On this page
- What the under-assessment requirement is, and why it exists
- Eligibility rules, prior approval, and subcontracted storage limits
- Step-by-step procedure for managing under-assessment stock
- Example
- Before your audit
- Questions people ask
- Can any Chain of Custody certified company buy under-assessment seafood?
- Can under-assessment seafood be stored in a third-party cold storage facility?
- When can under-assessment seafood be sold as certified?
- What harvest dates are eligible for under-assessment seafood?
- Reference documents
The short version
- Only fisheries, farms, or named members of their client groups are eligible to purchase under-assessment seafood.
- Certificate holders must obtain written approval from their certification body before handling under-assessment seafood.
- All under-assessment products must be clearly identified and physically segregated from certified and non-certified stock.
- Under-assessment seafood cannot be sold as certified or carry certified trademarks until final certification is published.
What the under-assessment requirement is, and why it exists
Under-assessment seafood refers to fish or seafood products harvested during a fishery or farm assessment process before final certification is awarded. Quality managers, compliance leads, and internal auditors must understand that under-assessment stock occupies a unique regulatory category within the Marine Stewardship Council framework. To prevent premature certified market claims while enabling supply chain preparation, the standard permits restricted harvesting, storage, and handling under strict physical and administrative safeguards.
These requirements apply strictly to fisheries, farms, named members of a fishery client group, and same legal entities of farms undergoing assessment. Under Section 5.6 of the MSC Chain of Custody Standard: Default Version v5.1 and Group Version v2.1, seafood harvested after the specified target eligibility date may be stored and processed ahead of certification. However, because the fishery or farm has not yet achieved formal certification, under-assessment product remains non-certified and must never enter general commercial trade as certified stock.
Eligibility rules, prior approval, and subcontracted storage limits
Taking ownership of under-assessment product is strictly restricted across global supply chains. Under Clause 5.6.1, organisations are eligible to purchase under-assessment product only if they are the fishery or farm undergoing assessment, or a named member of the client group for that fishery. Guidance 5.6.1.b clarifies that no other chain of custody certified companies further down the supply chain are eligible to buy or take ownership of under-assessment seafood prior to certification.
Prior to handling under-assessment stock, Clause 5.2.2.d mandates that an organisation must receive prior written approval from its Conformity Assessment Body. In addition, under Table 4 of the MSC Chain of Custody Certification Requirements v3.2, the certification body must record Scope Activity 16, titled Handling under-assessment product, on the scheme database alongside the relevant fishery or farm assessment certificate number.
Important: Eligible client group members may utilise subcontracted storage facilities to warehouse under-assessment stock, provided the eligible client group member retains legal ownership until final certification is published.
| Requirement Domain | What the Auditor Checks | Evidence to Have Ready |
|---|---|---|
| Ownership Eligibility | Verification that buyer is a named fishery client group member | Official fishery client group list and target eligibility date record |
| Prior CAB Approval | Written approval from CAB before receiving under-assessment stock | CAB approval email and scheme database Scope Activity 16 entry |
| Harvest Date Compliance | Proof that harvest occurred on or after the target eligibility date | Catch certificates, logbooks, and vessel landing documentation |
| Physical Segregation | Complete physical separation from certified and non-certified stock | Dedicated freezer bays, distinct lot tags, and line clearance logs |
| Trademark Restrictions | Total absence of MSC or ASC labels or certified sales claims | Sales invoices without certified claims and unlabelled packaging |
Step-by-step procedure for managing under-assessment stock
Managing under-assessment seafood requires a systematic control procedure from harvest to final certification publication. Operating entities must establish robust physical and digital controls to guarantee that uncertified product is not released into commercial channels prematurely.
- Confirm that the fishery or farm assessment has formally established a target eligibility date published on the scheme website.
- Verify that the purchasing entity is explicitly named on the fishery client group list under Guidance 5.6.1.b.
- Submit a written scope extension request to the Conformity Assessment Body and obtain written approval under Clause 5.2.2.d.
- Inspect incoming deliveries to confirm harvest dates occur on or after the target eligibility date under Guidance 5.6.
- Apply distinct physical tags and assign dedicated storage locations to keep under-assessment stock segregated under Clause 5.6.2.a.
- Maintain complete traceability logs linking stored batches back to the Unit of Certification and harvest date under Clause 5.6.2.b.
- Monitor the scheme website for publication of the final Public Certification Report before releasing stock as certified under Clause 5.6.2.c.
Example
A seafood processing company that is a named member of a salmon fishery client group wishes to store fish harvested during assessment. After receiving written approval from its certification body for Scope Activity 16 under Clause 5.2.2.d, the plant receives a 50-tonne landing and verifies that the harvest date succeeds the published target eligibility date. Receiving staff place the batch into a dedicated, clearly marked cold storage bay with bright orange under-assessment tags, recording the inventory as non-certified stock. Once the Public Certification Report is posted on the MSC website, the company updates the inventory status to certified and issues certified sales invoices under Clause 5.6.2.c.
Tip: Cross-check the published target eligibility date on the MSC website before taking delivery, as any fish harvested prior to that date can never be sold as certified.
Common finding: Transferring legal ownership of under-assessment stock to a third-party processor or trader before final certification, violating Clause 5.6.1.b.
Note: Subcontracted cold stores may physically hold under-assessment seafood, but legal ownership must remain with the eligible client group member until certification is awarded.
Before your audit
- Confirm that your organisation is officially listed as a named member of the fishery client group.
- Verify that written CAB approval for handling under-assessment product was received prior to stock arrival under Clause 5.2.2.d.
- Check that Scope Activity 16 is correctly recorded on the scheme database profile under Table 4 rules.
- Inspect physical storage areas to ensure under-assessment stock is clearly tagged and physically segregated under Clause 5.6.2.a.
- Audit traceability records to confirm every under-assessment batch links directly to the Unit of Certification and harvest date under Clause 5.6.2.b.
- Review all sales invoices for under-assessment stock to verify that no certified claims or trademarks were applied under Clause 5.6.2.c.
- Verify that catch records demonstrate harvest occurred on or after the published target eligibility date.
Questions people ask
Can any Chain of Custody certified company buy under-assessment seafood?
No, only a fishery or farm undergoing assessment, or a named member of the client group for that fishery or farm, is eligible to purchase under-assessment product under Clause 5.6.1. General supply chain entities further down the chain cannot buy or take ownership of under-assessment seafood until final certification is achieved.
Can under-assessment seafood be stored in a third-party cold storage facility?
Yes, eligible client group members may store under-assessment seafood in subcontracted storage facilities under Guidance 5.6.1.b. However, the eligible fishery client group member must retain legal ownership of the seafood until the fishery or farm achieves final certification.
When can under-assessment seafood be sold as certified?
Under-assessment seafood can only be sold as certified after the fishery or farm is officially certified and the Public Certification Report is published on the MSC or ASC website under Clause 5.6.2.c and Guidance 5.6.2.c. Until that publication occurs, the product cannot carry certified claims or trademarks.
What harvest dates are eligible for under-assessment seafood?
Under Guidance 5.6, under-assessment seafood must be harvested on or after the specified target eligibility date published on the MSC or ASC website. Any seafood harvested before the official target eligibility date is ineligible for certification and can never be sold as certified.
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
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