Prevent Child Labour and Protect Young Workers Under ASC Feed

Preventing child labour across feed mill operations

The Aquaculture Stewardship Council established mandatory rules prohibiting child labour and protecting young workers under Criterion 1.5 in version 1.2 of the ASC Feed Standard. This affects quality managers, compliance leads, human resources personnel and recruitment officers at certified feed manufacturing facilities. Feed manufacturers must ensure that no child labour occurs within production operations, through labor contractors or across supply chains. Conformity Assessment Body auditors inspect age verification records, employee registers and young worker shift schedules during certification audits.

Child labour deprives children of their childhood, potential and dignity, while interfering with their schooling and health. Under Criterion 1.5, feed mills must establish robust age verification controls during onboarding to verify that all workers satisfy minimum age requirements. In addition, feed mills must implement specific safeguards for young workers aged fifteen to seventeen to prevent exposure to industrial hazards. Failing to verify worker age or allowing underage children to perform hazardous work indicates a critical non-conformity.

Auditors examine physical employee registers, review government identity dockets and interview young workers to verify compliance. Where feed mills hire seasonal workers or day labourers, age verification rules apply equally without exception. In addition, feed mills must extend child labour prevention rules to ingredient manufacturers and primary raw material producers under Principle 2 Due Diligence. Demonstrating strict age verification and protecting young workers safeguards fundamental human rights across global aquafeed supply chains.

Minimum working age and age verification rules

Indicator 1.5.1 establishes that the minimum age for employment is fifteen years, or the national minimum working age, or the age of completing compulsory education, whichever is higher. Under footnote 19, developing countries that ratified International Labour Organization Convention 138 may initially set the minimum age at fourteen years if legally permitted. Management must maintain documented age verification procedures under Indicator 1.5.3 to verify worker age prior to hiring.

Age verification must rely on official documentation verified before onboarding begins:

• Official identification dockets: Management must inspect and retain copies of valid birth certificates, national identity cards, passports or official government population registers.
• Educational completion records: Facilities may verify school leaving certificates or official education transcripts confirming completion of mandatory schooling.
• Medical age estimations: Where official identity dockets are unavailable or falsified, facilities must obtain independent medical assessments conducted by qualified healthcare professionals.
• Verified employee registers: Feed mills must maintain an updated central register listing full names, birth dates and verified age documentation for every worker.

Protecting young workers from industrial hazards

Indicator 1.5.2 and Indicator 1.5.4 enforce strict operational limits to protect young workers aged fifteen to seventeen from physical harm and educational disruption. Young workers possess developing bodies and require specific safeguards against workplace injuries, fatigue and chemical exposure. Management must conduct specific risk assessments under Appendix 7 to identify hazardous tasks and reassign young workers to safe duties.

Facilities employing young workers must enforce four mandatory operational controls:

• Hazardous work prohibition: Young workers are strictly prohibited from handling hazardous chemicals, operating heavy mill machinery, working at heights, carrying heavy loads or working in dangerous temperature extremes.
• Night shift restrictions: Employers must not assign young workers to night shifts between 22:00 and 06:00, or during hours defined as night work under national legislation.
• Educational time limits: Combined hours of school, training and work must not exceed eight hours per day, ensuring work schedules do not interfere with compulsory education.
• Health monitoring logs: Feed mills must provide regular health checks for young workers to confirm that assigned duties do not impact their physical development.

Child labour remediation and educational support

When child labour is identified on site or in supply chains, feed mills must take immediate action under Indicator 1.5.5 and the Remediation Guidance section. Removing a child from work without financial support risks driving the child into worse exploitation or illegal labor. Therefore, remediation must prioritize the best interest of the child and provide long-term educational and financial stability.

Management must execute a structured remediation process in consultation with local child protection authorities:

• Immediate safeguarding: The child must be removed immediately from hazardous work or factory premises to ensure physical safety and wellbeing.
• Financial stipend provision: The feed mill must provide an interim stipend to the family equal to the higher of the child's previous earnings or local minimum wage.
• Educational enrolment support: The facility must pay for school fees, books, uniforms and transport until the child reaches the legal working age or completes compulsory education.
• Stakeholder consultation: Remediation plans must be developed in partnership with parents, local child welfare organisations and education authorities to monitor progress.

What to do now

• Audit employee registers: Review central personnel files for all current workers to confirm that verified copies of birth certificates or national identity cards are on file.
• Inspect young worker duties: Identify all workers aged fifteen to seventeen and verify that their work schedules exclude night shifts, heavy lifting and hazardous chemical handling.
• Formalise age verification procedures: Update human resources onboarding protocols to require identity verification prior to signing employment contracts.
• Establish child remediation protocols: Draft a documented child labour remediation procedure covering immediate removal, family stipends and school fee support under Criterion 1.5.

Reference documents

• ASC Feed Standard, V1.2, Criterion 1.5, Indicators 1.5.1, 1.5.2, 1.5.3, 1.5.4, 1.5.5, 1.5.6, Appendix 7
• ASC Feed Standard Interpretation Manual, V1.2, Criterion 1.5, Remediation Guidance Section