Managing Inseparable or Practicably Inseparable Catches in MSC Audits

Understanding MSC IPI stocks rules and catch eligibility

Understanding MSC IPI stocks rules is vital for quality managers and compliance leads overseeing fisheries where non-target catches are mixed with target catches. Under the MSC Fisheries Standard and Fisheries Certification Process, inseparable or practicably inseparable (IPI) catches occur when non-target species are harvested alongside target species and cannot be practically or commercially separated during fishing operations. Quality leads can find comprehensive guidance on audit preparation in our MSC Fisheries reference articles.

The rationale behind these requirements is to allow defined and limited proportions of indistinguishable or unseparable non-target fish to enter certified Chains of Custody and carry the MSC ecolabel without compromising scheme credibility. At the same time, the rules create strong commercial incentives to improve the management of non-target stocks over time or adopt technical mechanisms for catch separation.

Under Clause 7.5.11 of the MSC Fisheries Certification Process version 2.3 and Clause 7.5.12 of version 3.0, Conformity Assessment Bodies must evaluate non-target Principle 2 catches to determine whether they meet strict IPI criteria. Inseparability arises under two specific operational scenarios. First, under sub-clause (a), the non-target catch is practicably indistinguishable from the target stock during normal fishing operations, such as closely related species that differ only by subtle biological features like caudal fin ray or gill raker counts. Second, under sub-clause (b), when the species are distinguishable, separating them is not commercially feasible because doing so would require significant modifications to existing harvesting and processing methods.

Core eligibility thresholds and screening criteria

To qualify for IPI recognition, non-target catches must pass four mandatory screening criteria set out in Clause 7.5.11.1 of version 2.3 and Clause 7.5.12.1 of version 3.0. Conformity Assessment Bodies evaluate these criteria against historical catch data to ensure that non-certified volume remains strictly bounded.

The total combined proportion of catches from all IPI stocks must not exceed 15 per cent by weight of the total combined target and IPI catches for the Unit of Assessment. When calculating this proportion, assessment teams evaluate catch composition variability over recent years, typically applying a five-year time series to account for natural fluctuations and production cycles. Furthermore, IPI status is strictly prohibited for any stock categorised as an Endangered, Threatened, or Protected (ETP) species, or an out-of-scope species under version 3.0, and cannot apply to stocks that are already certified separately under Principle 1.

For salmon fisheries, special allowances apply under Annex SC of MSC Fisheries Standard version 2.01 and Section SC5 of version 3.0. Under these normative sections, IPI salmon catches are restricted to a lower maximum limit of 5 per cent by weight, and may include non-local stocks of the same target species that do not breed within the Unit of Assessment.

Assessment pathways: the two-per-cent exemption versus full Annex PA

Once a Conformity Assessment Body confirms that a non-target catch meets basic IPI criteria, the certifier assigns the fishery to one of two distinct assessment pathways based on catch volume and stock risk. Quality managers preparing for fleet transitions should review our practical guide to transitioning to MSC Fisheries Standard v3.0.

The first pathway is the exemption pathway under Clause 7.5.13.2 of version 2.3 and Clause 7.5.14.2 of version 3.0. If the total proportion of IPI catch is less than or equal to 2 per cent by weight, and the certifier demonstrates that the Unit of Assessment does not have a significant impact on the IPI stock as a whole, the catches are granted an exemption from additional assessment requirements. The certifier submits an IPI announcement to the MSC database, allowing the product to enter Chain of Custody without setting mandatory conditions or applying Annex PA1.4.2.

The second pathway is the full Annex PA pathway, which applies when the IPI catch proportion is greater than 2 per cent but does not exceed 15 per cent. Under Clause 7.5.12 of version 2.3 and Clause 7.5.13 of version 3.0, the certifier must apply Annex PA in its entirety:

• Modify the default assessment tree under Clause PA1.2 to evaluate the IPI catch under the primary component of Principle 2.
• Separately assess all fishing activity impacts on the IPI stock under Clause PA1.4.2, verifying that the stock is likely above biologically based limits or the point of recruitment impairment, or that measures prevent fishing mortality from hindering rebuilding.
• Establish mandatory conditions under Clause PA1.3.1 to either promote future Principle 1 assessment of the IPI stock or promote the development of catch separation techniques.
• Limit the use of the MSC ecolabel on these catches to a maximum of one certification period of five years under Clause PA1.4.1.1.

Reassessment obligations and long-term compliance options

Because the Marine Stewardship Council restricts full Annex PA IPI eligibility to a single five-year certification period, quality leads must plan for reassessment long before the initial certificate expires. Under Clause PA1.6.1, a certifier cannot grant a second consecutive IPI allowance above 2 per cent at reassessment.

To maintain certification at the end of the five-year term, the fishery client must implement one of three compliance options defined under Clause PA1.6.1. The client may bring the IPI stock into full Principle 1 assessment during reassessment, develop physical or operational separation techniques so the catch is no longer inseparable, or implement management measures that reduce the IPI catch proportion to 2 per cent or less.

Example

During an initial assessment of a demersal trawl flatfish fishery, a Conformity Assessment Body identifies that 6 per cent of the landed catch consists of a closely related flounder species that cannot be visually distinguished from the target species on sorting belts. The certifier confirms the catch is not an ETP species and publishes an IPI announcement under Clause 7.5.12. Applying Annex PA, the assessment team evaluates the flounder stock under Principle 2, confirms it is above biologically based limits under Clause PA1.4.2, and grants Chain of Custody eligibility for the five-year certificate term. The certifier sets a mandatory condition under Clause PA1.3.1 requiring the fishery to prepare for a full Principle 1 assessment or implement optical sorting technology.

By Year 4 of the certification cycle, the fishery client collaborates with regional scientific institutes to conduct a full analytical stock assessment for the flounder species. At the reassessment audit, the certifier evaluates the flounder stock directly against Principle 1 Performance Indicators under Clause PA1.6.2. The stock achieves passing scores, successfully transitioning from an IPI catch to a fully certified Principle 1 target stock without any loss of Chain of Custody access.

Before your audit

• Review all non-target catches to identify any species that are visually indistinguishable or commercially unseparable from target stocks.
• Calculate the five-year average catch proportion of all candidate IPI stocks relative to total target plus IPI catch.
• Verify that no candidate IPI stock is listed as an ETP species, an out-of-scope species, or certified under another certificate.
• Confirm whether the IPI catch proportion falls at or below 2 per cent for the exemption pathway, or between 2 and 15 per cent.
• Collate stock status data demonstrating that IPI stocks are above biologically based limits or point of recruitment impairment.
• Verify that your Conformity Assessment Body has uploaded the MSC IPI Announcement Template to the scheme database.
• Review Client Action Plan milestones for open PA1.3.1 conditions to ensure progress towards Principle 1 assessment or separation.
• Prepare processing and landing flowcharts showing the exact point where IPI catches enter certified Chains of Custody.

Questions people ask

What are MSC IPI stocks rules?

MSC IPI stocks rules allow defined, limited proportions of non-target fish that are inseparable or practicably indistinguishable from target stocks to enter certified Chains of Custody under the MSC ecolabel for a limited time.

What is the maximum catch percentage allowed for an IPI stock in an MSC fishery?

The total combined proportion of all IPI stocks must not exceed 15 per cent by weight of the total combined target and IPI catches for the Unit of Assessment, or 5 per cent in salmon fisheries.

How does the 2 per cent IPI catch exemption work?

If the IPI catch proportion is 2 per cent or less and does not significantly impact the stock, the fishery receives an exemption from additional Annex PA assessment requirements and mandatory condition setting.

Can a fishery maintain IPI catch status across multiple five-year certification cycles?

No, IPI status above 2 per cent is permitted for a maximum of one 5-year certification period, after which the stock must be assessed under Principle 1, separated, or reduced to 2 per cent or less.

Reference documents

• MSC General Certification Requirements version 2.7
• MSC Fisheries Certification Process version 2.3
• MSC Fisheries Certification Process version 3.0
• MSC Fisheries Standard version 2.01
• MSC Fisheries Standard version 3.0