Comparing Multi-Site and Group Architecture in MSC Chain of Custody

What the certification options are, and why they exist

Seafood organisations operating across multiple locations must select an appropriate certification option to demonstrate supply chain integrity. Quality managers, compliance leads, and internal auditors must evaluate whether Multi-Site certification under the Default Standard or Group certification under the Group Standard best fits their operational structure. Under Table 3 of the MSC Chain of Custody Certification Requirements v3.2, both options issue a single certificate and unique Chain of Custody code shared across all participating sites. However, the key distinction lies in audit intensity, internal oversight, and central office governance.

Multi-Site certification under the MSC Chain of Custody Standard: Default Version v5.1 applies to organisations with multiple physical addresses where every site receives an individual audit from the Conformity Assessment Body. In contrast, Group certification under the MSC Chain of Custody Standard: Group Version v2.1 delegates primary auditing responsibility to a central office function. The certification body audits the central office and a sampled subset of sites, reducing external audit overhead for large site networks while establishing strict central management requirements.

Eligibility criteria and central office governance obligations

Determining eligibility for Group certification requires meeting strict normative thresholds under Clause 6.2.2 of the MSC Chain of Custody Certification Requirements v3.2. First, under Clause 6.2.2(a), the group's central office must be a legal entity capable of executing a binding certification contract. Second, under Clause 6.2.2(b), all member sites must perform substantially similar handling activities under Table 4, or be stratified into distinct sub-groups. Third, under Clause 6.2.2(c) and Clause 6.2.2(d), the group must operate within a single geographic region and utilise a shared written language across all site managers.

Central office control mechanisms under Principle 6 of the MSC Chain of Custody Standard: Group Version v2.1 dictate how the group manager governs member sites. Under Clause 6.1.3, the central office must demonstrate control through full ownership, franchise agreements, or signed contracts requiring every site to conform with the Group Standard and abide by central office and CAB decisions. Furthermore, under Clause 6.4.1 and Clause 6.4.5, the central office must execute internal on-site audits of all sites prior to initial certification and conduct annual internal audits thereafter under Clause 6.4.6.

Risk-based site sampling plans and stratification rules

For Group certificates, certification bodies determine site sample sizes using a structured risk assessment under Section 10.4 of the MSC Chain of Custody Certification Requirements v3.2. Under Clause 10.4.1, the auditor assigns risk scores using Table 11, evaluating scope activities, ownership structures, quality certifications, species mixing risks, label application authority, country corruption index scores, and purchasing management. Under Table 12, the cumulative score categorises the group into one of four sampling tiers: High Risk (Table 14), Medium Risk (Table 15), Low Risk (Table 16), or Very Low Risk (Table 17).

Where a group operates across diverse activities or geographic regions, Clause 10.3.1 mandates sample stratification. Under Clause 10.3.1.1 and Clause 10.3.1.2, stratification is required if sites undertake different activity categories under Table 4 or if processing occurs at only a subset of sites. When stratification applies, Clause 10.3.2 requires the certification body to calculate independent site sample sizes for each sub-group using Table 13 sample selection hierarchy rules.

Example

A seafood distributor with twenty-five warehouse locations and five processing facilities seeks group certification. Because processing facilities introduce higher transformation risks than storage warehouses, the certification body applies Clause 10.3.1.2 and stratifies the group into two sub-groups: Processing (five sites) and Storage (twenty-five sites). The auditor calculates independent risk scores using Table 11, placing Processing into High Risk (Table 14) requiring three initial site audits, and Storage into Low Risk (Table 16) requiring three initial site audits. The central office completes internal audits across all thirty sites under Clause 6.4.1 before the CAB conducts its six sampled site audits.

Step-by-step procedure for selecting between Multi-Site and Group structures

• Audit candidate sites to determine physical addresses, handling activities, geographic spread, and local management languages.
• Evaluate central office resources to verify if the organisation can maintain a legal central entity and conduct annual internal audits under Clause 6.1.1.
• Compare estimated external audit costs between 100% CAB site coverage under Multi-Site and sampled site coverage under Group risk tables.
• Assess expansion plans, noting that adding new sites to a Multi-Site certificate requires prior CAB audits under Clause 11.2.11, whereas Group structures allow central office onboarding under Clause 6.2.2.
• Submit the selected scope structure and site register to the certification body for formal eligibility verification under Clause 6.2.1.

Before your audit

• Confirm that the central office is registered as a valid legal entity capable of signing the CAB contract.
• Verify that all member sites are bound by ownership, franchise, or signed contracts under Clause 6.1.3.
• Inspect internal audit reports to ensure 100% of group sites received an internal audit prior to initial CAB assessment.
• Reconcile the site register to confirm physical addresses, contact details, and joining dates are complete under Clause 6.2.1.
• Verify that document control procedures cover translated operational manuals across all site languages under Clause 6.2.2(d).
• Confirm that any site expansion exceeding 10% of total group size has received written CAB approval under Clause 6.2.2(d).
• Maintain comprehensive annual internal group review minutes signed by the group manager under Clause 6.5.2.

Questions people ask

Can an organisation with sites in multiple countries use Group certification?

Yes, organisations with sites in multiple countries can use Group certification, provided the group is stratified by geographic region or close country groupings under Clause 6.2.2(c) and Clause 10.3.1.3. The CAB calculates independent site sample sizes for each geographic sub-group.

How does a certification body determine how many sites to audit in a Group certificate?

The certification body calculates site sample sizes using Table 11 risk-scoring criteria, evaluating activities, ownership, species mixing, and purchasing controls. The total score assigns the group to a risk table (Tables 14 to 17), which defines the required number of site audits.

What happens if a major non-conformity is found at one site in a Group certificate?

Under Clause 9.4.9(b), a site major non-conformity must be closed within thirty days or the site is immediately suspended from the group. If major non-conformities across sampled sites equal or exceed the reject number in Table 10, the certification body raises a group critical non-conformity and suspends the entire group certificate.

Do new sites added to a Group certificate require a CAB audit before joining?

No, new sites added to a Group certificate do not automatically require a CAB audit if they do not introduce new scope activities and total 10% or less of the existing group size. Under Clause 6.2.3, the central office must conduct an internal audit to verify site conformity before adding the site to the register.

Reference documents

• MSC Chain of Custody Standard: Default Version v5.1
• MSC Chain of Custody Standard: Group Version v2.1
• MSC Chain of Custody Certification Requirements v3.2
• MSC General Certification Requirements v2.6