Transferring MSC Chain of Custody Certificates Between CABs

Regulatory context and seamless transfer rationale

In commercial seafood supply chains, maintaining continuous Chain of Custody certification is vital to preserve commercial claims and market access. Quality managers, compliance leads, and internal auditors may need to change their accredited Conformity Assessment Body due to commercial preference, service changes, or a certification body losing its accreditation scope. The Marine Stewardship Council framework provides a structured transfer process to ensure that changing certification providers never creates an unintended gap in valid certification.

This regulatory framework affects single-site certificate holders, multi-site entities, and group certificate managers seeking to transition between third-party auditors. Under Section 4.11 of the MSC General Certification Requirements v2.6, both the current certification body and the succeeding certification body share formal obligations to exchange records and coordinate database updates. Understanding these mandatory transfer mechanics prevents accidental certificate cancellation, ensuring certified seafood remains fully eligible for sale throughout the transition.

Pre-transfer reviews, non-disclosure waivers, and risk evaluations

Under Clause 4.11.3 of the MSC General Certification Requirements v2.6, the certificate transfer process initiates when a client submits a transfer application to a succeeding certification body. For Chain of Custody clients, Clause 4.11.3(b) mandates that the succeeding certification body must secure a written non-disclosure agreement or data waiver from the client. This authorisation allows the succeeding auditor to request and review historical audit reports, outstanding non-conformities, and complaint records directly from the current certification body.

Following data collection, Clause 4.11.5 requires the succeeding certification body to conduct a formal pre-transfer review of the client's three-year audit history. Under Clause 4.11.8, the current certification body must provide all requested compliance records within ten days. Depending on the review outcome, Clause 4.11.9 allows the succeeding certification body to accept the transfer under the existing surveillance schedule, require a partial or full audit if risk factors or data gaps exist, or decline the transfer if integrity concerns remain unaddressed.

Database synchronisation and maintaining continuous certification

To protect client market access, Clause 4.11.12 dictates that both certification bodies and the client must formally agree on an exact transfer date when certification rights pass to the new provider. Under Clause 4.11.13, the succeeding certification body must notify the Marine Stewardship Council of this agreed transfer date at least ten calendar days in advance. Guidance 4.11.14.a explicitly warns current certification bodies never to cancel an active database certificate prior to the agreed transfer date, as premature cancellation instantly invalidates client claims.

On the agreed transfer date, Clause 4.11.14 requires the preceding certification body to cancel the existing database listing while ensuring all client records are fully updated. Concurrently, Clause 4.11.15 mandates that the succeeding certification body issue the new certificate on or before the agreed transfer date, guaranteeing zero gap in valid coverage. Furthermore, under Clause 4.11.16, the new certificate retains the original expiration date, while all open non-conformities and the existing surveillance schedule transfer directly to the new certification body.

What to do now

• Submit a formal transfer application to the succeeding certification body well in advance of scheduled surveillance or re-certification audits.
• Sign a written non-disclosure agreement waiver under Clause 4.11.3(b) to permit direct record transfer between the current and succeeding certification bodies.
• Verify that the current certification body transmits all three-year audit records and open non-conformity files within the mandatory ten-day window under Clause 4.11.8.
• Confirm that the succeeding certification body submits written notification of the agreed transfer date to the Marine Stewardship Council at least ten days in advance.
• Inspect the public scheme database on the agreed transfer date to confirm seamless cancellation and replacement certificate issuance without coverage gaps.

Reference documents

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