ASC Programme Centre Beta

Feed Standard Interpretation

Criterion 2.1 – The UoC implements a Supplier Code of Conduct.

What is the intent of this Criterion?

The feed mill implements a Supplier Code of Conduct with its ingredient manufacturers and their supplying manufacturers to mitigate against socio-environmental risks.

How do I interpret the Requirements?

Supplier Code of Conduct:
Throughout the Interpretation Manual, this orange box with a magnifying glass indicates that the Criterion must be included in the feed mill’s Supplier Code of Conduct for their ingredient manufacturers (as per Indicators 2.1.3 and 2.1.4) as well as the ingredient manufacturer’s Supplier Code of Conduct for their suppliers (as per Indicator 2.1.8).The guidance and interpretation of the Criterion is to be followed by the feed mill’s ingredient manufacturers, as well as their suppliers, with the exception of any reporting requirements e.g., Indicator 1.21.2 calculation and reporting of energy consumption. The feed mill is not required to ask for evidence of implementation – that is addressed through the Due Diligence requirement (Indicator 2.2.5) for the most serious socio-environmental risks. 

Applicability of the Supplier Code of Conduct

Ingredient manufacturers who produce ingredients that represent >1% of the total annual ingredient-weight (volume) received by the feed mill for use in aquafeeds are required to meet the feed mill’s Supplier Code of Conduct. If the feed mill also produces livestock/poultry feed, the received volume is based on the ingredient volume destined for inclusion in aquafeed. Moving up the supply chain, the ingredient manufacturers’ suppliers (i.e., manufacturers of purchased feed materials) sign the ingredient manufacturers’ code of conduct. 

The requirements for a Supplier Code of Conduct do not apply for the following situations:

  • Non-producing suppliers to the feed mill or ingredient manufacturer e.g., traders, distributors, brokers, exporting agents
  • Ingredient manufacturers of feed additives e.g., premixes, vitamins, minerals, trace elements and colourants. 
  • Non-ingredient suppliers to the feed mill or ingredient manufacturer e.g., office materials, packaging materials, cleaning agents, non-ingredient service providers.

‘Effectively implement’ a Supplier Code of Conduct (2.1.1)

Effective implementation means that the Supplier Code of Conduct is a mandatory part of the sourcing process governed by the feed mill’s management system (Criterion 1.2).

Making the Supplier Code of Conduct ‘publicly available’ (2.1.2)

Making the Supplier Code of Conduct publicly available only applies to the feed mill’s code of conduct, not to codes of conduct of their ingredient manufacturers. 

Scope of Supplier Code of Conduct (2.1.4)

Note that the reference to Indicator 3.4.2 (product characteristics) means the following: If the feed mill discloses the presence of GMO to buyers of aquafeed as “may contain GMO”, then Indicator 3.4.2 can be excluded from the Supplier Code of Conduct. If, however, the feed mill discloses the presence of GMO to buyers of aquafeed as “does/does not contain GMO”, then Indicator 3.4.2 is included in the Supplier Code of Conduct to ensure necessary information provided down the supply chain is included in the feed mill’s disclosure.

Note that the reference to Indicator 3.4.3 (product characteristics) means the following: ingredient manufacturers and their suppliers inform buyers of aquafeed of active compound and inclusion levels of added antibiotics or other added medicinal feed additives, to ensure the necessary information is provided down the supply chain and can be included in the feed mill’s disclosure.

‘Discontinue purchases’ (2.1.5)

The feed mill discontinues purchases from ingredient manufacturers, and ingredient manufacturers from their suppliers, that do not meet the Supplier Code of Conduct. 

Examples of how the Supplier Code of Conduct is not met, could include:

  • the ingredient manufacturer has its own Code of Conduct which does not address all of the same requirements listed in Indicators 2.1.3 -2.1.8. 
  • the ingredient manufacturer has developed implementation measures to meet the requirements but has not implemented them according to an agreed timescale (see Indicator 2.1.6).
  • the ingredient manufacturer’s suppliers have not declared that they meet the Supplier Code of Conduct.

Timeline

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Figure 5: Illustration of how the code of conduct requirements apply along the supply chain, and implications for purchasing. 

The boxes outlined in green and red are examples of Code of Conduct declarations, leading to continued or discontinued purchasing.

Declaration (2.1.6)

The Supplier Code of Conduct is considered to be met if all requirements listed in 2.1.1 are fully met or measures have been implemented to ensure they will be met against a time-bound action plan (see Feed Standard Annex 7, figure 4, step 4).

If the ingredient manufacturer declares compliance against an equivalent Code of Conduct, which the feed mill has found to be equivalent through an own internal and documented benchmark, then this also complies with 2.1.6. The same applies to the ingredient manufacturer’s suppliers.

The declaration could be obtained either as a signed copy of the Supplier Code of Conduct, or by email acknowledgment, or through inclusion in a purchase contract with explicit reference to the Supplier Code of Conduct.

Ingredient manufacturer’s suppliers (2.1.8)

The feed mill verifies that its ingredient manufacturers have a Supplier Code of Conduct which includes the all the requirements within 2.1.1. and that they have a system in place to check that the Supplier Code of Conduct has been signed. For example, the ingredient manufacturer demonstrates its supplier approval process.

Auditing considerations

The auditor will verify that the Supplier Code of Conduct sent out to the ingredient manufacturers meets the requirements as described in Criterion 2.1 of the Standard. 

The auditor may ask the mill for their list of Ingredient Manufacturers (see also Indicator 2.2.2). The auditor can then use this information to sample a number of Supplier Code of Conduct documents to verify that the feed mill has identified and sent a copy of the Supplier Code of Conduct to each Ingredient Manufacturer on the list. They can also verify that a time-bound action plan has been submitted for any Indicators an ingredient manufacturer has declared they have not met.

The auditor could also query if there is there a process or procedure in place for the mill to follow up with ingredient manufacturers who have received but not returned the Supplier Code of Conduct. 

Another triangulation point could be, as part of the review of Eligible Ingredients in Principle 3 of the Standard, the auditor could request the Supplier Code of Conduct for the ingredient manufacturers for relevant supplied eligible ingredients. 

The auditor verifies that the feed mill has a process to check their ingredient manufacturers have passed on an equivalent set of requirements with the same intention to their suppliers.

Which Feed Standard Criterion does this apply to?

Criterion 2.2 – The UoC conducts Due Diligence on ingredient manufacturers and primary raw material production.

What is the intent of this Criterion?

The feed mill conducts Due Diligence on ingredient manufacturers and primary raw material production to identify and manage any serious socio-environmental risks.

Which RUoC sections need considering?

4.1 Feed mill staff competency requirements

4.2 Ingredient Approval Process

Annex C Competency Requirements

How do I interpret the Requirements?

Due Diligence Requirement:
Throughout the Interpretation Manual, this red box with a magnifying glass indicates that the Criterion also applies to the feed mill’s ingredient manufacturers (as per Indicator 2.2.5) and primary marine/plant raw material production (as per Indicator 2.2.6).

Who is subject to Due Diligence?

Ingredient manufacturers

Ingredient manufacturers who produce ingredients that represent >1% of the total annual ingredient-weight (volume) received by the Feed mill for use in aquafeeds are subject to Due Diligence. Due Diligence is not required for ingredients that represent ≤1% so that the burden on the Feed mill to assess a large number of associated supply chains is reduced and low quantities are likely to have a lower level of risk. If the Feed mill also produces livestock/poultry feed, the received volume is based on the ingredient volume destined for inclusion in aquafeed.This includes manufacturers of marine-based ingredients, plant-based ingredients and feed stuffs (e.g., land animal, algae, insects based). Ingredient manufacturers of feed additives are excluded from the requirement to perform a Due Diligence (e.g., premixes, vitamins, minerals, trace elements and colourants). Note that feed mills producing their own premixes are not required to conduct Due Diligence on feed materials sourced if they are used as carriers within the premix.

Ingredient manufacturer refers to the company/facility that is involved in the majority processing of the ingredient i.e., does not refer to pre-processing or repacking for example. Moving up the supply chain, the ingredient manufacturers’ suppliers e.g., pre-processors, are covered through the code of conduct (Criterion 2.1) as they sign the ingredient manufacturers’ code of conduct.

Primary raw material production

The production of plant or marine based primary raw material from agriculture or from fishing is also subject to Due Diligence. Primary raw materials have not been subjected to processing, and examples are: whole fish, krill, squid, soy, corn, wheat, rice, oil palm, rapeseed/canola, barley, rye, linseed, lupines, legumes, sunflower.

By-products derived from aquaculture and ingredients from by-catch retained under the EU landing obligation are excluded from primary raw material Due Diligence. The aim of the EU landing obligation is to eliminate discards by encouraging fishers to fish more selectively and to avoid unwanted catches. By-catch retained under the EU landing obligation is excluded from Due Diligence because fishmeal/fish oil will include this bycatch, and if documented correctly/legally, this fishmeal/fish oil will also contain red listed species, which without this exception would impact on the Due Diligence. To avoid a fishery failing the Due Diligence because it is complying with the landing obligation, this exception was added, so that auditors do not penalise fishmeal/fish oil which is correctly documented in terms of species content and is discouraging wasteful practices.

In the case of ingredients derived from algae, insects or land animals (e.g., omega 3 from microalgae, insect meal, feather meal, blood meal, bone meal, haemoglobin powder), Due Diligence only extends to the ingredient manufacturer – not to the primary raw material producer (e.g., livestock farm). Future versions of the Standard may require raw materials derived from livestock to be assessed.

Table 14: Example of where Due Diligence assessments occur

IngredientPrimary Raw MaterialIngredient Manufacturer DD required?Primary Raw Material DD required?
Fishmeal from whole fish (fishery)Whole fishYesYes
Fishmeal from trimmings (fishery)Whole fishYesYes
Fishmeal from trimmings (aquaculture)Whole fishYesNo
Fishmeal from EU by-catchWhole fishYesNo
Wheat glutenWheatYesYes
Soy lecithinSoyYesYes
Insect mealBlack Soldier FlyYesNo
Algae oilAlgaeYesNo
Poultry blood mealChickenYesNo
MineralsFeed AdditiveNoNo

List of ingredients (2.2.2, 2.2.3 and 2.2.4)

When determining the country(ies) and fishery(ies) of origin of primary raw material, the feed mill identifies where primary production or fishing occurs. For example, soy grown in Brazil and then processed in Argentina has Brazil as its country of origin for the primary raw material. The farm or cooperative where the primary raw material is produced is also listed if known. If the primary raw material is from multiple countries through one ingredient manufacturer, all countries of origin are listed.

Primary raw material is defined at a species level, not category level. For example, ‘whole fish’ is not sufficient and would need to be identified as e.g., Peruvian anchoveta (Engraulis ringens). Ingredients containing mixed species, e.g., fishmeal from trimmings, are accepted if all possible species are listed. Fisheries are identified using the FAO Fishing Area classification, including subarea and division.

Ingredients derived from algae, insects or land animals do not need to have the country of origin identified (this may change in future versions of the Standard). See the table below for an example of how a feed mill keeps an internal list of ingredients.

Table 15: Example internal listing of ingredients

IngredientName & contact of ingredient manufacturerPrimary Raw MaterialCountry or Fishery of Origin
Fishmeal from whole fish (fishery)John Smith
Big Fish
Company
Email/Phone 
Address/GPS
Website
Peruvian anchoveta (Engraulis ringens)FAO 87 Northern Border of the Peruvian EEZ to 16 ‘South
Fishmeal from trimmings (fishery)John Smith
Big Fish
Company
Email/Phone 
Address/GPS
Website
Atlantic herring (Clupea harengus)FAO 27.4 North Sea
Fishmeal from trimmings (aquaculture)John Smith
Big Fish
Company
Email/Phone 
Address/GPS
Website
Atlantic salmon (Salmo salar)Norway
Wheat glutenJane Brown
Plant
Company
Email/Phone 
Address/GPS
Website
Wheat (Triticum aestivum)Ukraine
Soy lecithinJane Brown
Plant
Company
Email/Phone 
Address/GPS
Website
Soy (Glycine max)BrazilArgentina
Insect mealSam Roberts
Bug Company
Email/Phone 
Address/GPS
Website
Black Soldier Fly (Hermetia illucens)N/A
Algae oilPaul Williams
Seaweed Company
Email/Phone 
Address/GPS
Website
Micro Algae (Schizochytrium sp.)N/A
Poultry blood mealHannah Jones
Animal Company
Email/Phone 
Address/GPS
Website
Whole poultry (Gallus gallus domesticus)N/A
PhosphatesN/AN/AN/A

What do better practices look like?
The feed mill keeps an internal list of the production origins of all ingredients if known. The feed mill also records additional production information, e.g., for marine ingredients: fishing vessels details, flag state fishing gear and landing port; farm name and location for ingredients derived from aquaculture.

If not known, the feed mill takes steps to determine production origins and/or further details. 

The next version of the ASC Feed Standard will likely require more traceability.

The feed mill publishes the list annually, without the ingredient manufacturer details, covering ingredients received throughout the previous year. For example, the list of ingredients received throughout 2021 is published at the end of 2022. This helps to safeguard corporate intelligence. 

For ingredients sourced from the start of the second certification cycle onwards, the feed mill includes the production region(s) within the country(ies) of primary raw material production for terrestrial plant-derived ingredients. Note that a certification cycle is 3 years. A region is a geographical area in which all farms that may be the source of a defined primary raw material are located. For example, wheat from Southern Ukraine or Kherson, Ukraine; soy from Central-west Brazil or Mato Grosso, Brazil. The feed mill defines the region and it will be the same as the defined region for the Due Diligence pathway 2 (if used).

A template is provided on the ASC website which illustrates the level of information which is to be published. Its use is optional for feed mills that have no own or better mechanism.

Ingredient manufacturer and primary raw material production Due Diligence (2.2.5 and 2.2.6)

In order to pass Due Diligence, all risk factors (as per table 1, Annex 3 of the Feed Standard) need to be ‘low risk’ which may mean using a combination of the pathways when conducting Due Diligence on an Ingredient Manufacturer or Primary Raw Material Production.

In exceptional cases, segregation of primary raw material does not occur down to the region, country or fishery level. In this case, all regions within a country/ all countries/ all fisheries of potential origin must be listed and covered by the Due Diligence. The resulting risk score is the highest risk of all.

Four different pathways can be selected to assess/determine the risk level, and the selection of pathway can have implications for traceability. The level of traceability required depends on the pathway used, for example, if country score cards are used, traceability goes down to the country level, or if the sector assessment is used traceability may go down to the/a group of primary raw material production. If a feed mill wants to source from a well-performing farm within a high-risk country (as per the country score card), and there is no third-party certified material available and the entire sector is experiencing issues, then traceability would need to extend down to the individual farm level.The pathways vary in their ease of implementation, direct cost of assessment and required competency level of those carrying out the Due Diligence.

Table 16: Comparison of the Due Diligence pathways

Pathway 1: Country Risk Score CardPathway 2: Industry/ Sector/ Fishery AssessmentPathway 3: Ingredient Manufacturer AssessmentPathway 4: Certification
Ease of implementation?Easy – reading scoresMore difficult – requires collecting & reviewing evidenceMore difficult – requires collecting & reviewing evidenceEasy – reading list of accepted schemes
Direct cost associated with assessment?NoYes – time and potentially outsourcing to consultant Yes – time and potentially outsourcing to consultantYes – sourcing certified material
Specific competency level required?NoYesYesNo

When is the Due Diligence assessment to be repeated?

As described in Feed Standard Annex 3, the DD assessment is repeated when:

  • monitoring indicates a different risk level than previously determined,
  • monitoring indicates that measures implemented are not effective, 
  • significant changes occur, which could affect the risk level previously determined, 
  • in all cases, at least every certification cycle (3 years). 

Pathway 1: Country Score Cards 

The link to the country score card can be found here. If a primary raw material is produced in, or an ingredient manufacturer is located in a country with all risk factors categorised as ‘low risk’ then Due Diligence has been passed. However, further Due Diligence is required under a different pathway for any risk factor not determined to be ‘low risk’. 

If using the country score card to assess an Ingredient Manufacturer, the feed mill applies the country in which the ingredient manufacturer is based. For assessing Plant-based Primary Raw Material Production, it is the country in which the plant was produced/grown. For assessing Marine-based Primary Raw Material Production, the country scope to be applied depends on whether the Flag State of the species caught is known (see the Country Score Cards for further detail).

The methodology behind the country score card can be found here.

Pathway 2: Sub-national/sectoral assessment (for plant-based primary raw material production) / Industry/sector assessment (for ingredient manufacturer)/ Fishery assessment (for marine-based primary raw material production)

  1. Supply Chain Mapping

The feed mill maps its relevant supply chains as far back as possible by requesting information from ingredient manufacturers on their own suppliers via self-assessment questionnaires, document review and gathering data from procurement or technical employees.

What do better practices look like?
Although it may not be possible for the feed mill to map out every supply chain to the primary raw material level, it is encouraged to do so to meet potential future obligations under the proposed EU Deforestation Regulation for soy and palm oil, as well as other Due Diligence regulation. Future versions of this standard will likely require more in-depth risk assessments to be carried out and a corresponding level of traceability demonstrated.

  1. Assessing the risk
    1. For ingredient manufacturers and/or plant-based primary raw material production

The feed mill conducts the assessment of the risk factor(s) in a successive manner, beginning with a high-level analysis and moving to more granular assessments where warranted based on the initial findings i.e., if low risk cannot be determined at a broader scale. In parallel, traceability processes also move towards finer-scale information (i.e., tracing to specific supply units, closer to origin) when risk assessments indicate that this may be necessary to demonstrate low risk for individual primary raw material production in a higher risk sector. 

For example, the high-level analysis may indicate that an ingredient manufacturer or farm is high risk for forced labour due to the prevalence of vulnerable migrant workers in the country and sector. However, the ingredient manufacturer or farm may not employ any migrant workers at all, or it may have robust processes for recruiting and supporting migrant workers.

See the table below for the example escalating level of traceability.

Table 17: Example escalating level of traceability.

Subject of AssessmentType of assessmentLevel of traceability(start at level 1 and if low risk cannot be determined then proceed through the levels as needed)Example evidence
Ingredient manufacturerIndustry/sectorManufacturer of same ingredient/ingredient type within a country e.g., soymeal manufacturers within Argentina.3rd party report (published within the past 5 years) which addresses the risk factor under assessment.
Industry association (if ingredient manufacturer is a member) e.g., ABIOVE, the Brazilian Association of Vegetable Oil Industries.Membership of the association requires evidence of mitigating against the risk factor under assessment e.g., having polices in place, being audited, regular reporting, etc.
Ingredient Manufacturer See Pathway 3.
Plant-based primary raw material productionSub-national/ sectoral Raw material sector within a region e.g., soy from Mato Grosso, Brazil.3rd party report (published within the past 5 years) which addresses the risk factor under assessment.
Groups of production units located in close geographic proximity and under common management.Auditing and reporting requirements for members, GIS data, interviews with employees, etc. which address the risk factor under assessment.
Production units, i.e., farms, plantations, farmer groups.Site visits, interviews with employees, GIS data, etc. which address the risk factor under assessment

A high-level analysis (level 1 traceability in the table above) of the risk factors is conducted through desk-based methodology that uses existing risk screening tools and other secondary sources of data. A granular risk assessment (level 2+ traceability in the table above) of the risk factors is a more detailed analysis that utilises additional secondary and primary sources of data about the sourcing area/industry, is based on more precise location and boundary data for suppliers, and/or considers other supplier characteristics that may affect risk levels. Additional data may be obtained through interviews with stakeholders and other subject matter experts, as well as with employees of the ingredient manufacturer/production unit. Due Diligence which involves granular risk assessments using primary data sources is conducted by individuals (can be internal staff or external consultants) who meet the competency requirements listed in Annex C of the RUoC. Individuals using published reports do not need to meet the competency requirements listed in Annex C.

The tables below provide further recommended Indicators of low risk and suggested sources and processes to assess the risk factors.

Table 18: Indicators of low risk for legal and environmental risk factors of plant-based primary raw material

Risk FactorIndicator of low risk Suggested sources and processes to assess risk
The risk that primary raw material originates from areas affected by poor regulatory oversight resulting in systematic violations of land use or environmental laws and regulation within the plant-based primary raw material production.The farm is located in an area where standards of forest and land use governance and law enforcement are strong.Assessments of the status of governance and law enforcement in the source region
The farm is located in an area where Indigenous rights are enforced, and land tenure rights are clearly definedAssessments of the status of Indigenous rights and land tenure in the source region, e.g., LandMark map, implementation of Voluntary Guidelines on the Responsible Governance of Tenure (VGGT) through LandPortal
The risk that primary raw material originates from areas resulted from illegal deforestation/conversion.The farm is located in an area with a low rate/ incidence of illegal deforestation and/or land conversion.Remote sensing (e.g., satellite or radar) data, Deforestation alertsFAO Forest Resources Assessment seriesIndependent or community forest monitors.Local communities, Indigenous Peoples and civil society organisations Country or landscape risk assessments.Information collected through grievance mechanisms

Sources: OECD-FAO Guidance for Responsible Agricultural Supply Chains (2016);

Table 19: Indicators of low risk for legal and environmental risk factors of ingredient manufacturers

Risk FactorIndicator of low riskSuggested sources and processes to assess risk
The risk that the ingredient manufacturer does not meet the following Indicator:1.1.1 legal licenses and permits, by operating in an area affected by poor regulatory oversight resulting in systematic violations of laws and regulation.The ingredient manufacturer is located in an area where governance and law enforcement are strong.Assessments of the status of governance and law enforcement in the source region.
The risk that the ingredient manufacturer does not meet the following Criteria:1.17 appl. environmental regulations1.18 water use1.19 waste handling1.20 effluent handling
The ingredient manufacturer measures and manages its water use, waste and effluent handling.Document reviewSite visitInterviews with key stakeholders/employees.
The risk that the ingredient manufacturer does not meet the following Indicators:3.4.2 GMO disclosure3.4.3 disclosure of medicinal additivesThe ingredient manufacturer discloses the presence of GMO and medicinal additives to all buyers of the product.Document reviewSite visitInterviews with key stakeholders/employees.

Table 20: Indicators of low risk for social risk factors of plant-based primary raw material and ingredient manufacturers

Risk FactorIndicator of low riskSuggested sources and processes to assess risk
The risk that primary raw material is produced using forced labour or worst forms of child labour.
The risk that the ingredient manufacturer does not meet the following Criteria:1.3 appl. labour regulations1.4 forced labour1.5 children and young workers
The farm/ingredient manufacturer is located in a country which has ratified the ILO fundamental conventions and has a strong record of implementation.ILO’s NORMLEX website on country ratification and supervision.
The farm/ingredient manufacturer is located in a country which does not have prison labour policies and programmes.Country research
The farm/ingredient manufacturer is located in a country which does not have state-orchestrated programmes including but not limited to: mass mobilisation for large-scale national development programmes (particularly in centrally-planned economies).labour and/or vocational programmes targeted at persons belonging to minorities (e.g., ethnic or religious).Country research
The farm/ingredient manufacturer is not located in an area with limited access to schools.Area research Interviews with key stakeholders/employees.
The farm/ingredient manufacturer does not employ migrant workers, particularly irregular migrant workers.Document reviewSite visitInterviews with key stakeholders/employees.
The farm/ingredient manufacturer does not recruit employees via third parties, including government recruiters. Document reviewSite visitInterviews with key stakeholders/employees.
The farm/ingredient manufacturer does not charge recruitment fees.Document reviewSite visitInterviews with key stakeholders/employees.
The farm/ingredient manufacturer does not have credit-arrangements and debt schemes for employees.Document reviewSite visitInterviews with key stakeholders/employees.
The farm/ingredient manufacturer does not provide family accommodation onsite.Document reviewSite visitInterviews with key stakeholders/employees.
The farm/ingredient manufacturer does not employ workers under age 18.Document reviewSite visitInterviews with key stakeholders/employees.
The risk that the ingredient manufacturer does not meet the following Criteria:1.6 discriminationThe ingredient manufacturer has effective communication, procedures, and monitoring in place to ensure harassment, abusive or exploitative behaviour does not occur in the workplace.Document reviewSite visitInterviews with key stakeholders/employees.
The risk that the ingredient manufacturer does not meet the following Criteria:1.13 grievance mechanismThe ingredient manufacturer has an effective grievance mechanism in place.Document reviewSite visitInterviews with key stakeholders/employees.

Sources: OECD-FAO Guidance for Responsible Agricultural Supply Chains (2016); Guidance on Due Diligence for EU businesses to address the risk of forced labour in their operations and supply chains (2021)

  1. For marine-based primary raw material production

Due to the complexity of marine ingredient supply chains and the lack of publicly available data and sector reports, the risk assessment process is different to that of ingredient manufacturers and plant ingredient supply chains. 

For whole fish derived ingredients, the feed mill conducts an assessment of the risk factors(s) by following the recommendations to determine low risk within Section 4 (Fisheries and fishing operations) of PAS 1550:2017 ‘Exercising Due Diligence in establishing the legal origin of seafood products and marine ingredients – Importing and processing – Code of practice. The table below specifies which PAS 1550:2017 sections relate to which risk factor. This fishery assessment is conducted by individuals who meet the competency requirements listed in Annex C of the RUoC.

Table 21: Fishery assessment for risk factors of whole fish derived marine ingredients

Risk FactorPAS 1550:2017 Section(s) 
Legal: The risk that primary raw material originates from areas affected by poor regulatory oversight resulting in systematic illegal fishing within the fishery.4.2 Fisheries access control4.3 Monitoring, control and surveillance4.4 Source fishing vessels4.5 Transhipment4.6 Landing at port (4.6.1 and 4.6.2)
Social: The risk that primary raw material is produced using forced labour or worst forms of child labour.4.2 Fisheries access control4.4 Source fishing vessels4.5 Transhipment4.6 Landing at port (4.6.3)4.7 Decent working conditions in the fishing sector
Environmental: The risk that primary raw material originates from unreported or unregulated fishing. The risk that primary raw material originates from species that are IUCN endangered or critically endangered species.The risk that primary raw material originates from species caught that appear in the CITES appendices.4.1 Management of fisheries4.2 Fisheries access control4.3 Monitoring, control and surveillance4.4 Source fishing vessels4.5 Transhipment4.6 Landing at port (4.6.1 and 4.6.2)

For marine by-product ingredients, the feed mill conducts the assessment of all the risk factors by following, at a minimum, the recommended Indicators of low risk as shown in the table below. Note that as the prevalence of IUU fishing is a proxy for labour issues and the fishing of endangered species, all risk factors are assessed together.

Table 22: Fishery assessment for risk factors of by-product derived marine ingredients

Indicator of low risk
The coastal state EEZ, FAO Area or RFMO where the fish was caught is known.
The coastal state EEZ or RFMO where the fish was caught maintains a register of authorised vessels.
The coastal state EEZ or RFMO where the fish was caught issues licenses in a transparent manner i.e., the application process is published and the list of all licensed vessels is publicly available on a website.
The coastal state EEZ or RFMO where the fish was caught has fishing quotas and other seasonal, temporal or technical catch restrictions that are publicly available on a website.
The coastal state EEZ or RFMO where the fish was caught operates sanctions on fishing vessels for IUU fishing or illegal labour practices that are published on a publicly available website.
The coastal state EEZ or RFMO where the fish was caught applies sanctions to fishing vessels that are sufficient to deter IUU fishing and illegal labour practices i.e., fines are at least five times the value of the catch caught by the vessel during the period IUU activity took place.
The coastal state EEZ where the fish was caught cooperates with other states in the region as well with as flag and port states involved in the catch and distribution of seafood products caught in the coastal states’ territorial or EEZ waters i.e., that at a minimum, coastal states make known to the above parties named officials who are responsible for coastal state fisheries duties and that any requests for information from the above parties receive a full and accurate reply within 10 working days; and either physically inspect crew conditions on fishing vessels to verify that conditions for crew meet the standards established by coastal state law or have a published and defined system whereby they place reliance on particular flag states to do so in the case of distant water vessels that are unlikely to call at port in the coastal state.
The coastal state EEZ where the fish was caught is neither ‘pre-identified’ as non-cooperating (‘yellow card’), ‘identified’ as non-cooperating (‘red card’) or ‘listed’ by the European Union.
The coastal state EEZ where the fish was caught is neither identified nor certified by the USA’s National Marine Fisheries Service (NMFS) as being responsible for vessels engaged in IUU fishing.

What do better practices look like?
ASC recognises for marine by-products it is difficult to obtain information on the landing port and vessel(s) involved. However, as technology improves visibility along the supply chain, mills can increasingly ask their suppliers to provide this information to assess against the risk factors using a more in-depth risk assessment as is used for whole-fish ingredients.

  1. Implement appropriate measures

If the outcome of the risk assessment does not determine low risk, the ingredient cannot be sourced until low risk is determined. The feed mill implements measures, such as:

  • prevention 
  • mitigation
  • remediation
  • cease sourcing, however, where possible mitigation is preferred over the discontinuation of sourcing. 

During the initial audit, the feed mill demonstrates that it has begun to implement measures, however, monitoring (as per Step 4) is not yet required.

  1. Implement a monitoring program

The feed mill implements a monitoring program to:

  • monitor the risk factors, or Indicators for the risk factors, to ensure the risk level determined remains valid;
  • monitor the effectiveness of measures implemented.

Pathway 3: Ingredient Manufacturer assessments:

The feed mill works with the ingredient manufacturer to demonstrate that the ingredient manufacturer, marine or plant-based primary raw material has a low risk for the Risk Factors detailed in Table 1, Annex 3 of the Feed Standard. 

  1. Supply Chain Mapping

As with Pathway 2, the feed mill maps its relevant supply chains as far back as possible by requesting information from ingredient manufacturers on their own suppliers via self-assessment questionnaires, document review and gathering data from procurement or technical employees.

  1. Assessing the Risk

For the ingredient manufacturer risk factors, the feed mill assesses the ingredient manufacturer by requesting and reviewing the same or similar evidence the feed mill must provide when audited against the equivalent Feed Standard Indicators/Criterion. It could do this through contractual or purchasing agreements, product specifications, or supplier questionnaires.

Table 23: Example evidence used to assess ingredient manufacturer risk factors under Pathway 3

Risk FactorExample evidence to be reviewed by feed mill
Legal: The risk that the ingredient manufacturer does not meet the following Indicator: 1.1.1 legal licenses and permits, by operating in an area affected by poor regulatory oversight resulting in systematic violations of laws and regulation.Business licenseFactory license
Social: The risk that the ingredient manufacturer does not meet the following Criteria:1.3 appl. labour regulations, 1.4 forced labour, 1.5 children and young workers, 1.6 discrimination, and 1.13 grievance mechanism.Company policies, procedures and work instructions related to labour.age verification systemevidence of risk assessment for children/young employeespolicies, procedures and records related to the recruitment processemployee contractsanti-harassment policygrievance procedure
Environmental: The risk that the ingredient manufacturer does not meet the following Criteria:1.17 appl. environmental regulations, 1.18 water use, 1.19 waste handling, and 1.20 effluent handling.And Indicators: 3.4.2 GMO disclosure, and 3.4.3 disclosure of medicinal additives.Company policies, procedures and work instructions related to environmental operations.Disclosure statements

The risk factors GMO and Medicinal Additives

Note that Indicators 3.4.2 GMO disclosure and 3.4.3 disclosure of medicinal additives are listed as environmental risk factors so that countries, companies and people can make their own choice about potential impact.

For marine and plant-based primary raw material production risk factors, the ingredient manufacturer demonstrates to the mill it has an appropriate system or sufficient information to ensure low risk at the raw material production level. 

Elements of ingredient manufacturer management and control systems that are reviewed include: 

  • risk assessments;
  • supply chain mapping and traceability activities and status;
  • procedures for identifying and addressing non-compliance, including grievances lodged and their status;
  • activities related to responsible land acquisition and development practices, including impact assessments and the use of Free, Prior and Informed Consent (FPIC) when appropriate;
  • monitoring, verification, and reporting systems—including appropriate tools, methods, and data sources—that are able to assess and communicate impacts and outcomes of their operations and supply chain.

(This list above is taken from AFi guidance)

  1. Implement appropriate measures

If the outcome of the risk assessment does not determine low risk, the ingredient cannot be sourced until low risk is determined. The feed mill implements measures, implemented into a time-bound action plan, such as:

  • prevention 
  • mitigation
  • remediation
  • cease sourcing, however, where possible mitigation is preferred over the discontinuation of sourcing. 

During the initial audit, the feed mill demonstrates that it has begun to implement measures, however, monitoring (as per Step 4) is not yet required.

  1. Implement a monitoring program

The feed mill implements a monitoring program to:

  • monitor the risk factors, or Indicators for the risk factors, to ensure the risk level determined remains valid;
  • monitor the effectiveness of measures implemented.

Pathway 4: Certification 

The link to the list of accepted certification schemes can be found here. If a primary raw material or an ingredient manufacturer is certified under one of the accepted schemes with all risk factors categorised as ‘low risk’ then Due Diligence has been passed. However, further Due Diligence is required under a different pathway for any risk factor not determined to be ‘low risk’.

Note that for certified primary raw material, only Identity Preserved, Segregated and Mass Balance production/traceability chain of custody models are accepted. Certificate trading models e.g., credits, book and claim, are not accepted. Corresponding Chain of Custody certification must also be present and verified throughout the supply chain.

Purchasing raw materials certified or approved to the list of accepted certification schemes does not necessarily entitle the feed mill to make any claims relating to those standards. Feed mills wishing to make claims should contact the scheme owner for further information on their requirements.

The endangered species risk factors (marine-based primary raw material)

For certified marine-based primary raw material production, the feed mill can compare the species listed on the catch certificate against the IUCN Red List and CITES Appendix I, II, III List to demonstrate low risk for the two environmental risk factors relating to endangered species.

System to ensure low risk sourcing (2.2.8 and 2.2.9)

The feed mill does not source from supply chains where the outcome of the ASC required Due Diligence on the ingredient manufacturer and the primary raw material production indicates medium or high risk, as these are considered non-permitted ingredients. Note that non-permitted ingredients are not allowed in any aquafeeds but can be used in non-aquafeeds.

Due Diligence and Pathways Report (2.2.10)

Feed mills use the template provided on the ASC website to annually report to ASC an overview of the outcome of the Due Diligences carried out and the respective pathways chosen. 

Sectoral/fishery Assessment or Ingredient Manufacturer Assessment Summary Report (2.2.11)

In all cases where the pathways “sectoral/fishery assessment” or “ingredient manufacturer assessment” are chosen, the feed mill publishes and shares with ASC an up-to-date summary report using the template provided on the ASC website.

Auditing considerations

The auditor will verify the that the feed mill maintains a list of ingredients as per the Standard Requirements and relevant information is published. The auditor will also verify that the reporting requirements to ASC have been completed.

The auditor refers to the Due Diligence Sampling Calculator to determine how many DD assessment reports to sample from each pathway. For each report sampled, the auditor verifies the following:

  1. That the fishery of origin (if applicable) is as determined by the feed mill as per the following process:
    1. Review all available traceability documents, for example: bills of lading, invoices, delivery notes, health certificates/veterinary checks, catch certificates, purchase orders, and packing list/loading records for every change of ownership;
    2. If the raw material is sourced from a certified or scheme approved fishery, then in place of point a), the auditor verifies the validity of all certificates of certified organisations in the supply chain that legally owned the certified products from the fishery to the mill (i.e., verify the Chain of Custody is maintained). 
  2. That the country/region of origin (if applicable) is as determined by the feed mill as per the following process:
    1. Review all available traceability documents, for example: bills of lading, invoices, delivery notes, purchase orders, and packing list/loading records for every change of ownership;
    2. If the raw material is sourced from a certified or scheme approved farm(s), then in place of point a), the auditor verifies the validity of all certificates of certified organisations in the supply chain that legally owned the certified products from the farm(s) to the mill (i.e., verify the Chain of Custody is maintained).
  3. That the risk level determined by the feed mill is supported by the Due Diligence pathway used and the evidence provided.
  4. That for ingredients determined not to be low risk, the feed mill has implemented appropriate measures to achieve low risk before sourcing.

The auditor will also verify that a monitoring program has been implemented and that Due Diligence is repeated when required as per the Standard (not applicable for initial audits).

Useful resources

AFi guidance on Supply Chain Engagement and Monitoring & Verification: https://accountability-framework.org/contents-of-the-framework/monitoring-and-verification/ 

AFi guidance on Achieving Commitments Through Collaboration (including jurisdictional initiatives): https://accountability-framework.org/operational-guidance/achieving-commitments-through-collaboration/ 

Seafish Guide to Illegal, Unreported and Unregulated (IUU) Fishing: https://www.seafish.org/document/?id=64546167-9781-464a-a1dd-29bb5e0ef3f0

OECD-FAO Guidance for Responsible Agricultural Supply Chains: https://mneguidelines.oecd.org/rbc-agriculture-supply-chains.htm