On-Site Audit Exemptions Under MSC Chain of Custody Standards

Regulatory context and on-site audit exemption rationale

The Marine Stewardship Council Chain of Custody certification framework balances rigorous supply chain integrity with proportional oversight. Quality managers, compliance leads, and internal auditors must navigate complex auditing rules across single-site, multi-site, and group certificates. While physical processing facilities present significant risks of product substitution and mixing, administrative trading offices and sealed storage sites carry distinct risk profiles that do not always justify physical on-site inspections.

Understanding the specific criteria for on-site audit exemptions allows compliance teams to optimise audit schedules without breaching standard requirements. The standard establishes clear thresholds where physical presence is mandatory and where remote assessment or central management system controls are sufficient. This risk-based approach ensures that auditing resources focus on high-risk operations where certified seafood is exposed to physical handling or transformation.

Exemptions for trading offices and non-handling operations

Under Clause 6.4.1.1 of the MSC Chain of Custody Standard: Group Version, sites that do not physically handle certified products are explicitly exempt from mandatory initial on-site internal audits. Guidance 6.4.1.1 confirms that pure trading offices—entities that take legal ownership, issue invoices, and manage commercial transactions without touching physical product—fall directly under this non-handling exemption. These entities manage product integrity entirely through administrative controls and documented traceability checks.

From a certification body oversight perspective, Clause 7.1.6.1 of the MSC Chain of Custody Certification Requirements v3.2 permits remote initial and re-certification audits for clients whose scope is limited to trading without physical handling or contract processing. Furthermore, Clause 11.3.1.a.ii allows an extended eighteen-month surveillance audit frequency for pure traders. Under Clause 11.3.3, surveillance audits for trading offices may also be conducted remotely if the site operates in a country with a Transparency International Corruption Perception Index score of forty-one or above.

Storage subcontractors and sealed container provisions

Storage facilities present distinct risk profiles depending on whether products are exposed or sealed. Under Clause 6.4.1.1(a) of the Group Standard, sites that only handle certified products in sealed containers are exempt from mandatory initial on-site internal audits. Guidance 6.4.1.1 explains that sealed boxes, cartons, or shrink-wrapped pallets eliminate physical substitution risks during transport and warehousing, provided the container seals remain unbroken throughout storage.

For external storage subcontractors, Clause 5.3 of the MSC Chain of Custody Certification Requirements v3.2 outlines when certification bodies must conduct on-site audits. Non-certified storage subcontractors handling sealed containers generally do not require on-site audits. However, an on-site audit is mandatory at least once during the three-year certificate validity if the storage subcontractor meets two specific risk triggers: location in a country with a Corruption Perception Index score below forty-one, and handling product part-processed by the client that is not yet in final consumer packaging.

Common management systems in group certification

In group certification structures, central office management controls determine how new sites are added to the certificate. Clause 6.2.3 of the Group Standard requires organisations to verify that any new site can conform to the standard before adding it. Under Clause 6.2.3.1(a), an internal on-site audit is not required prior to adding a new site if all sites operate under the control of a common management system maintained by the central office.

To qualify under Clause 6.2.3.1(a), the common management system must determine all parameters for seafood supply, traceability infrastructure, and staff operational procedures. The central office must demonstrate that standardised operating procedures, centralised purchasing, and unified training apply consistently across all sites. If these conditions are met, the central office may add new sites following administrative verification, avoiding pre-addition on-site audits while preserving total operational accountability.

What to do now

• Categorise every site and subcontractor in the certificate register by handling activity, physical exposure, and location.
• Formalise documented exemption rationales in internal audit records for all trading offices and sealed storage sites under Clause 6.4.1.1.
• Verify whether external storage subcontractors operate in countries with a Corruption Perception Index score below forty-one and handle part-processed seafood.
• Audit central management system controls to ensure unified purchasing, operational procedures, and traceability apply across all group sites under Clause 6.2.3.1(a).
• Ensure signed subcontractor agreements granting physical and record access are in place for all external storage and processing facilities.

Reference documents

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