Mandatory Food Safety Certification for ASC Chain of Custody

What the food safety requirement is, and why it exists

Supply chain integrity for farmed seafood extends beyond environmental criteria to encompass rigorous food safety oversight. Quality managers, compliance leads, and internal auditors must recognise that the Aquaculture Stewardship Council enforces mandatory food safety certification requirements for specific supply chain actors. Under Section Part A of the ASC Chain of Custody Module v1.1, organisations undertaking processing, contract processing, packing, or repacking must maintain valid certification against a Global Food Safety Initiative recognised scheme or ISO 22000 throughout their entire certification period.

This requirement, effective following a grace period ending on 30 May 2024 under Clause 5.7.2.1, bridges the gap between environmental sustainability and consumer safety. While the Marine Stewardship Council Default Standard focuses primarily on traceability and segregation, the ASC Module recognises that farmed seafood processing carries distinct food safety risks. By embedding GFSI and ISO 22000 benchmarks into the eligibility criteria, the ASC ensures that processing sites handling certified farmed seafood adhere to internationally accredited food safety management systems.

Scope activities, exemption thresholds, and small business guidance

The food safety requirement applies specifically to physical handling activities defined in Table 4 of the MSC Chain of Custody Certification Requirements v3.2. Under Part A Eligibility rules, any organisation performing processing, contract processing, packing, or repacking must hold an accredited food safety certificate covering the scope of their seafood activities. Pure trading, storage, or transportation entities that do not alter packaging or process fish are exempt from this obligation.

To prevent disproportionate administrative burdens on smaller enterprises, the ASC establishes explicit exemption criteria based on business size. Under Part A Eligibility, an organisation is exempt from mandatory GFSI or ISO 22000 certification if it meets at least one of three thresholds: annual turnover below EUR 2 million, annual seafood volume handled below 200 metric tonnes, or fewer than 50 seafood-business staff including peak seasonal workers. Exempt organisations must still demonstrate compliance with local food safety regulations and official government inspections.

Notification deadlines, audit protocols, and suspension risks

Maintaining active food safety certification requires strict administrative vigilance and rapid reporting mechanisms. Under Clause 5.2.1.1(a), certified processors and packers must operate an effective procedure to notify their Conformity Assessment Body within two calendar days if their GFSI-recognised or ISO 22000 certificate becomes invalid, suspended, or withdrawn.

Auditors enforce this rule during annual planning and surveillance audits. Under Clause 7.3.1 of the ASC Chain of Custody Module v1.1, the auditor must verify prior to each audit that non-exempt processors and packers maintain valid food safety certification covering their supply chain scope across the entire audit cycle. If a required food safety certificate lapses or is withdrawn, Clause 7.4.10(l) of Part C mandates that the certification body shall immediately suspend the organisation's Chain of Custody certificate.

Step-by-step procedure for managing food safety compliance

• Review operational scope against Table 4 activity definitions to determine if site activities include processing, contract processing, packing, or repacking.
• Evaluate business metrics against Part A size criteria to confirm whether the facility qualifies for an exemption based on turnover, volume, or headcount.
• Obtain and maintain an accredited GFSI-recognised or ISO 22000 certificate covering all physical handling sites if non-exempt under Clause 5.7.2.1.
• Establish an internal escalation procedure to notify the certification body within two calendar days if food safety certification status changes under Clause 5.2.1.1(a).
• Align the mandatory Food Fraud Vulnerability Assessment required under Clause 5.8.1 with the existing food safety management system framework.

Example

A salmon smoking and packing facility holding ASC Chain of Custody certification processes 1,500 metric tonnes of seafood annually with 80 staff, making it non-exempt under Part A rules. During an unannounced food safety audit, the plant receives a certificate suspension from its GFSI scheme owner. Under Clause 5.2.1.1(a), the compliance manager notifies their Chain of Custody certification body in writing within 48 hours. Because valid food safety certification is a mandatory eligibility requirement under Clause 5.7.2.1, the certification body applies Clause 7.4.10(l) and suspends the ASC Chain of Custody certificate until accredited food safety certification is reinstated.

Before your audit

• Confirm whether processing, contract processing, packing, or repacking activities are included in your certificate scope.
• Verify that your GFSI-recognised or ISO 22000 certificate covers all physical handling addresses and processing activities.
• Compile financial, volume, or headcount documentation if claiming a size exemption under Part A rules.
• Verify that local food hygiene inspection reports and operating permits are current for exempt sites.
• Test internal escalation channels to ensure two-day CAB notification compliance under Clause 5.2.1.1(a).
• Review food safety certificate expiration dates to prevent coverage gaps ahead of annual CAB audits under Clause 7.3.1.
• Ensure your annual Food Fraud Vulnerability Assessment covers farmed seafood products under Clause 5.8.1.

Questions people ask

Are seafood traders who do not physically touch product required to hold GFSI certification?

No, traders, wholesalers, and distributors that do not undertake processing, contract processing, packing, or repacking are exempt from mandatory GFSI or ISO 22000 certification under Part A of the ASC Chain of Custody Module v1.1. The requirement applies strictly to physical handling and transformation activities.

What happens if a processor's GFSI certificate expires or is suspended?

If a required GFSI or ISO 22000 certificate becomes invalid, the organisation must notify its certification body within two days under Clause 5.2.1.1(a). Under Clause 7.4.10(l) of Part C, the certification body must immediately suspend the organisation's ASC Chain of Custody certificate.

Do small processors exempt from GFSI rules still need a Food Fraud Vulnerability Assessment?

Yes, under Clause 5.8.1 and Guidance 5.8.1, all ASC Chain of Custody certificate holders must maintain a documented Food Fraud Vulnerability Assessment procedure and intervention plan. This obligation applies universally regardless of whether an organisation is exempt from GFSI or ISO 22000 food safety certification.

Which GFSI-recognised schemes satisfy the ASC Chain of Custody requirement?

Any scheme benchmarked and recognised by the Global Food Safety Initiative, such as BRCGS Food Safety, FSSC 22000, SQF, or IFS Food, as well as ISO 22000, satisfies the eligibility requirement under Part A of the ASC Chain of Custody Module v1.1. Organisations must ensure that the scope of their food safety certificate explicitly covers all physical seafood handling activities conducted on-site.

Reference documents

• ASC Chain of Custody Module v1.1
• MSC Chain of Custody Standard: Default Version v5.1
• MSC Chain of Custody Certification Requirements v3.2
• MSC General Certification Requirements v2.6