Guidance

Traceability and labelling information

Updated 19 November 2021

1. Who does traceability apply to?

As a fisher, buyer, seller, agent, transporter or keeper of fisheries products, it is your responsibility to ensure that fish is traceable from the point catching, through landing up until the point of retail sale.

All current labelling and traceability requirements will continue to apply following the end of the Transition Period.

In this guidance ‘Fisheries products’ or ‘fish’ includes fish and shellfish, a list of these is available at Regulation (EU) No 1379/2013 Annex1.

Fish sales beyond first sale must still be traceable back to the vessel through these and other regulations. Please see Defra guidelines on fish labelling for further details.

Fish or shellfish up to the value of 50 Euros sold from fishing vessels directly to consumers are excluded from traceability requirements.

Seafish have published guidance and an introduction for industry.

1.1 Traceability and the landing obligation

Traceability regulations apply to fish below the minimum conservation reference size (MCRS – also known as ‘undersize’) brought ashore in accordance with the landing obligation (‘discard ban’).

2. How must you ensure traceability

Fish must be traceable with details recorded, retained and submitted as required.

The information provided within these guidance documents details the minimum level of information required by the regulations. It is not intended to be prescriptive instructions about the methods which are expected to be put in place. It is for individual operators to decide exactly how to conform to the requirements. However, example approaches are described for each stage.

2.1 On Landing

All fisheries products must be identifiable to the vessel which landed it at any time.

After landing (‘post-landing’) this can be achieved by statutory documents accompanying the products such as:

• logsheet
• transport document (or landing declaration)
• takeover document

Once landed, fish must be identifiable to the vessel from which it originated; an example of a label template designed to help the fishing industry comply with EU regulations that seek to ensure traceability information on catches of fish are made available up to the first point of sale.

2.2 Post-landing

Before the first point of sale, fisheries products may move through a number of stages. To ensure traceability during this time, it is essential that the correct details are recorded and submitted throughout the chain.

The stages of the chain:

• landing
• weighing
• takeover
• transport
• first Sale of Fish (sales notes)

3. Information to be retained with the ‘lot’ post-landing.

To ensure that all fisheries products are traceable from catching or harvesting to the point of retail sale, minimum labelling and information must be present on or carried with all lots of fisheries products.

Prior to first sale, fisheries products may either be put into ‘lots’ and labelled, or packed using a code, barcode, electronic chip or other suitable method.

3.1 Definition of a ‘lot’

A ‘lot’ means a quantity of fisheries and aquaculture products of a given species of the same presentation and coming from the same relevant geographical area and the same fishing vessel, or group of fishing vessels, or the same aquaculture production unit. A fish box is an example of a ‘lot’.

Mixed quantities of less than 30 kg per species

Quantities of less than 30 kg per single species coming from the same management area from several fishing vessels may be put into lots by the Producer Organisation of which the operator of the fishing vessel is a member or by a registered buyer prior to the first sale.

Mixed fish below minimum conservation reference size

Quantities of fishery products of several species, consisting of individuals below the applicable minimum conservation reference size coming from the same relevant geographical area and the same fishing vessel, or group of fishing vessels, may be put into lots prior to the first sale. Detailed guidance on the Landing Obligation.

3.2 Minimum labelling requirements for a ‘lot’

The CMO Regulation, Control Regulation and the FIC Regulation require ‘lots’ of fisheries and aquaculture products to be traceable and to include minimum labelling requirements from the point of catching or harvesting all the way through to sale to the consumer, not just first sale. The information available prior to first sale must include as a minimum:

• identification number of each lot
• external identification number (PLN) and name of the fishing vessel or the name of the aquaculture production unit
• FAO alpha-3 code of each species, or commercial designation(common name) or scientific name
• date of catches or date of production
• quantities of each species in kilograms expressed in net weight or, where appropriate, the number of individuals
• if fish below minimum conservation reference size are present separate information on the quantities of each species in kilograms expressed in net weight, or the number of individuals;
• name and address of the suppliers
• relevant geographical (ICES) area
• production method (caught, farmed etc)
• category of fishing gear used (Beam trawl – TBB, Driftnet – GND etc)
• whether the fisheries products have been previously frozen or not

The above information can either be attached to the lot by way of an identification tool such as a code, barcode, electronic chip or similar device or marking system or by way of a physical document accompanying the lot but the lot must be labelled in such a way as to allow it to be matched with the document.

Operators must be able to identify the immediate supplier and the immediate buyer of any lot except if the sale is to the final consumer.

3.3 Effect of the Northern Ireland Protocol

Article 7(2) of the Northern Ireland Protocol requires goods produced in Northern Ireland to be labelled with the UK(NI) mark where EU rules require the indication of an EU Member State or third country. Guidance on health and identification marks that applies from 1 January 2021 has been published by the Food Standards Agency.

This requirement does not apply to goods produced in the rest of the UK which would need to be labelled according to the origin of those goods. The UK(NI) mark will be accepted on the EU and UK market. Where the indication of an EU Member State is not explicitly required by EU rules applicable to Northern Ireland, Northern Irish businesses will also be able to continue to use either the ‘origin EU’ or the ‘origin UK’ label.

For pre-packaged fish for sale on the Northern Ireland market, either a Northern Ireland or an EU address will be sufficient to meet the Food Business Operator (FBO) requirement under EU law applicable in Northern Ireland. If the FBO is not in Northern Ireland or EU, include the address of your importer, based in Northern Ireland or the EU.

For fisheries and aquaculture products, the above (origin and address provisions) only applies for Northern Ireland produced aquaculture products and Northern Ireland caught freshwater fish. Wild caught fish, as per the existing regulations, are required to indicate the FAO alpha-3 code of each species caught (amongst other minimum requirements).

The requirement for catch certificates for most movements of fish from Great Britain to Northern Ireland from 1 January 2021, will mean that certain sections of the minimum labelling requirements outlined in 1224/2009 will be met by the provision of those catch certificates and not need to be repeated on labelling attached to the ‘lots’. ‘Lots’ will, however, need to be identifiable to matching catch certificates (Article 67(7) of 404/2011), and other labelling requirements will still need to be met (e.g. Article 58(5)(g) of 1224/2009).

4. Second Sale fish

To ensure that all fisheries products are traceable from catching or harvesting to the point of retail sale, minimum labelling and information must be present on all lots of fisheries products after first sale.