Understanding the Pre-Transfer Review in MSC Certificate Transfers

What the pre-transfer review is, and why it exists

When an MSC fishery or Chain of Custody certificate holder decides to change its Conformity Assessment Body, the transition must occur without compromising the credibility or continuity of the certification. Under Section 4.11 of the MSC General Certification Requirements version 2.7, certification bodies are mandated to respect client requests to switch providers, whether prior to or after certificate issuance. To protect market integrity and ensure that unmitigated compliance risks are not transferred unexamined, Clause 4.11.5 requires the succeeding certification body to conduct a rigorous pre-transfer review of all historical assessment and audit data.

The pre-transfer review serves as an essential gatekeeping mechanism within the MSC certification system. It allows the incoming certification body to evaluate the authenticity, scope, and validity of the existing certificate, review the status of open conditions or non-conformities, and detect any underlying integrity issues such as unresolved complaints or conflicts of interest. By establishing objective criteria for evaluating incoming clients, the Marine Stewardship Council ensures that a transfer cannot be used to evade regulatory oversight or reset condition timelines.

Key elements evaluated during a pre-transfer review

The succeeding certification body must systematically collect and examine specific categories of operational and audit information before approving a certificate transfer. Under Clause 4.11.3 and Clause 4.11.4 of the MSC General Certification Requirements version 2.7, the incoming body coordinates with the client and preceding body to gather documentation covering the entire current certification cycle.

For Chain of Custody certificates, Clause 4.11.3.b requires a signed non-disclosure agreement waiver or formal agreement to ensure compliance with data protection laws, such as general data protection regulations. Under Guidance 4.11.5, a pre-transfer review for Chain of Custody is mandatory only if audit records exist within the preceding three years. The review evaluates core operational criteria specified under Clause 4.11.4.b, ranging from accreditation scope alignment to assurance body findings.

Procedure and timelines for executing a pre-transfer review

Executing a pre-transfer review involves strict multi-party coordination between the client, the succeeding certification body, and the preceding certification body. Clause 4.11.6 through Clause 4.11.15 set out the mandatory step-by-step transfer workflow.

• The client submits a formal transfer request, and the succeeding body records the application and reviews the client's reasons for changing certifiers.
• The succeeding body requests required audit reports and compliance data from the client or obtains written authorization to contact the preceding body.
• Upon receiving an information request under Clause 4.11.7, the preceding body must supply all requested certification data within ten days under Clause 4.11.8.
• The succeeding body evaluates the collected data, determines the transfer outcome under Clause 4.11.9, and presents its proposed action plan to the client for acceptance.
• Upon client acceptance, both certification bodies and the client agree on a formal transfer date under Clause 4.11.12.
• The succeeding body notifies the Marine Stewardship Council of the agreed transfer date at least ten days in advance under Clause 4.11.13.
• On the transfer date, the preceding body cancels the certificate in the scheme database, and the succeeding body issues the new certificate simultaneously to prevent any gap in coverage.

Pre-transfer review outcomes and risk-based audit pathways

Following the pre-transfer review, Clause 4.11.9 specifies four distinct operational outcomes available to the succeeding certification body based on the identified risk level. The certifier must explain its chosen path and rationale to the client under Clause 4.11.10.

If no compliance or traceability risks are identified, Clause 4.11.9.b.iii allows the succeeding body to accept the transfer and continue the client's existing surveillance schedule without additional audit activity. If minor information gaps or specific problem areas are detected, Clause 4.11.9.b.ii permits the certifier to conduct a targeted partial on-site or remote audit focused exclusively on those deficient areas.

Where major integrity issues or substantial systemic breakdowns are uncovered, Clause 4.11.9.b.i requires the succeeding body to treat the applicant as a new client and execute a full assessment or audit. Alternatively, under Clause 4.11.9.a, the succeeding body may decline the transfer entirely. If the existing certificate is currently suspended, Clause 4.11.9.b.iv mandates that all remaining suspension and corrective action obligations must be fulfilled under Section 7.4.

Under Clause 4.11.16, transferring a certificate does not alter core compliance obligations. The expiration date of the new certificate must match the original certificate's expiry date, all open conditions or non-conformities remain active, and the established surveillance schedule must be followed unless a documented justification is submitted to the Marine Stewardship Council.

Example

A certified whitefish processing facility applies to transfer its Chain of Custody certificate to a new certification body due to commercial preferences. During the pre-transfer review, the incoming auditor reviews the latest surveillance report provided by the client and notes an open minor non-conformity regarding mass balance record-keeping. The succeeding body requests complete audit working papers from the preceding body, which transmits the files within seven days under Clause 4.11.8.

The pre-transfer review concludes that the non-conformity is isolated and does not threaten supply chain integrity. Under Clause 4.11.9.b.ii, the succeeding body proposes accepting the transfer subject to a partial remote audit of the facility's updated mass balance log at the next scheduled surveillance. The client accepts the proposal under Clause 4.11.11, the parties establish a transfer date, and the new certificate is issued under Clause 4.11.15 without interrupting certified sales.

Before your audit

• Review your current certificate status and expiry date in the MSC scheme database.
• Sign a written non-disclosure agreement waiver to permit data sharing between certification bodies.
• Collate all recent assessment reports, surveillance findings, and open condition progress records.
• Document the specific commercial or operational reasons for requesting a certificate transfer.
• Confirm that your proposed succeeding certification body holds accreditation for your exact operational scope.
• Ensure all outstanding certification fees with the current certification body are settled to avoid administrative friction.
• Verify that the proposed transfer date allows at least ten days' advance notice to the Marine Stewardship Council.

Questions people ask

How long does a preceding CAB have to supply records during a certificate transfer?

Under Clause 4.11.8 of the MSC General Certification Requirements version 2.7, the preceding certification body must provide all requested information within ten days of receiving the request.

Does transferring an MSC certificate reset the five-year certification cycle or condition deadlines?

No, under Clause 4.11.16, the new certificate retains the original expiration date, and all existing conditions, non-conformities, and milestone deadlines remain fully applicable.

What happens if a client rejects the action plan proposed after a pre-transfer review?

Under Clause 4.11.11.b, if the client does not accept the succeeding body's proposed actions, the succeeding body must decline the transfer and notify both the client and current certifier.

Can a suspended MSC certificate be transferred to a new certification body?

Yes, under Clause 4.11.9.b.iv and Clause 4.11.17.d, a suspended certificate may be transferred, but the client must complete all remaining suspension and corrective action requirements under Section 7.4.

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