheries that comply with the key requirements of the FAO Code of conduct for responsible fisheries. However the standard for responsible sourcing does not take into account the ecological importance or forage species and their role in maintaining food web stability, and it is only MSC certified species that are automatically approved for IFFO RS use that includes this consideration. For responsible traceability Demonstrate through traceability that only approved fisheries are used in the manufacture of IFFO compliant fishmeal and fish oil and demonstrate the avoidance of IUU fishery material from their supply. For responsible manufacturing Have attained certification to the International Feed Ingredients Standard (IFIS) of the International Feed Safety Alliance (IFSA) or an equivalent, as proof of responsible manufacturing and; 8

Be in possession of all relevant permits and licenses for the production and sale of fishmeal and fish oil products. 4.3 IFFO IP (Improvers Programme) The IFFO RS Technical Advisory Committee (TAC) have become aware that, despite the early success of the RS standard, a large number of factories are currently unable to meet the standard, either because of issues within the factory or because of problems with the raw material sourcing and the associated fisheries. Many of these factories are in areas where aquaculture is growing strongly, but fisheries management is poor, particularly in Asia. This means local fish feed companies and fish farming companies that wish to demonstrate responsible sourcing by using only IFFO RS compliant aquatic raw materials would have to import such products, hence adding cost and also impoverishing the local economy. In order to encourage factories that at present would struggle to meet the RS standard (whether because of a lack of fisheries management or factory infrastructure and systems), to implement improvements leading to eventual compliance an organised programme, providing a pathway to full certification was developed the IFFO RS Improvement Programme (IP) An applicant for adoption onto the IP must be a named factory producing fishmeal and fish oil. The factory shall produce two key documents to be accepted formally onto the IP: 1. A Gap Analysis Study identifying where the factory and its raw material fail to meet the RS standard 2. An Action Plan which identifies how any shortcomings will be addressed, who is responsible for their completion, and in what timescale. Both these documents shall address the two areas which comprise the RS standard: responsible raw material procurement and responsible production. The steps required to be undertaken for a non-compliant factory wishing to be part of the IP are: Phase 1: Initial Assessment - Gap Analysis study identifies improvements required to both factory and the raw material. - Based on this IFFO advises applicant on suitability for adoption onto the IP. - If both parties agree that a workable Action Plan might be achievable the applicant moves to Phase 2. 9

Phase 2: Formulation & Implementation of Action Plan Stakeholder Committee produces a Fisheries Improvement Programme. The applicant and IFFO produce a Factory Improvement Programme. The applicant and the Stakeholder Committee agree to implement the Action Plan. The factory then accepted onto the Improvers Programme. Certification Body audits the Action Plan progress. Phase 3: Certification of Factory At the end of the Action Plan the factory can then apply for the RS. Independent certification Body audits the factory for RS. If desired an approved fishery might then seek to become certified under the MSC standard for sustainable fisheries. 5. Chain of custody 5.1 MSC Before the MSC ecolabel can be used on seafood or any claim about the MSC can be made, an assessment must take place at each step in the chain that confirms the product originates from a fishery certified to the MSC s Principles and Criteria for sustainable fishing. Certified chain of custody systems are an essential component of any product labelling programme, providing credible assurance that traceability of fish products through supply chains is maintained. To achieve this, companies in each relevant supply chain are subject to certification against the MSC Chain of Custody standard for seafood traceability. Principles that form the MSC Chain of Custody Standard are: 1. The organisation shall have a management system 2. The organisation shall operate a traceability system 3. There shall be no substitution of certified products with non-certified products 4. There shall be a system to ensure all certified products are identified. To get Chain of Custody certification, businesses must be audited to show they have effective traceability, storage and record-keeping systems which prove that only seafood from a certified fishery carries the MSC ecolabel. The Aquaculture Stewardship Council (ASC) uses the MSC Chain of Custody requirements to assure the traceability of ASC-certified aquaculture products through their supply chains. Although this is an important collaboration, the ASC remains a separate organisation that will use a different ecolabel. 10

5.2 IFFO RS To ensure the IFFO RS fishmeal and fish oil identity is protected and to reassure users of fishmeal and fish oil, the IFFO RS Governing Board has developed a Chain of Custody Standard. This standard is based on the requirements of the FAO Eco-labelling requirements version 2005 and updates in 2009. The purpose of this standard is to provide marine ingredient users with a recognised standard, which they can use to demonstrate that the ingredients that they are sourcing come from responsible managed factories and supply-chains. An applicant must be able to demonstrate that IFFO RS products are segregated from non- IFFO RS products and that traceability can be maintained at all times throughout the distribution. To achieve this, a full product traceability system is required so products can be traced from their suppliers and tracked to their point of use or onward sale. The RS Chain of Custody Standard provides a means for suppliers to demonstrate and claim that their products originate from a certified IFFO Responsible Supply factory and in turn gives reassurance to fishmeal and fish oil users that the products they are buying are produced from responsible sourced raw materials and manufactured to produce safe and pure products. This specification details the set of requirements that must be certified as being in place to ensure that the fishmeal and fish oil product put on the market and bearing the IFFO RS logo is really a product of designated origin and coming from the certified factory concerned. These measures thus cover both the tracking/traceability of the product all along the processing, distribution and marketing chain, as well as the proper tracking of the documentation and control of the quantity concerned. The general Principles of traceability for Chain of Custody are: 1. Applicant must have a documented policy that states that they are committed to achieving and adhering to the requirements of the Chain of Custody Standard. 2. Fishmeal and fish oil products must not carry the official certified label to indicate that they originate from a Certified RS factory unless they have been certified as meeting the Chain of Custody Standard. 3. All fishmeal and fish oil products carrying the official label from Certified RS factories must be kept readily identifiable and where necessary kept clearly separated from products of non-certified factories at all times. 4. Traceability systems must be in place that are able to identify the certified labelled fishmeal and fish oil products and trace those products back to the Certified RS factory from where they were derived. 5. Approved and authorized identification code, where appropriate, must be in place for each link in the supply chain from the Certified RS factory through to the customer. 6. All stages in the value supply chain, including secondary processors or other buyers must comply with the applicable national/federal and/or regional/state regulations on labelling and traceability. 11

7. The applicant must have a system in place to ensure that purchased fishmeal and fish oil products carrying the official certified label are not mixed with non-certified fishmeal and fish oil products during transportation to and from the site and in third party storage, if applicable. 6. Timeline for review and consultation process 6.1 MSC The standards are maintained by the MSC Technical Advisory Board subject to continual review. Since the introduction of the default tree in 2008, the standard has been reviewed annually. During 2013-2014, the MSC undertook a review of its sustainable fisheries standard to be consistent with the MSC s commitment to best practice for ecolabelling and certification as set out by the FAO and ISEAL. With the release of the latest criteria there will now be official review every 5 years in which stakeholder consultation is central. To ensure the review process is inclusive and transparent, the MSC completed a series of consultations that encompassed the views of industry, NGOs, governments and scientists from all around the world. The review ensures the MSC program remains fit for purpose. The fisheries standard will consolidate the MSC s existing policy development process on issues pertaining to the Default Assessment Tree and other fishery client performance requirements. In addition, the MSC will undertake a Speed and Cost Review in parallel to the Standard, to review and reform the assessment process. 6.2 IFFO RS The Certification Program has been designed to allow certification to meet the requirements of the ISO/IEC Guide 65:1996 General requirements for bodies operating product certification programs. Through the program framework, the requirements for Certification of Responsible Supply will be subject to continual review and improvement to ensure that it continues to serve IFFO member and stakeholder needs in the provision of safe, responsibly sourced fishmeal and fish oil for the International market. 12

7. Accounting for the ecological importance of forage species The ecological importance of Low-trophic level (LTL) species, also referred to as forage fish species and the control they can exert on the rest of the food web has been well established (e.g. Cury et al, 2000 4 ). However, even though the scientific knowledge of the importance of forage species has been accumulating, the response from fisheries managers to account for this has been lacking, largely due to the lack of reliable tools and methods of implementation. Recently, a new global approach and an attempt to better quantify impacts of removing forage species for a vast variety of systems was presented in the seminal paper by Smith et al, 2011 5 The results from this paper not only clearly highlighted the role forage species can play in maintaining ecosystem stability for some systems, acting as the principal means by which energy gets transferred from primary production to large predatory fish, mammals and seabirds, but also for the first time provided guidelines for managers as to what a sustainable harvest strategy should be for these types of organisms to ensure that impacts on the wider ecosystem are minimized. The following year, a group called the Lenfest forage fish taskforce, a panel of thirteen preeminent marine and fisheries scientists from around the world, published a comprehensive examination of the science and management of forage fish populations in the report Little Fish, Big Impact. (Pikitch, et al, 2012 6 ). The primary purpose of this publication was to provide practical, science-based advice for the management of forage fish and how to better recognize their crucial role in marine ecosystems. 7.1 MSC Low Trophic Level (LTL) Requirements As the global best practice on how to harvest forage species was rapidly changing, the Marine Stewardship Council (MSC) decided to incorporate these latest scientific guidelines within the MSC standard for sustainable seafood and in August 2011 provided clarifications to its default assessment tree and guidance and how it relates to fisheries targeting Low Trophic Level (LTL) species. The intent of these new requirements on LTL fisheries focused on limiting the ecosystem impacts of fisheries management on these important species. A principal distinction within the requirements is the designation between what MSC deem to be KEY LTL species as separate from non-key LTL species. The intent is that all forage (LTL) species need to be assessed against their potential ecosystem importance, principally 4 Cury, P., Bakun, A., Crawford, R. J. M., Jarre, A., Quin ones, R. A., Shannon, L. J.,and Verheye, H. M. 2000. Small pelagics in upwelling systems: patterns of interaction and structural changes in wasp-waist ecosystems. ICES Journal of Marine Science, 57: 603 618. 5 Smith, A.D.M., Brown, C.J., Bulman, C.M., et al. 2011. Impacts of fishing low-trophic level species on marine ecosystems. Science 333, 1147 1150. 13

relating to their role in energy transfer, when applying for certification according to the MSC standard. There are three indicators which are used to identify whether or not an LTL stock is Key, these are based on the connectance of the species to other organisms within the system, the proportion of energy of that gets channelled through the species and finally whether the system is wasp-waisted following the definition in Curry et al (2000). Essentially, if it is evident that a species is highly connected in the food web and found in the diets of many predators it will likely be a Key LTL species. If there is no evidence to show that any one criteria is not met, it would by default be considered met. The first two indicators are based on results from Smith et al, 2011 and the thresholds used relate directly to an ecosystem level of impact that the depletion of any given LTL species will have. If a species is determined to be KEY, the removal of this species beyond defined precautionary reference points will cause a cascade effect in the system and other predators dependent on the LTL species as food will likely see a decrease of up to 60% in their abundance. Based again on the Smith et al paper, the default precautionary reference points which should be adhered to by management of a KEY species in order to not negatively affect the ecosystem, is to either maintain 75% of the virgin biomass in the system or to have a harvest strategy with a target of 0.5 of FMSY or 0.5 of M (natural mortality of the species). If there is sufficient understanding of the system, these default reference points can be adjusted to a specific case, if shown to not have adverse ecosystem effects through the use of credible ecosystem models. If an LTL species is not KEY, it is assumed that the impacts of removing it are not of extraordinary importance, defined as no species abundance in the system being affected by more than 20%. It can therefore be assessed as a regular species within the MSC system and evaluated against the standard and robust MSY levels of biomass and fishing mortality. The requirements have undergone revision since their original release, which include the development of a more robust index to complement the connectance criterion, called the SURF index (Essington and Plagànyi, 2013). The Certification Requirements (CR) were also calibrated in terms of the three indicators used to determine KEY status to confirm that only those fisheries that are genuinely at a high risk of causing unacceptable ecosystem impacts are correctly classified in the key LTL group. This work also aimed to extend the guidance originally provided on the use of ecosystem models and empirical information for both identifying key LTL species and scoring their impacts. When the LTL requirements were first drafted, there were concerns that the normal precaution levels built into MSC s Risk Based Framework (RBF) for data deficient fisheries might be insufficient for evaluating fisheries against stock status requirements in LTL fisheries. Analyses conducted since then have shown that the RBF is sufficiently precautionary to apply to key LTL stocks as well as normal stocks even when data-deficient in relation to stock status and reference points 14

Following public consultation stages, the MSC s Technical Advisory Board (TAB) and the Board of Trustees approved all of these above revisions to the Low Trophic Level (LTL) requirements for CR v1.3 in 2013. The core purpose behind the changes was to increase accessibility of the MSC to fisheries targeting LTL stocks, without compromising the ecological stability of marine ecosystems. To further complement this direction, additional guidance has been developed to assist CABs (Conformity Assessment Bodies) in generating plausible arguments on the status of fisheries. In short, fisheries with landings >50 000 t/year, averaged over a 5 year period, will generally not be considered key-ltl and a system shall not be considered wasp-waisted if the catches of the candidate LTL stock are less than those of the combined total of other species at the same trophic level. There is no specific RBF-type methodology for determining whether a particular LTL stock is a key LTL stock. Instead, the requirement for determination of key LTL status has been made more qualitative for all types of fisheries. Nevertheless, some basic understanding of the ecosystem structure and trophic levels of different species will still be required in all fisheries; even to apply these simplified guidance options. In parallel with this work, MSC also contracted an evaluation of the model adequacy of several ecosystems in the world and whether there was sufficient data to 1) determine KEY status, 2) If models could support simulation of removing key LTL species from the system and determine impacts on other species (Essington and Plagànyi, 2013). This included a survey of several fisheries in the MSC program and in assessment. The survey identified 32 (25 certified and 7 in assessment) that would be flagged as default LTL species based on taxonomy (for example, fisheries targeting herrings, sardines, anchovies and krill). Many of the fisheries target the same stocks so the total number of stocks in the program is much smaller. 15

Below there is a list of stocks and ecosystems in analysis (stocks marked * assumed to be key LTL). Essington and Plagànyi, 2013 The study revealed that Conformity Assessment Bodies (CABs) should apply appropriate caution when using existing models for testing stocks against the key LTL filters. Models should be reviewed for: 1. Representation of predators, i.e. are major predator groups represented? 2. Aggregation of predators, i.e. are important predators specified individually or combined into broader functional groups? When predator groups are not represented in a model, additional diet data should be gathered to more fully capture likely predators in an ecosystem. This may include developing new data matrices that incorporate predator species that are missing from the models. 7.2 IFFO RS IFFO RS fish stocks approved as raw material for feed, which are not already MSC certified, have to be harvested in line with scientific advice however, there is no extra consideration given within the IFFO RS scheme for the ecological importance of forage species when assessing the suitability of reference points used by management and no wider ecosystem impact of harvesting a forage species is tested within the standard. 16

8. Summary The starting point to understanding the difference between these standards is the scope of the certification - the unit of certification. The MSC standard certifies at a fishery level while the IFFO RS certifies a fishmeal factory and does not certify any fisheries, however the standard does list produce a list of species that form an approved list of raw materials. However, this does not allow fisheries supplying IFFO RS certified factories to make any claims. As standards continually evolve, it can be difficult to compare rigour between one standard and another but the following are key requirements in both standards: The governance of the standard must be independent of the commercial activities being certified. Assessments against the standard must be conducted by qualified, independent certification bodies, accredited by national or international authorities for the scope of the certification. Stakeholders must have input to the standard setting process and the final certification decision. The IFFO RS is not a standard that is used to certify a fishery neither is it an eco-label to be used on consumer facing packaging. It is designed to allow a fishmeal and fish oil factory to demonstrate its responsible practices and can be used as a step in a certified responsible value chain. A factory must be able to demonstrate that it responsibly sources its raw materials and then converts these into safe and pure marine ingredients. In order to demonstrate that it responsibly sources its raw materials it must first show where all its raw materials come from. Any whole fish must come from well managed fisheries which are managed according to the key principles of the FAO Code of Conduct for Responsible Fisheries. One way to demonstrate this is to use a fishery that has been certified by the MSC. If MSC certification is not available, the independent certification body will have to conduct an assessment against the FAO Code for the specified fishery. In relation to fisheries by-products (heads, tails, viscera etc) they must not come from threatened species or from illegal unreported or unregulated (IUU) fisheries. The factory must also be able to demonstrate that it has full traceability in the factory from the intake area to the dispatch of finished products. Also the factory must have implemented control systems which can be audited to demonstrate good manufacturing practices. 17

9. Summary table UNIT OF CERTIFICATION PERMITTED CLAIM INDEPENDENT STANDARDS SETTING BODY INDEPENDENT CERTIFICATION BODY GOVERNANCE IFFO RS MSC Principles and Criteria MSC Non KEY species MSC LTL (Low Trophic Level) KEY Species LTL species fishery Fishmeal and Fishery Fish Oil factory Responsible Sustainable Sustainable supply Yes Yes Yes Yes Yes Yes IFFO RS Governing Board Representati ves of fishmeal and fish oil producers, traders, fish feed producers, fish farmers, fish processors, retailers, environment al NGOs, related standards and the IFFO Technical Director. Board of Trustees Technical Advisory Board Stakeholder Council Representatives for industry, environmental and science. Board of Trustees Technical Advisory Board Stakeholder Council Representatives for industry, environmental and science. CHAIN OF CUSTODY TIMELINE FOR REVIEW AND CONSULTATION PROCESS Chain of Custody Standard Continual review and improvement Chain of Custody Requirements Two years (every 5 years) N/A Two years 18

IMPACT ON PET (Protected Endangered and Threatened) SPECIES WILD CAPTURE FISHEIRES FARMED SPECIES FISHERIES AND THE ENVIRONMENT Recorded Whole fish and by-products From byproducts Sourcing for responsibly managed fisheries: Whole fish must come from fisheries scientifically assessed and meeting the key principles of the FAO Code of Conduct for Responsible Fisheries. MSC certification is accepted as evidence of compliance. Avoided Yes Enhanced wild fisheries/cultivation only Three key principles: Sustainable fish stocks: fishing activity must be at a level which is sustainable for the fish population. Minimising environmental impact: fishing operations must be managed to maintain the structure, function and diversity of the ecosystem. Fully assessed and mitigated for with documented evidence of actions Yes Enhanced wild fisheries/cultivation only MSC LTL requirements focus on limiting the ecosystem impacts of fisheries management. Fish byproducts must come from well managed stocks and not included IUU or IUCN red listed fish stocks. Effective management: fishery must meet all local, national and international laws and have a management system in place to respond to changing circumstances to maintain sustainability. 19

No consideration for wider ecosystem impacts of harvesting forage species. Good manufacturing practice for safety, purity and traceability FOOD SAFETY Factory must have attained Certification to the International Feed Ingredients Standard (IFISI) of the International Feed Safety Alliance (IFSA) or equivalent, as proof of responsible manufacturing. N/A N/A The applicant must be in possession of all relevant permits and licenses for the production and sale of fishmeal and fish oil products. 20

TRACEABILITY INCLUDED COMPLY WITH THE FAO CODE OF CONDUCT FOR RESPONSIBLE FISHERIES Conformity ASSESSMENT BODY (CAB) Yes. It covers full traceability from the fishery to the fishmeal factory gate. The IFFO RS Programme also has the Chain of Custody Standard which requires the applicant to demonstrate that the products used are IFFO RS certified. An applicant must be able to demonstrate that IFFO RS products are segregated from non-iffo RS products and that traceability can be maintained at all times throughout the distribution. Yes key elements Yes. This standard is fully accredited by INAB to ISO 65 (EN 45 011) Yes. The MSC Chain of Custody Standards ensures that all MSC-labelled seafood comes from a certified sustainable fishery. Chain of Custody requires effective traceability, storage and record-keeping systems. The MSC also tests the traceability with random trace backs and DNA testing. Yes Yes. MSC certifications are structured in sequence based on the ISO Guide 65.Also ISEAL compliant Yes. The MSC Chain of Custody Standards ensures that all MSClabelled seafood comes from a certified sustainable fishery. Chain of Custody requires effective traceability, storage and record-keeping systems. The MSC also tests the traceability with random trace backs and DNA testing. Yes Yes. MSC certifications are structured in sequence based on the ISO Guide 65.Also ISEAL compliant 21

10. References Brown C and Mackinson S (2011) MSC Low Trophic Level Project: North Sea ECOSIM. Marine Stewardship Council Science Series 1: 2 18. Essington T and Pláganyi EE (2013) Model and data adequacy for Marine Stewardship Council key low trophic level species designation and criteria and a proposed new assessment index. Marine Stewardship Council Science Series 1: 171 191. Johnson P, Bulman C, Fulton B and Smith T (2010) MSC Low Trophic Level Project: South Eastern Australia Case Study. Marine Stewardship Council Science Series 1: 111 170. Kaplan I, Brown CJ, Fulton EA, Gray IA, Field JC and Smith ADM (2012) Impacts of depleting forage species in the California Current. Environmental Conservation 1-14. Marzloff MP and Tam J (2011) MSC Low Trophic Level Project: Ecosystem impacts of fishing low trophic level groups Northern Humboldt Current case study. Marine Stewardship Council Science Series 1: 19 53. Shannon L and Shin Y (2011) MSC Low Trophic Level Project: Southern Benguela Upwelling Ecosystem. Marine Stewardship Council Science Series 1: 54 110. http://www.msc.org http://www.iffo.net/iffo-rs 22