1. What is traceability, and why is it needed?

Traceability in relation to commercial fisheries, means having the ability to trace fish products from the catching or harvesting stage, right through to the point of retail sale. Traceability helps to evidence that fish are legally caught and fully reported, aiding fisheries authorities in the sustainable management of fish stocks. It is also a legal requirement under retained EU legislation that commercial fisheries products are fully traceable. All operators within the supply chain must be able to identify the immediate supplier and buyer of any fisheries products except when the sale is to the final consumer.

Labelling is crucial for traceability, as it ensures that essential information about the origin of the products stays with them throughout the supply chain.

A project undertaken by the MMO Evidence Team investigated the potential technologies available to help support traceability of fisheries products. You can read more on this here:  Fish traceability technology examined – Marine developments.

In this guidance, “Fish” and “Fisheries products” includes all fish, crustaceans, and shellfish. A full list of “Fisheries Products” is available within Annex 1 of Regulation 1379/2013^{[footnote 1]}. 

This guidance is not meant to provide specific instructions on the methods to be implemented. It is up to individual operators to determine how to meet the requirements.

2. Who do traceability and labelling requirements apply to?

As a fisher, buyer, seller, agent, transporter, exporter, or keeper of fisheries products, you are responsible for ensuring traceability and labelling requirements are met for all fish or fisheries products that are in your control. This includes any fish below the minimum conservation reference size (MCRS – also known as ‘undersize’) brought ashore in accordance with the Landing Obligation. 

Seafish^{[footnote 2]} have published guidance on seafood traceability and labelling which you may find useful.

2.1 Exemptions

Fish or shellfish sold directly to the final consumer from fishing vessels are exempt from traceability and labelling requirements, provided the value of each sale does not exceed £45 per person per day. However, where catches are to be transported or stored prior to sale, they should be labelled to ensure traceability throughout those stages.

3. What are the labelling requirements?

The Common Marketing Standards Regulation^{[footnote 3]} and the Control Regulation^{[footnote 4]} require all ‘lots’ of fisheries and aquaculture products placed on the market, or likely to be placed on the market, to be adequately labelled to ensure traceability. Minimum labelling and information requirements are specified within the regulations and must be followed to ensure products are traceable from the point of catching or harvesting until the product is sold to the final consumer, not just until the first sale.

Accurate labelling of catches prior to first sale ensures that essential information on the origin of the fish or fisheries products is passed onto the registered buyer/seller and can be correctly recorded in sales notes. When fisheries products are placed into lots, and no later than the first sale, operators should provide the minimum information as detailed in section 3.1 below.

The required information can either be attached to the lot in one of the following ways:

• by way of labelling or packaging of the lot, or
• by an identification tool such as a code, barcode, electronic chip, or similar device or marking system, or
• by 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 corresponding document.

This information must always be accessible by fisheries authorities, so consideration should be given to this when implementing electronic solutions.

3.1 Minimum labelling requirements

Minimum labelling and information requirements for each lot include:

• 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, or commercial designation (common name) or scientific name of each species
• 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 previously been frozen

In addition, to ensure the buyer/seller at first sale has all the required information to accurately complete and submit accurate sales notes, the following should be included on a label:

• Trip dates/date of landing
• Port of landing

3.2 Definition of a ‘lot’

A ‘lot’ means a quantity of fisheries and aquaculture products of a specific species, of the same presentation and originating 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 of a single species from the same management area from multiple fishing vessels may be combined into lots by: 

• the Producer Organisation of which the fishing vessel operator is a member, or
• by a registered buyer before 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 may be combined into lots before the first sale. This is permissible only if the catches come from the same relevant geographical area and the same fishing vessel, or group of fishing vessels.

4. How to ensure traceability and labelling requirements are met

To comply with traceability and labelling requirements, fisheries products must be traceable and labelled with the necessary information being displayed, recorded, retained, and submitted as required.

Before the first point of sale, fisheries products may move through several stages, including landing, weighing, transport, or storage. To ensure traceability during these stages, it is crucial that the correct details are recorded and passed along the chain. 

Individual operators are responsible for determining how to comply with the traceability and labelling requirements and should seek further advice from the MMO as required.

Examples of how traceability and labelling requirements may be met at each stage of the supply chain are detailed in the following sections. 

4.1 On landing 

All fisheries products must be traceable to the vessel which landed it at any time. Vessels must complete and submit information on their catches in their paper logbook, electronic logbook, or Catch Record in accordance with the Control Regulation4 and their Fishing Vessel Licence^{[footnote 5]}.

Upon landing, catches should be adequately labelled with key information about their provenance:

• Vessel name and PLN
• Species FAO code
• Quantity of each species (kg)
• Trip dates (including date of landing)
• Port of landing
• Sea area of capture (e.g. Area 7D)
• Fishing gear used

We have created label templates to assist the fishing industry to ensure traceability information on catches of fish is made available up to the first point of sale.

4.2 Post landing - Transport

When catches are transported away from the place of landing prior to first sale where no sales note or takeover declaration has been submitted, they must be accompanied by a transport document, and traceability and labelling requirements must be met.

See our guidance on transport documents, including what they must contain and printable templates here: Transport documentation - GOV.UK (www.gov.uk)

During transport, traceability and labelling requirements may be met through adequate labelling of the catch, or by carrying a document detailing all the necessary information. For instance: A completed landing declaration can meet traceability and labelling requirements if the fish boxes are labelled in such a way to link them to that document.

4.3 Post-landing – Storage

When fish and fisheries products are to be stored after landing before the first sale takes place, traceability and labelling requirements must be maintained during storage and a take-over declaration must be submitted.

See our guidance on Take-over declarations, including submission timelines and required contents, here: Takeover of fisheries products - GOV.UK

5. Second Sale fish

To ensure traceability from catching or harvesting to retail sale, minimum labelling and information must be available for all lots of fisheries products after the first sale.

6. Export

Catch certificates, which are needed to export catches to the EU, require the exporter to provide details on the origin of catches being exported, including details of the vessel, date of landing and species. As such it is important that the traceability information detailed within this guidance accompanies the fisheries products as they move through the supply chain so that the exporter has all the information they need to correctly complete a catch certificate.

The requirement for catch certificates also means that some minimum labelling requirements outlined above can be met by the provision of a catch certificate physically accompanying the lot. ‘Lots’ must be labelled in such a way that it can be matched with the catch certificate(s), however the remaining elements of the labelling requirements must still be fulfilled.

Additional labelling may be required for goods produced in Northern Ireland, guidance on which has been published by the Food Standards Agency^{[footnote 6]}.

7. Relevant Legislation and Useful Resources

Control Regulation Detailed Rules:  Commission Implementing Regulation (EU) No 404/2011 of 8 April 2011 laying down detailed rules for the implementation of the Council Regulation (EC) No 1224/2009