ASC approves blanket variance for mass balance bagged feed labelling

Global variance approval for mass balance feed mills

The Aquaculture Stewardship Council has approved a global variance request that significantly simplifies compliance for certified feed manufacturers. Variance Request VR1040 introduces an approved blanket variance allowing feed mills operating under the Mass Balance Production Model to identify conforming product using dispatch documentation instead of physical bag labels. This decision applies globally to all units of certification facing operational challenges under Indicator 3.3.1 and Indicator 3.3.3 of the ASC Feed Standard Version 1.2, as well as RUoC Requirement 4.6.1.

Previously, feed mills experiencing difficulties with physical labelling had to submit individual variance requests to conformity assessment bodies for case-by-case evaluation. The Aquaculture Stewardship Council initially issued communications instructing eligible mills to apply individually, which generated multiple submissions from feed companies. Following review, the Variance Request Committee decided that a single global variance was necessary to ensure consistent application across all certified sites. Consequently, individual units of certification no longer need to submit separate variance applications to adopt this documentation-based alternative.

Operational background and standardisation rationale

Under standard certification rules, certified feed mills must physically mark sealed bagged feed to identify it as ASC-conforming product. For mills operating under the Mass Balance Production Model, segregating and physically labelling individual bags destined exclusively for certified farms presents severe operational difficulties. To achieve physical identification, feed mills would be forced to re-bag and relabel entire production lines through an additional secondary process. This secondary handling introduces substantial operational complexity, increases production costs and reduces mill efficiency.

The approval of Variance Request VR1040 establishes parity between bagged feed deliveries and long-standing rules governing bulk feed shipments. For bulk deliveries, product conformity under the Mass Balance Production Model is identified through accompanying delivery paperwork, such as invoices and dispatch notes, rather than physical markings on transport containers. Extending this paper-based approach to bagged feed provides a practical compliance pathway while maintaining rigorous chain of custody oversight across the global aquaculture supply chain.

Core requirements for paper-based product identification

Feed mills that cannot physically label sealed bags must satisfy three specific operational conditions to demonstrate product conformity:

• Dispatch documentation: Accompanying transfer, shipping and sales documents such as invoices, dispatch notes and distribution notes must explicitly state ASC product identification and the Mass Balance Production Model applied.
• Batch traceability: Feed mills must maintain complete traceability by ensuring that identical batch or lot numbers appear on both physical feed bag labels and corresponding dispatch, transfer and sales documentation.
• Centralised management: The generation and management of all accompanying dispatch and sales documentation must be executed through an effective centralised database or software system.

Validity periods and transition timeline

The approved variance takes effect on 25 June 2026 and provides immediate operational relief to eligible feed manufacturers worldwide. Variance Request VR1040 will remain in active effect until Version 1.01 of the ASC Feed Standard is officially superseded by Version 1.2. At that transition point, the Aquaculture Stewardship Council will issue an updated variance aligned with Version 1.2 to maintain regulatory continuity.

Upon publication of the updated Version 1.2 variance, both Variance Request VR1040 and Variance Request VR1028 will be archived. Quality managers should note that this decision was formally released and made effective on 25 June 2026 following stakeholder consultation under the normative ASC Variance Request Procedure Version 2.1. Maintaining full alignment with these transition dates ensures that certified feed mills avoid compliance gaps during upcoming audit cycles.

What to do now

• Audit system workflows: Review software and centralised database configurations to verify that dispatch notes, shipping documents and invoices automatically display ASC product status and the Mass Balance Production Model.
• Align batch labelling: Verify that batch or lot numbers printed on physical feed bags match the corresponding numbers generated on dispatch, transfer and sales paperwork.
• Update compliance procedures: Revise internal quality management procedures to incorporate Variance Request VR1040 rules without submitting individual variance applications to certifiers.

Reference documents

• Variance Request VR1040
• ASC Feed Standard, Version 1.2, Indicator 3.3.1 and Indicator 3.3.3
• Requirements for Units of Certification, Version 1.01, Requirement 4.6.1