Defining UoA vs UoC: Scope Traps and Traceability at Landing

What the scope requirements are, and why they exist

Under Section 7.5 of MSC Fisheries Certification Process v2.3 and v3.0, Conformity Assessment Bodies must establish clear boundaries for the Unit of Assessment and the Unit of Certification before conducting a fishery evaluation. Clause 7.5.1 mandates that assessors use all available information in the MSC Client Document Checklist and pre-assessment reports to define these parameters. Correct definition prevents ambiguity regarding which vessels, gear types, target stocks, and fishing operators are subject to environmental scoring and eligible to sell certified seafood.

The distinction between assessment scope and certificate coverage exists to balance comprehensive environmental evaluation with flexible market access. While the Unit of Assessment evaluates the broader environmental impact of all fishing effort targeting a stock, the Unit of Certification defines the specific client entities entitled to market certified catch under the MSC ecolabel. Quality managers, compliance leads, and internal auditors must master these definitions to prevent scope non-conformities, manage certificate-sharing mechanisms with other eligible fishers, and enforce rigorous traceability controls at point of landing.

Distinguishing the Unit of Assessment from the Unit of Certification

Under clause 7.5.2, the Unit of Assessment encompasses the target stock or stocks, the fishing gear type or types and vessel types, and all fishing fleets, vessel groups, or individual operators pursuing that stock within a defined geographical area. Crucially, clause 7.5.2.c dictates that the Unit of Assessment must include any other eligible fishers operating outside the proposed Unit of Certification. Other eligible fishers represent entities targeting the same stock with identical gear who are not initial members of the client group but may share access to the certificate later through formal certificate-sharing arrangements under clause 7.5.11.

In contrast, clause 7.5.3 defines the Unit of Certification as the specific combination of target stock, gear type, vessel type, and fishing fleets or operators initially covered by the certificate. The Unit of Certification can never be larger than the Unit of Assessment. When the Unit of Assessment is broader than the Unit of Certification, clause 7.24.7.1 requires the assessor to publish a Fishery Certificate Statement on the MSC database specifying the exact entities eligible to access the certificate, the terms for certificate sharing, and the points of landing where certified sales occur.

Navigating operational scope traps and gear variations

Defining scope incorrectly creates severe audit roadblocks known as scope traps. Clause 7.5.4 strictly prohibits Conformity Assessment Bodies from defining a Unit of Assessment or Unit of Certification by a subset of activities undertaken with a stock and gear combination. For example, in a purse seine fishery, an applicant cannot limit the Unit of Assessment to free-school sets while excluding FAD-based sets using the same gear. The assessment team must evaluate all set types and operational variations associated with that gear configuration across the target stock.

Similarly, clause 7.5.5 prohibits defining scope based on species caught as determined at the time of fishing to exclude specific hauls or landings. Under Guidance G7.5.2.b and G7.5.3.b, physical gear configuration—rather than deployment method or target intent—determines gear classification. Combining multiple gear types or gear variations within a single Unit of Assessment is permitted, but Guidance G7.5.2.b warns that when multiple gears are scored together, the lower score determines the overall outcome for the Unit of Assessment.

• Collate all vessel registries, license categories, gear technical specifications, and historical landing locations in the MSC Client Document Checklist.
• Verify that target stocks meet biological unit stock criteria under Section 1 scope requirements and Figure SA3 species classification rules.
• Identify all operational variations within each gear type to ensure no set types or hauls are improperly excluded under clause 7.5.4.
• Establish whether non-client fleets target the same stock with identical gear to map all other eligible fishers under clause 7.5.11.
• Publish a clear certificate-sharing statement detailing equitable cost-allocation mechanisms for other eligible fishers seeking certificate entry.

Example

A tuna client group operates twenty longline vessels targeting albacore tuna and applies for MSC assessment. Ten vessels utilize deep-setting monofilament gear equipped with circle hooks, while ten vessels utilize shallow-setting gear equipped with J-hooks. The client group attempts to define the Unit of Assessment to cover only the ten deep-setting vessels, arguing that shallow-setting vessels catch higher proportions of sea turtles and should be excluded.

The assessment team rejects this scope definition under clause 7.5.4 and clause 7.5.5. The team explains that shallow and deep setting represent operational variations of the same longline fleet targeting the same stock. To proceed, the client must include all twenty vessels and both gear configurations in the Unit of Assessment. During scoring, the higher turtle interaction rates of the shallow-setting vessels result in a score of 65 on Indicator 2.3.1, triggering a mandatory condition of certification for the entire Unit of Assessment.

Managing traceability risks at point of landing and Chain of Custody boundaries

Demonstrating robust product tracking and tracing represents a core condition for certificate issuance. Under clause 7.17.1, the Conformity Assessment Body must determine whether the fishery client maintains sufficient tracking and tracing systems to ensure that all seafood sold as MSC certified originates strictly from the individual Unit of Certification. Clause 7.17.1.2 mandates that the client maintain detailed traceability records, such as logbooks and landing declarations, demonstrating product origin back to the Unit of Certification for at least two years.

Assessing traceability requires evaluating five primary risk factors under clause 7.5.9 and clause 7.5.10. Assessors must analyze the potential usage of non-certified gears within the Unit of Certification, vessels fishing outside certified geographic areas on the same or different trips, non-certified vessels fishing the same stock, high seas transhipment, and general substitution risks at landing or auction. Under clause 7.17.1.3, if high seas transhipment occurs, systems are deemed sufficient only if independently verified by third parties through 100 percent observer coverage or electronic monitoring.

Under clause 7.17.4.a, Chain of Custody certification is mandatory immediately following the first change of ownership to any party not covered by the fishery certificate. Furthermore, clause 7.17.4.b allows the assessor to require Chain of Custody certification prior to change of ownership if internal fishery tracking systems cannot guarantee product segregation. Clause 7.24.7.1 requires the Fishery Certificate Statement to specify all eligible landing points, auctions, sales agents, and the exact physical point where Chain of Custody certification begins.

Before your audit

• Verify that all target species, gear types, and vessel registries match the MSC Client Document Checklist.
• Confirm that no operational set types or hauls have been excluded from the Unit of Assessment scope.
• Audit logbooks and VMS records to ensure clear geographic boundary segregation during fishing trips.
• Establish documented procedures for segregating certified catch from non-certified catch on board and at landing.
• Draft a certificate-sharing statement if other eligible fishers are identified in the Unit of Assessment.
• Identify all points of landing, fish auctions, and sales agents intended to handle certified catch.
• Verify that high seas transhipment events, if present, carry 100 percent observer or electronic monitoring verification.
• Ensure traceability and catch origin records are retained for at least two years.

Questions people ask

What is the primary difference between a Unit of Assessment and a Unit of Certification?

The Unit of Assessment defines the full scope of what is evaluated by auditors, including target stocks, gear types, vessel fleets, and other eligible fishers. The Unit of Certification specifies the exact client group entities and vessels entitled to hold the certificate and sell certified catch under the MSC ecolabel.

Can a fishery exclude certain set types or hauls from its Unit of Assessment?

No, clause 7.5.4 strictly prohibits defining a Unit of Assessment or Unit of Certification by a subset of activities undertaken with a stock and gear combination. All set types, gear variations, and hauls associated with the gear configuration must be included in the assessment.

Who are other eligible fishers in an MSC assessment?

Other eligible fishers are non-client group entities targeting the same target stock with the same gear type within the defined Unit of Assessment. Under clause 7.5.11, these fishers may gain access to the fishery certificate later through formal certificate-sharing arrangements defined in the Fishery Certificate Statement.

At what point is Chain of Custody certification required for an MSC fishery?

Under clause 7.17.4.a, Chain of Custody certification is mandatory following the first change of ownership to any party not covered by the fishery certificate. Under clause 7.17.4.b, assessors may require Chain of Custody certification earlier if internal fishery traceability systems cannot guarantee segregation.

What evidence is required to verify high seas transhipment traceability?

Under clause 7.17.1.3, high seas transhipment systems are sufficient only if independently verified by third parties. The system must cover all fishing and receiving vessels across all transhipment events, typically requiring 100 percent observer coverage or electronic monitoring.

Reference documents

• MSC Fisheries Standard v2.01
• MSC Fisheries Standard v3.0
• MSC Fisheries Certification Process v2.3
• MSC Fisheries Certification Process v3.0
• MSC General Certification Requirements v2.7