Managing MSC Supply Chain Traceback Requests and the 5-Day Deadline

Understanding MSC supply chain traceback requests and submission rules

The Marine Stewardship Council conducts periodic supply chain traceback exercises and reconciliations to verify product integrity across certified supply chains. A traceback involves collecting and reviewing documentation to trace certified seafood from the point of sale or serving back to its certified fishery or farm of origin. Reconciliations compare total purchase and sales volumes between trading partners over defined timeframes to ensure non-certified seafood has not entered the certified chain.

Under Clause 5.5.1 of the Default Version v5.1 and Group Version v2.1, and Clause 5.6.1 of the Consumer-Facing Organisation Version v2.1, certified organisations must cooperate fully with all requests for traceability documents or sales and purchase records. These requests may originate directly from the scheme owner, its designated agents, or the nominated Conformity Assessment Body. Designated agents include nominated representatives from partner scheme owners such as the Aquaculture Stewardship Council, as well as official assurance providers.

Under Clause 4.8.7.d of the General Certification Requirements v2.7, maintaining compliance with traceback requests is a mandatory contractual commitment. The requirement applies universally to all certified entities taking legal ownership of certified products, regardless of whether they operate single sites, multi-site networks, group certificates, or consumer-facing facilities.

Understanding the time calculations is critical for compliance leads. According to the scheme definitions, timeframes measured in days refer strictly to calendar days unless working days are explicitly specified. Consequently, weekend days and public holidays count towards response windows.

Managing the 5-day submission deadline and document preparation

Clause 5.5.1.1 of the Default and Group Standards and Clause 5.6.1.1 of the Consumer-Facing Organisation Standard establish a strict document submission timeframe. Certified organisations must provide all requested purchase, sales, and traceability records within five calendar days of the request being issued.

Organisations may remove sensitive financial details, such as prices, margins, and unit costs, prior to submitting documentation. However, all non-financial text, dates, volume figures, batch numbers, species identifiers, and supplier details must remain completely unaltered. If requested by the scheme owner, organisations must submit records in English.

If an extension request is denied, the original five-calendar-day deadline remains fully enforceable. Furthermore, Clause 5.3.5 of the Default Standard and Clause 5.4.4 of the Consumer-Facing Organisation Standard mandate that certified entities must maintain the legal right to request records from subcontracted storage, transport, or contract processing facilities. Subcontractor delays do not exempt certificate holders from the five-day rule.

The CAB escalation pathway and non-conformity timeline

When an organisation fails to deliver requested records within five calendar days, the scheme owner initiates a formal enforcement mechanism governed by Clause 4.8.7.d.i of the General Certification Requirements v2.7. The scheme owner issues an official request for action to the assigned Conformity Assessment Body.

• Within 15 calendar days of receiving a request for action, the Conformity Assessment Body must intervene directly with the client, at the client's expense, to verify record availability and transmit the required documentation.
• If the client fails to provide the requested records to the scheme owner within this 15-day intervention window, the Conformity Assessment Body must raise a major non-conformity against the organisation's management system.
• The organisation receives a final 15-day period to close out the major non-conformity by providing complete, verified traceability documentation.
• If the major non-conformity remains open after 15 calendar days, the Conformity Assessment Body must immediately suspend or withdraw the certificate in accordance with Section 7.4.

Following any intervention regarding non-provision of traceback data, Clause 4.8.7.d.i.C mandates that the Conformity Assessment Body perform a comprehensive risk analysis. This analysis often leads to additional expedited or unannounced physical audits. Under Clause 7.4.16, suspended organisations must cease selling certified products immediately and notify all affected commercial customers in writing within four days.

Auditing traceback readiness: requirement matrix and practical scenario

Quality managers and internal auditors must regularly assess site systems against traceback obligations to verify operational readiness.

Example

During a routine supply chain reconciliation, the scheme owner identifies a volume discrepancy for certified Atlantic cod between a primary processor and a secondary distributor. The scheme owner issues a formal traceback request to the distributor, requiring purchase invoices, goods receipt notes, and dispatch logs for five specific production lots within five calendar days.

The distributor's compliance lead immediately gathers the electronic receiving files and dispatch records. Before transmission, the lead redacts unit prices and total monetary values while leaving supplier certificate numbers, lot identifiers, net weights, and delivery dates fully legible. The complete record package is transmitted securely in English on day three, successfully satisfying the traceback request and avoiding escalation to the Conformity Assessment Body.

Before your audit

• Verify that the designated Chain of Custody contact person details are current on the scheme database.
• Confirm that written agreements with all active subcontractors include mandatory record access provisions.
• Review historic purchase and sales records to ensure retention covers a minimum of three years or product shelf life.
• Test internal redaction software to confirm financial details can be removed without obscuring traceability codes.
• Check that responsible administrative staff understand the strict five-calendar-day document submission rule.
• Ensure procedures exist to translate non-English shipping and processing documents into English upon request.
• Verify that mock traceback exercises are conducted at least annually to validate system response speeds.

Questions people ask

How many days does an organisation have to respond to an MSC traceback request?

An organisation must provide all requested traceability documents and sales or purchase records within five calendar days of the request being made.

Can financial information be removed from MSC traceback documents?

Yes, financial details such as prices and cost figures may be removed, provided all non-financial traceability text, volumes, and dates remain unaltered.

What happens if an organisation fails to submit traceback records on time?

The scheme owner issues a request for action to the Conformity Assessment Body, initiating a 15-day intervention period that can lead to a major non-conformity and certificate suspension.

Are weekend days included in the 5-day document submission window?

Yes, timeframes defined in days refer to calendar days unless working days are explicitly stated, meaning weekends and holidays are included in the five-day limit.

Can an organisation request an extension to the 5-day traceback deadline?

An extension may be requested in writing, but if the scheme owner or designated agent does not formally approve it, the original five-day deadline remains mandatory.

Reference documents

• MSC Chain of Custody Standard: Default Version v5.1
• MSC Chain of Custody Standard: Group Version v2.1
• MSC Chain of Custody Standard: Consumer-Facing Organisation Version v2.1
• MSC General Certification Requirements v2.7
• MSC-MSCI Vocabulary v1.7