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The short version
- Certified organisations must notify their certification body within ten calendar days of receiving first deliveries from new certified suppliers.
- Receipt of new certified species requires notification within ten calendar days of arrival at the certified facility.
- Operational changes including new activities, contract processors, or scheme scope extensions require written certification body approval prior to execution.
- Certification bodies must update the scheme database within ten days of receiving reported supply chain or scope changes.
Regulatory context and scope management rationale
The Marine Stewardship Council Chain of Custody Standard provides supply chain organisations with a structured mechanism to adapt to commercial opportunities while maintaining full chain of custody integrity. Quality managers, compliance leads, and internal auditors must understand how reporting requirements balance commercial flexibility with rigorous verification. Rather than requiring pre-audit approval for every new purchase, the standard distinguishes between routine supplier additions and fundamental changes to operational scope.
This regulatory framework affects single-site operations, multi-site certificates, and group certificate managers who oversee purchasing and inventory systems. Failing to report changes within prescribed timelines creates discrepancies between internal records and the public scheme database, leading to non-conformities during surveillance audits. A robust internal reporting system ensures that all incoming certified seafood is traceable to an active, validly certified source before claims are passed down the supply chain.
Distinguishing post-event notifications from prior approval requirements
Under Clause 5.2.1 of the Default Version and Group Version of the MSC Chain of Custody Standard, organisations must inform their Conformity Assessment Body in writing or by email within ten calendar days of specific operational events. This ten-day post-event window applies specifically when certified products are received from a new certified supplier, fishery, or farm, or when a new certified species is received. Guidance 5.2.1 clarifies that the ten-day calculation begins on the date of receiving the first delivery of certified products from the new supplier, rather than the contract signing date.
Conversely, Clause 5.2.2 establishes that organisations must receive written approval from their Conformity Assessment Body before implementing structural or operational scope changes. Prior written approval is mandatory before undertaking a new handling activity not listed on the certificate, extending scope to other recognised schemes sharing the standard, or onboarding contract processing and repacking subcontractors. For group certificates, Clause 6.2.2 mandates prior written consent if adding new sites increases the group's total site count by more than ten percent or if new sites perform unapproved activities.
| Change Type | Clause Reference | Timing Requirement | CAB Action |
|---|---|---|---|
| First delivery from new certified supplier | Clause 5.2.1(b) | Within 10 calendar days of receipt | Update scheme database |
| Receipt of new certified species | Clause 5.2.1(c) | Within 10 calendar days of receipt | Update scheme database |
| Change of Chain of Custody contact person | Clause 5.2.1(a) | Within 10 calendar days of change | Update scheme database |
| Undertaking a new operational activity | Clause 5.2.2(a) | Prior written approval required | Review and decide within 10 days |
| Adding contract processing subcontractor | Clause 5.2.2(c) | Prior written approval required | On-site audit before use |
| Group site addition exceeding 10 percent | Clause 6.2.2(d) | Prior written approval required | Sample audit and site register check |
Certification body duties and database synchronization
The reporting process relies on a tight feedback loop between the certified organisation and its accredited Conformity Assessment Body. Upon receiving notification of a new supplier, species, or contact person under Clause 5.2.1, the certification body must update the central scheme database within ten days of the reported change in accordance with Clause 11.2.7 of the MSC Chain of Custody Certification Requirements. This database synchronization guarantees that public certification listings remain accurate for downstream supply chain verification.
When an organisation submits a request for a scope extension involving new activities under Clause 5.2.2, the certification body must evaluate the client's management system and determine whether an on-site audit is required. Under Clause 11.2.5 of the Certification Requirements, the certification body must formally notify the client of its decision within ten days of receiving the request. Compliance leads must account for this evaluation period when planning operational changes to avoid handling certified products before official scope approval is granted.
What to do now
- Establish an automated alert within the procurement system that triggers a notification to the quality team upon the creation of any new certified supplier or species record.
- Verify the active certification status of every new supplier on the official scheme online registry prior to issuing purchase orders and taking initial delivery.
- Submit written or email notifications to the certification body within ten calendar days of receiving the first physical delivery of product from a new certified supplier or farm.
- Draft formal scope extension applications to the certification body well in advance of undertaking new processing, repacking, or subcontracting activities.
- Review internal site registers and group site expansion metrics monthly to ensure site additions exceeding ten percent receive prior certification body consent.
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
- ASC Chain of Custody Module v1.1
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