Update to the MSC/ ASC Chain of Custody (CoC) Program and document releases

28 October 2022
On 26th of October 2022, the MSC released the new MSC Fisheries Standard, the MSC Labour Eligibility Requirements and various associated scheme documents.

This is a follow-up communication on updates relating to the MSC/ ASC CoC Program.

The following scheme documents are affected by the releases.

All CoC scheme documents can be found on the MSC website:

Overview of the changes
New MSC Labour Eligibility Requirements: The new MSC Labour Eligibility Requirements version 1.0 brings together all labour requirements across the MSC Fisheries and CoC programs into a single scheme document. The document publication follows consultation earlier in the year to extend existing requirements for 3rd party labour audits and self-assessment to CoC certification applicants, certificate holders and their subcontractors with packing, processing and manual offload in scope for all geographic locations, regardless of the country labour risk score.

The MSC Labour Eligibility Requirements v1.0 sets apart the following key elements:

  • No conviction for forced or child labour (Eligibility requirements for all MSC applicants and certificate holders)
  • Requirement to submit a forced and child labour policies statement (Additional eligibility requirements for at-sea CoC applicants and certificate holders)
  • Requirement to undertake a 3rd party labour audit or submit a self-assessment and allow MSC commission an audit if selected (Additional eligibility requirements for land-based CoC applicants and certificate holders).
For at-sea CoC applicants and certificate holders (e.g. fishing, transhipping vessels, and vessels with on-board processing), a new section for reporting forced or child labour convictions has been added to the existing 'MSC Certificate Holder Forced and Child Labour Policies, Practices and Measures Template' resulting in a new labour template – the MSC At Sea Labour Eligibility Requirements Reporting Template. The labour requirements for at-sea operations however remain unchanged.
For land-based CoC applicants and certificate holders, the labour requirements have been extended to all CoC certificate applicants, certificate holders and their use of subcontractors that manually off-load, pack and process certified products, regardless of geographical location and country labour risk score. Those with the specified activities in scope would be required to provide evidence of a valid 3rd party labour certification or submit a self-assessment of labour practices with a signed agreement to complete a labour audit where required by the MSC.

MSC Derogation 8: CoC Labour Eligibility Requirements outlines that all labour related requirements in the MSC CoC Standards, CoC Certification Requirements and Derogation 7: CoC Labour Audit Risk Revision are now superseded by the MSC Labour Eligibility Requirements v1.0.

The effective date for the MSC Labour Eligibility Requirements v1.0 is 01 May 2023. At the first audit of all CoC applicants and certificate holders (whether initial, surveillance or recertification audits) carried out on or after this date, are required to adhere to the MSC Labour Eligibility Requirements. There will be no grace period, and conformance must be demonstrated from this date to be eligible for a CoC audit and to maintain an existing CoC certification.

MSC General Certification Requirements and introduction of MSC Rules of Unacceptable Conduct: The MSC introduced new Rules on Unacceptable Conduct for MSC certificate holders (both fisheries and CoC) and adjustments to certificate holder data management. Sections 4.8 "Contract" and 7.4 "Suspension or withdrawal of certification" in the General Certification Requirements (GCR) v2.5 included new clauses relating to this and the introduction to the Labour Eligibility Requirements. Both sections' clause numbering has also been updated. GCR v2.5 becomes effective on 01 May 2023.

MSC-MSCI Vocabulary: A revised Vocabulary document has been published to reflect new terms and definitions added during the review process.

CoC Audit Checklist and Reporting Templates: The CoC Audit Checklist for all three Standard versions have been updated to incorporate updates to the Labour Eligibility Requirements, accredited CoC CAB name listing, and updates to the Seaweed requirements. The updated audit checklists facilitate on-going audits prior to MSC Supply Chain Audit Platform (SCAP) adoption in 2023.

Additional resources: Updated labour policy online training module for auditors, language translations of supporting documents and templates will become available in the coming month. Links to these will be shared in future CAB Updates.

UCSL Marine Program