Which Feed Standard Criterion does this apply to?

Criterion 4.1 – The UoC increases the majority sustainability level of its (whole-fish) marine ingredients.

What is the intent of this Criterion?

The feed mill increases the majority sustainability level (MSL) of its (whole-fish) marine ingredients over time, moving up a level from the entry level (EL) every three years towards the maximum level (L4). This drives improvement in responsible sourcing of marine ingredients (Principle 4).

How do I interpret the Requirements?

Scope of the MSL calculation 

The MSL is for whole-fish marine ingredients only (including krill, squid and shellfish, etc.). Calculations, therefore, are based on all of the whole fish marine ingredients the mill sources for aquafeed and are expressed according to the majority proportion (i.e., ≥50%) of material received. Marine by-product ingredients (derived either from fisheries or aquaculture, and including by-catch retained under a regulatory landing obligation in the EU) are not included in the MSL calculation (i.e., they do not need to be specifically calculated out).  

Note that all whole fish marine ingredients must also meet the Due Diligence (DD) requirements under Principle 2 and Annex 3 of the Feed Standard. 

Whole-fish derived marine ingredients outside of sustainability categories 1-4, may be used by feed mills in the minority proportion (i.e. <50%) of marine ingredients. Please note that these ingredients, however, will not count towards the mass balance eligible volume (see Annex 5 of the Feed Standard). 

Verifying the sustainability category (4.1.1)

The ASC understands the practicalities of feed mill operation and notes that feed mills often have a number of different sources of marine ingredients. Where whole-fish marine ingredients from multiple fishery sources (e.g., basic FIP and comprehensive FIP) are received in a mixture, and the proportion of the ingredients from each of these sources is known, the quantities will be allocated to the relevant source in proportion to the actual content. If the proportion of the ingredients from each of these sources is not known, the whole quantity will be allocated to the source which falls within the lowest sustainability category of the material in the mixture.

Note that any batches/lots need to also meet the requirements of schemes listed in the sustainability categories. For example, MarinTrust compliant batches cannot contain ‘non-approved’ MarinTrust material such as that which cannot be traced back to a fishery or has not been sourced from a MarinTrust approved fishery.

Weights used in the MSL calculation relate to the weight of the ingredient during receiving.

Verification of whole fish marine ingredients as per the sustainability categories can be conducted as per the following table.

Table 24: Verification of sustainability categories

Sustainability Category	Verification Process
1	a) The fishery is listed as active (basic) on Fishery Progress website, and; b) The fishery is listed as ‘approved’ on the MarinTrust website and is matched to the traceability acceptance document from the ingredient manufacturer/ supplier; c) If the fishery is not listed as approved on both websites, compliance cannot be assumed unless confirmation is received from the missing publisher (MarinTrust or Fishery Progress). d) The ingredient manufacturer is a MarinTrust Improver Programme accepted site;  e) The supply chain actors between the ingredient manufacturer and the feed mill hold a valid MarinTrust Chain of Custody (CoC) certification and documentation (delivery/purchase records) accompanying the raw material confirms its CoC certified status from factory to feed mill; OR f) The feed mill can demonstrate a third-party verified traceability system from factory to mill.
2	a) The fishery is listed as ‘approved’ on the MarinTrust website and is matched to the traceability certificate from the ingredient manufacturer/ supplier; b) The ingredient manufacturer holds valid MarinTrust certification (or equivalent as per footnote 202 in the ASC Feed Standard); c) The supply chain actors between the ingredient manufacturer and the feed mill hold a valid MarinTrust Chain of Custody (CoC) certification and documentation (delivery/purchase records) accompanying the raw material confirms its CoC certified status from factory to feed mill; OR d) The feed mill can demonstrate a third-party verified traceability system from factory to mill.
3	a) The fishery is listed as active (comprehensive) on Fishery Progress website, and; b) The fishery is listed as ‘approved’ on the MarinTrust website and is matched to the traceability certificate from the ingredient manufacturer/ supplier; c) If the fishery is not listed as approved on both websites, compliance cannot be assumed unless confirmation is received from the missing publisher (MarinTrust or Fishery Progress). d) The ingredient manufacturer holds valid MarinTrust certification (or equivalent as per footnote 202 in the ASC Feed Standard); e) The supply chain actors between the ingredient manufacturer and the feed mill hold a valid MarinTrust Chain of Custody (CoC) certification and documentation (delivery/purchase records) accompanying the raw material confirms its CoC certified status from factory to feed mill. OR f) The feed mill can demonstrate a third-party verified traceability system from factory to mill.
4	a) If the feed mill sources directly from a fishery:the fishery is listed as ‘certified’ on the  MSC ‘track a fishery’ website; b) the ingredient(s) used by the mill is listed on the MSC fishery certificate as certified (or equivalent as per footnote 205 in the ASC Feed Standard);   c) all the records are matching in the traceability documents (e.g., bills of lading, invoices, delivery notes, health certificates/ veterinary checks, catch certificates, purchase orders, and packing list/loading records). If the feed mill sources from an MSC Chain of Custody (CoC) certified organisation: a) the ingredient manufacturer/supplier holds a valid MSC CoC certificate and is listed as certified in the MSC ‘find a supplier’ website; b) the ingredient(s) used by the mill is listed on the certificate as certified and are included in the scope sub-categories for trading fish meal and trading fish oil; c) all the records are matching in the traceability documents (e.g., bills of lading, invoices, delivery notes, health certificates/ veterinary checks, catch certificates, purchase orders, and packing list/loading records).

Example MSL calculations

The tables below provide example calculations of the MSL.

Table 25: Illustration of a range of examples for the MSL

Whole fish ingredients classification	Volume in tonnes
Volume of whole-fish ingredients scoring at Category 1	0	600	450	100	100	50	50	0	0	0
Volume of whole-fish ingredients scoring at Category 2	0	0	150	500	100	200	100	50	300	250
Volume of whole-fish ingredients scoring at Category 3	0	0	0	0	300	300	430	50	100	100
Volume of whole-fish ingredients scoring at Category 4	0	0	0	0	20	50	70	350	300	350
Volume of whole-fish ingredients that does not score at Category 1-4	300	400	550	400	350	350	350	200	100	100
Total whole fish ingredients	300	1000	1150	1000	870	950	1000	650	800	800
MSL	0	1	1	2	1	2	3	4	3	3

Table 26: Example MSL calculation

Marine Raw Material (whole)	ASC Category	% of annual total (whole fish)
Meal from whole Anchoveta E. ringens (FAO 87, Chilean EEZ Regions IV-XV)	2(MarinTrust)	35%
Oil from whole Anchoveta E. ringens (FAO 87, Chilean EEZ Regions V-X)	2(MarinTrust)	20%
Meal from whole Araucanian Herring S. benticki (FAO 87, Chilean EEZ Regions V-X)	2(MarinTrust)	25%
Oil from whole Chilean Jack Mackerel T. murphyi (FAO 87, Chilean EEZ Regions X-XV)	4(MSC)	10%
Meal from whole Japanese Anchovy E. JaponicusChina	0	5%
Other whole fish ingredients	0	5%
MSL	2

Calculating the Entry Level and maintaining/increasing the MSL (4.1.2, 4.1.3 and 4.1.4)

The Entry Level (EL) reflects the MSL as assessed and calculated over the 24 months prior to the initial audit. It is not possible for the feed mill to choose a lower EL if whole fish ingredients meet the requirements of multiple sustainability categories such as MarinTrust as well as MSC. The highest score is used to calculate the EL, not the lowest so as to simply use the other certification to comply with the requirement to increase its MSL for each subsequent certificate cycle. For example, if a feed mill’s current level is 2, they cannot choose to start at 1. 

The MSL is calculated annually (January to December) and maintained from year to year (verified at surveillance audit) and at the 3 year certificate cycle end, the next level needs to be met to achieve recertification. The table below provides examples of MSL maintenance under various hypothetical scenarios.

Table 27: Examples of MSL maintenance under various hypothetical scenarios

Failed scenarios D and E are shown in red.

*As long as compliance as per footnote 162 of the ASC Feed Standard (Indicator 4.1.3) is demonstrated as follows:

• The most likely path will be for feed mills to demonstrate that they have secured sourcing contracts for category 1 compliant raw material but might still be in the process of using up old stock/contracted supplies and will be switching over to the new source within the first year of certification. 
• In other cases, the feed mill may have been working together with their supply chains for some time, and may be in the final stages of the following processes:
  • Raw material is currently under assessment for MarinTrust IP and basic FIP (and other conditions of Category 1 are met), and there is reasonable expectation that this material will be available within the next 12 months, and
  • The ingredient manufacturer is currently under assessment to become a MarinTrust Improver Programme Accepted Site (and other conditions of Category 1 are met).

Possible exceptions to maintaining/increasing the MSL (4.1.3 and 4.1.4)

During surveillance audits, the feed mill demonstrates elements of a procurement strategy that shows that they are on route to achieve a higher MSL by the next recertification cycle. Some exceptions to compliance as detailed in footnote 163 of the ASC Feed Standard (Indicator 4.1.4) may occur, for example:

• If a feed mill sources the majority of its marine ingredients from a single fishery which is in a FIP, but which has not yet managed to move from a comprehensive FIP to MSC certification within the 3-year ASC certification cycle, then the feed mill could maintain its MSL 3 for another 3-year period and continue sourcing from that FIP, in anticipation that the FIP will reach MSC certification within that period, and that therefore the mill will move to MSL 4 within the second 3-year cycle.  Where such a scenario occurs, it is only acceptable once.
• If a feed mill is dependent on a single MSC certified fishery in order to maintain its MSL 3, and that fishery temporarily drops out of MSC certification and into a comprehensive FIP, then the mill could maintain its MSL 3 for another 3-year period and continue sourcing from the FIP, in anticipation that the FIP will reach MSC certification and therefore the mill will move to MSL 4 within the second 3-year cycle. Where such a scenario occurs, it is only acceptable once.

Note, the dependency in this example is that the feed mill had planned and had reasonable expectations to move from MSL 3 to MSL 4 (e.g., has sourcing contracts to gradually increase its volume from the MSC fishery, and has documentation to support this). If, however, any of the other marine ingredients received by the feed mill score at sustainability category 4 and for which an increased volume is potentially available, then the mill is considered not to be dependent on the MSC fishery and the extension would not be allowed. 

Note, if a mill is at MSL 4 and is sourcing ≥50% from a MSC certified fishery which loses its certification, the mill drops to MSL 3 and would therefore likely lose its ASC feed certification. Feed mills should consider the consistency of supply and try to source from multiple MSC fisheries providing raw material for marine ingredient production in their procurement strategies in order to mitigate any risk of reduction in MSL. 

Note that where claimed, any dependency on a specific fishery must be demonstrated by purchase records indicating historical deliveries to the mill over a time period in excess of three years. Such feed mills should also present a case that indicates that importing other raw materials are not a practical or economically viable option (i.e., causes significant delays in production or increases in costs of production), such evidence could include, for example: logistical issues with deliveries; particular nutritional factors related to those marine ingredients specifically; production of certain marine ingredients and their delivery according to the scheduling of production cycles.

• Where a feed mill sources most of its marine ingredients from a single fishery which is in a basic FIP (and meets the other requirements of Category 1), and which has not progressed as planned, and the mill has no obvious relationship with the fishery e.g., is not working with/sponsoring the fishery to progress, and there are other similar fisheries (species, logistics, availability) which would fulfill the mills moving up the MSL ladder as required, then this mill is considered to be not dependent on that fishery, and consequently is not allowed to extend its cycle on the current MSL for another 3 years.

Reporting templates (4.1.5 and 4.1.6)

A reporting template is provided on the ASC website through which the feed mill can calculate the MSL from the various sources of whole-fish marine ingredients used, for the majority proportion (i.e., ≥50%) of whole – fish marine ingredients.

The MSL and the total volume of the marine ingredients used is published on the Feed mill’s website prior to initial certification and prior to subsequent re-certification.

Note that purchasing raw materials certified or approved to any scheme listed in a Sustainability Category does not necessarily entitle the feed mill to make any claims relating to that scheme. Feed mills wishing to make claims should contact the scheme owner for further information on their requirements.

Auditing considerations

The auditor verifies that the sustainability categorisation was performed correctly by sampling records, including at least one sample per sustainability category. The records to be checked are listed in table 24. The auditor checks that only whole-fish derived ingredients were used for the calculation.

The auditor verifies that the Majority Sustainability Level was calculated correctly by reviewing the volume totals used for the calculations.

The auditor will also verify that the reporting requirements to ASC have been completed.