Conduct Due Diligence Under ASC Feed Standard Principle 2

Due Diligence rules for ingredient supply chains

The Aquaculture Stewardship Council updated supply chain Due Diligence rules under Criterion 2.2 in version 1.2 of the ASC Feed Standard. This affects quality managers, compliance leads and procurement teams at certified feed manufacturing units. Feed mills must conduct structured Due Diligence to identify and manage social, legal and environmental risks associated with ingredient manufacturers and primary raw material producers. Conformity Assessment Body auditors verify Due Diligence reports, risk classifications and supplier approval procedures during certification audits.

Due Diligence applies to any unique ingredient from an individual manufacturer that represents more than one percent of the total annual ingredient weight received by the mill for use in aquafeed. Sourcing teams determine the one percent threshold based on purchasing records from the previous year or best estimates for the current year. Excluded per default from Due Diligence are feed additives, including premixes, vitamins, minerals, trace elements and colourants, regardless of volume. For facilities producing both aquafeed and livestock feed, volume calculations apply exclusively to ingredient quantities destined for aquafeed production.

Failing to conduct Due Diligence prior to purchasing, omitting required risk factors or sourcing non-permitted ingredients indicates a dysfunctional quality management system. Auditors examine supplier approval logs, traceability documentation and annual Due Diligence summary reports during reviews. Demonstrating transparent supply chain risk screening ensures that feed mills source raw materials responsibly across global supply chains.

Assessing supply chain tiers and risk factors

Due Diligence covers two distinct levels of the ingredient supply chain:

• Ingredient manufacturers: Facilities performing primary processing must demonstrate Low Risk for legal operating licences, labour rights, health and safety, environmental management and product disclosures under Criterion 2.2 and Table 1.
• Primary raw material producers: Agricultural farms and capture fisheries producing raw inputs must be evaluated for legal land use, labour rights, illegal fishing, deforestation and endangered species risks.

Four approved pathways for risk determination

Indicator 2.2.5 and Indicator 2.2.6 require feed manufacturers to determine risk levels using four approved pathways detailed in Appendix 3. Feed mills can select Pathway 1 Country Risk Score Cards to verify if a producing country is ranked as Low Risk for specific risk factors. If a country is rated Medium or High Risk under Pathway 1, the mill must utilise another pathway to determine risk levels for those specific factors.

Under Pathway 2, feed mills conduct sub-national, sectoral or fishery assessments through escalating supply chain mapping and evidence collection. For marine whole fish ingredients, assessors evaluate fishery access controls, monitoring systems and vessel registries using Section 4 of PAS 1550 principles.

Under Pathway 3, feed mills collaborate directly with ingredient manufacturers to evaluate operational evidence, management systems, supplier questionnaires and audit reports. Alternatively, feed mills can select Pathway 4 to verify whether an ingredient manufacturer or primary raw material holds valid certification under an approved scheme listed on the ASC website.

Permitted risk levels and the three-year Medium Risk exception

Indicator 2.2.8 mandates that feed mills must only source from supply chains where Due Diligence on the ingredient manufacturer indicates Low Risk across all applicable risk factors. Sourcing from ingredient manufacturers displaying Medium Risk or High Risk is strictly prohibited for all aquafeeds.

Under Indicator 2.2.9, primary raw material production must generally achieve a Low Risk rating. However, version 1.2 introduces a temporary exception for primary raw materials determined as Medium Risk under Pathway 1, Pathway 2 or Pathway 3. Feed mills may source Medium Risk primary raw materials for a period of three years from 2 February 2026 until 2 February 2029, provided the ingredient manufacturer itself is verified as Low Risk.

Ingredients sourced under this Medium Risk exception are classified as non-eligible ingredients for Mass Balance accounting under Appendix 5. Feed mills using this exception must publish their outcomes, demonstrate an increasing proportion of Low Risk primary raw materials at each annual surveillance audit, and transition all primary raw materials to Low Risk by 2 February 2029. Under Appendix 3, Due Diligence assessments must be repeated whenever monitoring signals changed risk levels, when supply chain changes occur, or at least once every three-year certification cycle.

What to do now

• Map aquafeed ingredients: Identify all unique ingredients from individual manufacturers representing more than one percent of total annual aquafeed volume.
• Review ingredient manufacturer risk scores: Confirm that every ingredient manufacturer achieves a Low Risk outcome across all applicable risk factors using one of the four pathways.
• Audit Medium Risk primary raw materials: Verify that primary raw materials classified as Medium Risk meet the Indicator 2.2.9 exception criteria and track annual progression toward Low Risk.
• Formalise ingredient approval procedures: Implement documented procedures under Appendix 11 to govern supply chain mapping, risk assessments, pathway selection and annual website disclosures.

Reference documents

• ASC Feed Standard, V1.2, Criterion 2.1, Criterion 2.2, Indicators 2.2.1, 2.2.2, 2.2.3, 2.2.4, 2.2.5, 2.2.6, 2.2.7, 2.2.8, 2.2.9, 2.2.10, 2.2.11, 2.2.12, 2.2.13, Appendix 3, Appendix 5, Appendix 7, Appendix 8, Appendix 10, Appendix 11
• ASC Feed Standard Interpretation Manual, V1.2, Criterion 2.1, Criterion 2.2, Appendix 3, Appendix 5, Appendix 10, Appendix 11