Carrying the blue MSC or green ASC label means every link in your supply chain can demonstrate where certified product came from, how it was kept separate, and where it went. We build the traceability, segregation, and record-keeping systems that make that chain provable.
Chain of Custody certification is what allows a business to buy, handle, process, or sell seafood carrying the blue MSC or green ASC ecolabel. It applies to every company that takes ownership of certified product on its way to the consumer, beyond the fishery or farm at the start of the chain.
The Marine Stewardship Council (MSC) certifies wild-capture fisheries against its Fisheries Standard, covering stock health, environmental impact, and management effectiveness. The Aquaculture Stewardship Council (ASC) runs the equivalent programme for responsibly farmed seafood. In both cases, the ecolabel on a product depends on an unbroken chain of Chain of Custody certified businesses, from the certified fishery or farm through every distributor, processor, and retailer, to the point of sale.
ASC Chain of Custody certificate holders are assessed against the same MSC Chain of Custody Standard, plus an additional module addressing aspects specific to farmed seafood, including food safety and antibiotic detection. A business handling both MSC wild-caught and ASC farmed product receives two separate certificates, one for each programme, built on the same underlying traceability and segregation requirements.
What makes Chain of Custody distinct from many other certifications is that it isn't really about your own processes in isolation, it's about your place in a chain. Your certification depends on your suppliers' certificates being valid and in scope, and your customers' ability to rely on your certification depends on your own records being complete. A gap anywhere in the chain breaks the claim for everyone downstream of it.
A Chain of Custody audit checks each of these in turn. Each one supports the others, a gap in any single component undermines the claim made by the label.
Confirming that every supplier of certified product holds a valid Chain of Custody certificate covering the relevant species and certification.
Certified product is clearly identified as certified at every stage: purchasing, receiving, storage, processing, packing, and sale.
Certified and non-certified product are kept physically or procedurally separate, eliminating the risk of mixing or substitution.
Records demonstrate that the volume of certified product leaving a site can be accounted for against the volume that entered it.
Documentation independently confirms certified status, so the chain doesn't rely on physical labelling alone if a label were missing or unclear.
Staff handling certified product understand the identification and segregation requirements relevant to their role.
Volume reconciliation is often where audits find the most unexpected gaps, not because businesses are doing anything wrong with the product itself, but because processing yield, trim, waste, and by-products change the relationship between input and output weight in ways that aren't always reflected in the records. A reconciliation system needs to account for that relationship explicitly, with a defined and documented yield factor, instead of relying on a simple one-to-one volume match that doesn't reflect what happens on the processing line.
Both MSC and ASC are revising their Chain of Custody requirements. Certificate holders should expect changes to how risk is assessed and what the ASC module covers, even if the core traceability principles remain the same.
The MSC's review of the Chain of Custody Standard proposes combining the three current versions, Default, Group, and Consumer Facing Organisations, into a single restructured standard. Alongside this, the risk assessment approach is being revised: risk categories are simplified to low, medium, and high, and this categorisation will now apply to all certificate holders, not only the Group and CFO models it previously covered. Higher-risk categorisation is expected to bring increased assurance activity, including unannounced audits and testing, so where a certificate holder lands in the revised risk model has practical consequences beyond paperwork.
The three current MSC Chain of Custody Standard versions are proposed to be combined into one document.
Standardised low/medium/high risk categorisation extends to certificate holders not previously assessed this way.
The ASC Chain of Custody Module is being renamed and expanded, with a stronger focus on social and human rights requirements.
For ASC certificate holders specifically, the revised module, renamed the ASC Supply Chain Module to reflect its scope beyond traceability, follows consultations run across 2025 and into 2026. The direction of travel is toward broader post-farm supply chain requirements, particularly around labour and social practices, in addition to the food safety and antibiotic detection requirements the module already covers for farmed seafood.
None of this changes the fundamental logic of Chain of Custody, identification, segregation, reconciliation, and record-keeping remain the core, but it does mean documentation written for the current standard versions may need updating once the revised standard is finalised, and certificate holders who haven't previously been risk-categorised should expect that to change. Reviewing current documentation against the direction of these proposals now reduces the work needed once the revised standard takes effect.
Chain of Custody certification is relevant to any business handling certified seafood, at any point between a certified fishery or farm and the consumer.
Importers, processors, distributors, or retailers wanting to handle or sell MSC or ASC labelled product for the first time.
Certified businesses whose documentation hasn't been reviewed against the proposed 2026 standard revisions.
Operations already certified for MSC wild-caught product that are expanding into ASC farmed product and need the additional module addressed.
Operations whose processing involves yield, trim, or by-products and whose reconciliation records don't currently reflect this.
Businesses with multiple sites handling certified product that need consistent identification, segregation, and record-keeping across all of them.
Operations integrating Chain of Custody requirements with existing HACCP, BRCGS, or other food safety management systems.
The process follows a defined sequence. Our part of the process typically takes 1 to 2 weeks.
| Stage | What happens | Our role | Duration |
|---|---|---|---|
| 1. Product flow mapping | Every point where certified product is received, stored, processed, packed, or sold is mapped. | We map the full product flow with your team. | 1 to 2 days |
| 2. Supplier certificate verification | Supplier Chain of Custody certificates are checked for validity and scope against the product being purchased. | We review and document the verification process. | 1 to 2 days |
| 3. Identification and segregation design | Systems for identifying and physically or procedurally segregating certified product are designed for each stage. | We design the identification and segregation system. | 2 to 3 days |
| 4. Volume reconciliation design | A reconciliation method reflecting processing yield, waste, and by-products is defined. | We design the volume reconciliation method and records. | 2 to 3 days |
| 5. Record-keeping system | Records are designed to independently confirm certified status throughout the chain. | We design the record-keeping templates and process. | 1 to 2 days |
| 6. ASC module alignment | For ASC certified product, additional food safety, antibiotic detection, and social requirements are addressed. | We align documentation with the ASC module requirements. | 1 to 2 days |
| 7. Staff training and rollout | Staff handling certified product are trained on identification, segregation, and record-keeping requirements. | We support documentation handover and rollout. | 1 to 2 weeks |
| 8. Certification audit | An accredited certification body conducts the Chain of Custody audit. | We support audit preparation and documentation walkthrough. | Our part of the process typically takes a few weeks. The certification body's timeline depends on their scheduling and is outside our control. |
We cover the full scope of Chain of Custody readiness, from first certification through to alignment with the revised standard.
A review of existing traceability, segregation, and record-keeping against the current MSC Chain of Custody Standard and ASC module where relevant.
Design of the full identification, segregation, reconciliation, and record-keeping system for businesses pursuing first-time certification.
Design of a reconciliation method that reflects processing yield, waste, and by-products, not a simple one-to-one volume match.
Design of a process for checking supplier Chain of Custody certificates for validity and scope at the point of purchase.
Alignment of documentation with the ASC Chain of Custody Module, including food safety, antibiotic detection, and social requirements.
Review of current documentation against the proposed MSC Chain of Custody Standard revisions and ASC Supply Chain Module changes.
Review of identification, segregation, and record-keeping practices across multiple sites handling certified product.
Integration of Chain of Custody requirements with existing HACCP, BRCGS, or other food safety management system documentation.
Training materials and documentation handover for staff responsible for identification, segregation, and record-keeping.
A Chain of Custody system depends on the people handling product day to day recognising what's certified, where it needs to go, and how it needs to be recorded. Training that builds genuine understanding of identification and segregation requirements, beyond a laminated sheet on the wall, is one of the most direct ways to keep a system audit-ready between certification cycles. We recommend pairing this consulting programme with relevant training delivered through Confi Food, and can advise on the right approach during the initial consultation.
Our gap assessment checks whether your system would hold up against the revised standard, beyond the one it was certified under.
The assessment reviews existing traceability, segregation, and record-keeping documentation against the current MSC Chain of Custody Standard and, where relevant, the ASC Chain of Custody Module, checking whether certified product is identifiable at every stage, whether segregation from non-certified product is consistently maintained in practice, whether volume reconciliation records reflect real processing yield and not a simplified assumption, and whether supplier certificates are verified for validity and scope at the point of purchase.
Where the proposed 2026 standard revisions are relevant to your certification, we flag where current documentation is likely to need updating once the revised standard and risk categorisation take effect.
We map current product flows and check identification at each stage.
We review segregation practices and reconciliation records against real processing yield.
We check whether supplier certificates are verified for validity and scope.
We produce a written gap assessment with a prioritised action plan.
If you're pursuing first-time certification, we can scope the gap assessment alongside the full readiness build, since both involve reviewing the same product flows and documentation.
The same gaps appear across Chain of Custody audits regardless of sector. Knowing where these gaps cluster is the most effective preparation.
Physical labelling identifies certified product, but records don't independently confirm certified status, leaving a gap if a label were ever missing or unclear.
Volume reconciliation assumes a simple one-to-one input-to-output match, not accounting for processing yield, trim, waste, or by-products.
Procedures describe segregated storage or processing, but in practice certified and non-certified product share space or equipment without a documented control.
Certified product is purchased without confirming the supplier's Chain of Custody certificate is valid and covers the relevant scope at the time of purchase.
Procedures reflect an earlier version of the Chain of Custody Standard and haven't been reviewed against current or proposed revisions.
For ASC certified product, the additional module requirements, food safety, antibiotic detection, social practices, aren't addressed with the same rigour as the core Chain of Custody requirements.
Understanding how the two programmes relate clarifies what's shared and what's additional for farmed seafood.
| MSC Chain of Custody | ASC Chain of Custody | |
|---|---|---|
| Underlying product | Wild-caught seafood | Responsibly farmed seafood |
| Core requirements | MSC Chain of Custody Standard | MSC Chain of Custody Standard + ASC module |
| Additional scope | None beyond the core standard | Food safety, antibiotic detection, social practices |
| Our consulting | MSC and ASC Chain of Custody Consulting: both programmes, one coordinated engagement | |
What drives the timeline and cost of a Chain of Custody consulting project. We provide a written proposal with a fixed fee after the initial consultation.
Timeline
How long our consulting work takes
Cost factors
What drives the consulting fee
No existing Chain of Custody system. Our consulting work, from scoping to documented system, typically takes 1 to 2 weeks.
Review of an existing system against current and proposed requirements. Typically 2 to 3 days.
Training and documentation handover, run alongside operations, typically 1 to 2 weeks.
More sites or more complex product flows require more mapping and design time.
Additional scope for businesses handling ASC certified product alongside or instead of MSC.
Processing involving significant yield, trim, or by-products requires more detailed reconciliation design.
Additional scope where Chain of Custody requirements need integrating with existing HACCP or GFSI scheme documentation.
A gap assessment only, a full readiness build, or ongoing review support each carry different fees. All scopes are defined in writing before work begins.
Answers to the questions we hear most often from businesses building or reviewing Chain of Custody certification.
MSC Chain of Custody certification is the certification that allows a business to buy, handle, process, or sell seafood carrying the blue Marine Stewardship Council ecolabel. Every company in the supply chain that takes ownership of a certified product and wants it to carry the MSC label, distributors, processors, wholesalers, retailers, and foodservice operators, must hold Chain of Custody certification. It confirms that certified products are identifiable, kept separate from non-certified products, and traceable back to an MSC-certified fishery through a documented chain of certified suppliers.
ASC Chain of Custody certification is the equivalent certification for the Aquaculture Stewardship Council label, used for responsibly farmed seafood and not wild-caught. ASC Chain of Custody certificate holders are assessed against the MSC Chain of Custody Standard, the same underlying traceability and segregation requirements, plus an additional module covering aspects specific to farmed seafood, including food safety and antibiotic detection. A company handling both wild-caught MSC product and farmed ASC product receives two separate certificates, one for each programme, though both build on the same Chain of Custody framework.
Any business that takes ownership of seafood it wants to sell with the MSC or ASC label needs Chain of Custody certification: importers, distributors, wholesalers, processors, pack houses, manufacturers, retailers, and catering or foodservice organisations. The requirement applies at every point in the supply chain where the product changes hands, not only at the final point of sale, since the certification exists to maintain an unbroken chain of certified handling from a certified fishery or farm through to the consumer-facing label.
The system needs to demonstrate that certified products are identified as certified at every stage, purchasing, receiving, storing, processing, packing, labelling, selling, and delivering, that they are physically or procedurally separated from non-certified product so the two cannot be mixed or substituted, and that volumes can be reconciled: the quantity of certified product purchased, processed, and sold must account for itself, so that more certified product cannot leave a site than entered it. Labelling alone is not sufficient. Associated records must independently confirm certified status if physical labelling were ever absent or unclear.
The MSC is running a review of its Chain of Custody Standard, with a public consultation on proposed changes that closed in mid-2026. The proposals include restructuring the three current versions of the standard, Default, Group, and Consumer Facing Organisations, into a single combined standard, and revising the risk assessment approach so that all certificate holders, not only Group and CFO models previously, are assessed and categorised as low, medium, or high risk using standardised criteria. The stated aims are to improve consistency for auditors and certificate holders, strengthen traceability and assurance, and help certificate holders demonstrate compliance with evolving traceability regulations more broadly.
The ASC Chain of Custody Module, which applied additional requirements such as food safety and antibiotic detection on top of the MSC Chain of Custody Standard for ASC certificate holders, is being revised and renamed the ASC Supply Chain Module to reflect a wider scope beyond traceability alone, including a stronger focus on human rights and social responsibility requirements across the post-farm supply chain. ASC ran a consultation on the revised module in 2026 following an earlier preliminary consultation in 2025. ASC certificate holders should expect the scope of post-traceability requirements, particularly around labour and social practices, to expand as this revision is finalised.
A Chain of Custody gap assessment reviews your existing traceability, segregation, and record-keeping systems against the current MSC Chain of Custody Standard and, where relevant, the ASC Chain of Custody Module, checking whether certified product is identifiable at every stage, whether segregation from non-certified product is consistently maintained, whether volume reconciliation records can demonstrate certified input matches certified output, and whether your documentation would withstand an unannounced audit, which is a feature of higher-risk categorisations under the revised risk assessment approach.
The most common gaps are: relying on physical labelling alone without records that independently confirm certified status. Volume reconciliation that doesn't account for processing yield, waste, or by-products, leaving discrepancies between certified input and output. Certified and non-certified product stored or processed in ways that create a risk of mixing, even where intent and procedures exist. Supplier certificates not checked for validity or scope at the point of purchase. Documentation written for the previous version of the standard that hasn't been updated to reflect revised risk categorisation or reporting requirements.
Chain of Custody certification depends on every supplier in the certified chain holding valid certification with the relevant scope, so verifying supplier Chain of Custody certificates, checking validity, scope, and expiry, is itself a supplier approval activity. For businesses with a broader supplier approval programme, MSC/ASC certificate verification can be built in as a defined check for any supplier providing certified seafood, not handled as a separate, disconnected process.
Our consulting work moves fast. For a business pursuing first-time certification, designing the traceability, segregation, and volume reconciliation systems and producing the supporting documentation typically takes 1 to 2 weeks, depending on the complexity of product flows and number of sites. For businesses with an existing certification needing review, particularly in light of the current standard revisions, a gap assessment typically takes 2 to 3 days. The certification audit itself is conducted by an accredited certification body and its scheduling is outside our control.
Yes. Traceability and segregation system design, volume reconciliation process design, documentation, and gap assessments are all available remotely, since they primarily involve reviewing product flows, supplier certificates, and record-keeping systems. We work with clients worldwide, including businesses preparing for their first MSC or ASC Chain of Custody audit and those reviewing existing certification against the revised standard.
You can commission any of these on their own, with an agreed scope and a written quote, without taking on ongoing consulting. See all food safety services.
Where the system design is the limitation.
Read about A traceability system assessment →To check what your supplier files evidence in practice.
Read about A supplier document review →Where visibility stops at the business that invoices you.
Read about A supply chain review →Tell us about your product flows, your current certification status, and which programmes, MSC, ASC, or both, you need to cover. We will tell you exactly where your system stands today.