Marine Stewardship Council. Mass Balance CoC Standard. 2. Stakeholder Consultation. 3. Summary of stakeholder feedback. 4.

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1 Marine Stewardship Council Mass Balance CoC Standard Summary of consultation feedback and Public Consultation: 1 March to 30 April Introduction MSC is developing a draft MSC Mass Balance CoC Standard which will assure traceability of marine ingredients handled by feed mills certified against the Aquaculture Stewardship Council s (ASC) Responsible Feed Standard (ASC-FS). ASC is developing the ASC-FS for certification of feed mills to supply responsible feed to ASC certified aquaculture farms. Eventually all ASC certified aquaculture farms must use ASC certified feed. The ASC-FS aims to incentivise feed mills to source responsible raw materials over time, partly by requiring incrementally increased volumes of marine ingredients sourced from MSC (or equivalent) certified fisheries. The MSC Mass Balance CoC Standard will support the ASC-FS by providing a basis for controlling the physical mixing of MSC-certified and approved marine ingredients 1 with non-certified/ non-approved marine ingredients at ASC-FS certified feed mills. Mass balance is necessary for feed mills which do not currently segregate certified and non-certified materials due to logistical challenges inherent to the manufacturing process and present lack of sufficient volumes of MSC-certified raw material. A mass balance CoC approach will help catalyse the uptake of the ASC-FS, and thereby over time create enough certified raw material volume to work towards a segregation CoC model. The ASC-FS will require feed mills to meet the MSC Mass Balance CoC Standard for mixing of certified/ approved and non-certified/ non-approved marine ingredients to become certified against the ASC-FS. The two standards are being developed separately but in parallel processes, with close communication and collaboration between ASC and MSC to ensure the standards are compatible. The aim is to align and streamline the audit processes for both standards. The two standards will be pilot tested together after the next version of the ASC-FS and MSC Mass Balance Standards are released in September Stakeholder Consultation The first public consultation on the draft Mass Balance CoC Standard took place between 1 March and 30 April 2017 and included two public webinars. Feedback was received from five respondents through an online survey. The anonymous full responses are given below. Further ed responses were received from one additional party. 3. Summary of stakeholder feedback Based on the small number of respondents, it was not possible to determine overall themes or trends. MSC has reviewed and is further researching the feedback received. Further consultation efforts will be used to develop and revise the draft standard accordingly. 4. Conclusion MSC has reviewed and considered all feedback received to-date, and is also further researching some of the suggestions provided, such as links to IUU vessel lists, country lists and other seafood traceability initiatives. The next round of public consultation on the revised draft standard will be held from 1-30 September 2017 on the MSC improvements website. 1 Such as marine ingredients from IFFO RS approved fisheries and IFFO RS CoC certified fish meal plants. Mass Balance - Consultation feedback and 1

2 5. Response from the MSC We appreciate the valuable input received from all stakeholders and thank them for taking time to make submissions on the draft Mass Balance CoC Standard. Comments are given below on individual suggestions, each of which have been considered in the next revision of the standard or are being further researched. In the remainder of 2017, MSC will focus on refining the draft standard and obtaining further feedback from relevant stakeholders as needed. The next public consultation will occur throughout September A revised draft Mass Balance CoC Standard will be presented to the MSC Technical Advisory Board in December 2017 for further expert technical input towards finalisation and release in All Consultation Survey feedback and s All online survey and ed responses are shown below. The numbers responding are very small so are not analysed by proportion but responded to individually. Type of respondent Number (multiple categories may apply) Processor/ producer or representative organisation 2 Conformity Assessment Body/ CAB 1 NGO 2 Q1. Principle 1: Organisation Sourcing Policy The organisation shall define and make public a general sourcing policy that commits the organisation to not use material sourced from vessels listed on Regional Fisheries Management Organisations (RFMO) blacklists. (Note: This builds on a requirement in the MSC Chain of Custody Standard: default version, Version 4.0, 20 February 2015.) Should additional commitments regarding exclusion of Illegal, Unreported, and Unregulated (IUU) material be included in the Mass Balance Chain of Custody Standard? For example, should MSC require exclusion of non-certified marine material sourced from countries that have been pre-identified or identified by the European Union as non-cooperating countries as part of their rules to combat illegal fishing? Respondent a) MSC should require exclusion of non-certified marine material sourced from countries that have been pre-identified or identified by the European Union as non-cooperating countries as part of their rules to combat illegal fishing? Respondent b) "[Respondent] strongly supports Principle 1 of the Mass Balance CoC Standard, and encourages the MSC to continue to require that certified organizations define and make public a general sourcing policy that commits the organization to not use material sourced from vessels listed on RFMO blacklists. In addition to this commitment, [respondent] suggests that the following commitments regarding exclusion of IUU material be included in the Mass Balance Chain of Custody Standard: The proposed MSC requirements for due diligence in the revised draft reference EU pre-identified and identified states as high risk red flags, which would preclude their use (unless acceptable mitigating action has been implemented to address the identified concerns). See MSC Mass Balance Standard, Appendix 1, Table 2.1. The MSC Mass Balance standard must be used together the ASC Feed Standard, which requires a publicly available Responsible Sourcing Policy to be in place (see Criterion 2.1, ASC Feed Standard, 2 nd Draft published for public consultation, August 2017). The Responsible Sourcing Policy includes the exclusion of sources associated with Mass Balance - Consultation feedback and 2

3 [Respondent] recommends that the MSC mandate a public sourcing policy for organizations who source non-certified marine ingredients from non-cooperating countries that have been identified or pre-identified by the European Union (i.e. red or yellow carded). The public commitment should outline the due diligence measures the specific organization is taking to ensure that non-certified marine ingredients they source from these countries are legally harvested. This public commitment and list of due diligence measures should be clearly accessible on the organization s website. If the organization does source non-certified marine ingredients from non-cooperating countries that have been identified or preidentified by the European Union, they should engage with their supply chains and request a time-bound improvement plan in writing by each supplier. If a supplier will not commit to improvements or does not make adequate progress towards the organization's public commitment, then the organization should drop that supplier. [Respondent] recommends that the MSC mandate a public sourcing policy for organizations who source non-certified marine ingredients from countries whose vessels or practices have been flagged by the National Oceanic and Atmospheric Administration (NOAA) for IUU fishing violations in their biennial Improving International Fisheries Management: Report to Congress ( ialreport.pdf). The public commitment should outline the due diligence measures the specific organization is taking to ensure that non-certified marine ingredients they source from these countries are legally harvested. This public commitment and list of due diligence measures should be clearly accessible on the organization s website. If the organization does source noncertified marine ingredients from countries whose vessels or practices have been flagged by NOAA for IUU fishing violations, they should engage with their supply chains and request a timebound improvement plan in writing by each supplier. If a supplier will not commit to improvements or does not make adequate progress towards the organization's public commitment, then the organization should drop that supplier. If commitments around EU and U.S. identified countries are incorporated in the organization s sourcing policy, there should be a systematic and efficient communication plan for how the MSC will update participating organizations when changes in status to IUU carded or identified countries occur. Respondent c) MSC should require that all companies are able to segregate and track their products to certified legal sources. Yes, additional commitments regarding exclusion of IUU material need to be included in the Mass Balance Chain of Custody Standard. Ideally, all non-certified marine material should be excluded, at least as an end goal. Yes, MSC should require, as one example, exclusion of non-certified marine material sourced from countries that have been pre-identified or identified by the European Union as non-cooperating countries as part of their rules to combat illegal fishing. Other suggested exclusions are listed below. IUU fishing (see Table 1 of Appendix 2 of the ASC Feed Standard, 2 nd Draft published for public consultation, August 2017). Reference to vessel blacklists also included as a red flag, See Appendix 1, Table 2.1. Suppliers are required to address the issues that result in a source being considered to be high risk, or to discontinue purchasing (see Criterion of the ASC Feed Standard, 2 nd Draft published for public consultation, August 2017). See above re: Public Sourcing Policy. Appendix 1, Table 2.1 of the MSC Mass Balance Standard references the NOAA report. See above for approach to due diligence, as specified in the ASC Feed Standard which must be used together with the MSC Mass Balance Standard. Appendix 1, Table 2.1 of the MSC Mass Balance Standard provides references to relevant sources of information, but it would be the responsibility of the feed mill and its suppliers to ensure that it accesses up to date information in relation to EU/US listing. The due diligence approach specified in the ASC Feed Standard (which must be used in combination with the MSC Mass Balance Standard) takes a due diligence approach. Inability to identify the source of marine ingredients to a sufficient level of accuracy to ensure it is low risk would mean that the source has to be excluded. Mass Balance - Consultation feedback and 3

4 Respondent d) We're providing commentary for the portion of the Mass Balance CoC Standard regarding the development of ASC Feed Standard and that the Mass Balance as currently implemented for CoC holders is not standardized. Neither of these comments appear to be addressed in this questionnaire. Our concern with the feed standard is the language "may be applied to other sectors" in section 3 line 15. This is not defined as future new sections only. Regarding meeting the standards of ASC, we perceive this as bending the MSC standard to meet an outside sources criterion. While we see the importance of participating and working with farmed seafood, we find it questionable that a certification program for Wild Seafood is essentially working to remove one of the last marketing tools for CoC holders to differentiate their product by. The Wild designation becomes more important as more fisheries enter the scope of MSC (very positive); but as more fisheries are engaged the ability to market product becomes commoditized. In response to stakeholder concerns about possible future uses of the MSC Mass Balance Standard MSC has decided that the Standard will be used exclusively for the certification of Feed Mills, in association with the ASC Feed Standard. In relation to use with the ASC scheme for aquaculture, it should be noted that ASC has always used the MSC Chain of Custody Standard for the chain of custody certification of ASC farmed fish, resulting in the application of the ASC logo. The MSC Mass Balance Standard will only be used in association with the ASC Feed Standard. Mass balance certified products will not be eligible to use the MSC logo (see MSC Mass Balance Standard, clause 2.1.4). MSC believes it has a clear missionoriented interest in supporting ASC in the development of a robust approach to the certification of aquaculture feed, given the use of wild marine material as a major feed ingredient. Respondent e) For a scheme designed around the actions of specific organisations/uoas, it would seem highly inconsistent to apply blanket exclusions to countries exclusions should only apply to those vessels/companies on IUU blacklists. The exclusion of IUU appears to require commitments beyond those in the fishery standard, for other categories (ITM, FIP) then an equivalent commitment/evidence should be required. The proposed approach uses country level exclusions specified by the EU and US as red flags in relation to IUU fishing. However it is also proposed that specific vessels that can demonstrate that they are not associated with illicit activity should still be able to supply marine ingredients. For example, a vessel that is fishing in a recognised certified fishery would still be able to supply approved ingredients, even if the fishery is in the territory of a state that has been red-flagged (where such use is compatible with national/ regional legislation). See MSC Mass Balance Standard, Appendix 1, Table 2.1 recognised mitigating actions. MSC is proactively seeking stakeholder feedback on other relevant mitigating actions that may be considered as evidence that concerns raised by other red flags are being addressed (see Consultation Question 3, Consultation Document, MSC Mass Balance CoC Standard, 1-30 September 2017). Mass Balance - Consultation feedback and 4

5 Q2. If you think additional commitments should be made to exclude IUU material, which existing lists or resources could be referenced? Respondent a) positive inclusion is better than exclusion See proposed due diligence approach, combined with the potential for acceptable mitigating actions (see notes under Q2, and request for further suggestions as per Consultation Question 3, in the consultation on the MSC Mass Balance Standard taking place from 1 st to 30 th September Respondent b) "[Respondent] recommends the following resources be referenced when organizations create their commitments to exclude IUU material from their seafood supply chains: Trygg Mat s Combined IUU Vessel List ( Respondent supports the MSC s use of this resource as a means of identifying vessels that have been identified by Regional Fisheries Management Organisations (RFMOs) and INTERPOL with IUU fishing activities. IUUWatch s Map of EU Carding Decisions ( This map is a helpful resource that visually displays the status of countries that have been red and yellow carded by the European Commission, as well those countries that were previously carded but are now delisted. NOAA s Improving International Fisheries Management: January 2017 Report to Congress ( ialreport.pdf): This biennial report highlights U.S. findings and analyses of foreign IUU fishing activities and of bycatch of protected species and shark catch on the high seas. [Respondent] recommends this report as a resource for identifying countries whose vessels have been flagged for IUU fishing violations. Presidential Task Force on Combating Illegal, Unreported, and Unregulated (IUU) Fishing and Seafood Fraud s Priority Species at Risk of IUU Fishing and Seafood Fraud ( 30/ /presidential-task-force-on-combating-illegal-unreportedand-unregulated-iuu-fishing-and-seafood): While all species can be susceptible to some risk of IUU fishing or seafood fraud, the species listed here have been identified by the Presidential Task Force as being of higher risk for these issues to occur, and identified as priority species for the U.S. Seafood Import Monitoring Program. [Respondent] recommends the MSC consider the Task Force list when designing the commitments for exclusion of IUU materials. IUU Species by Pramod et al ( ):This peer-reviewed journal article seeks to estimate the proportion and value of IUU seafood imports to the U.S., and presents several species case studies. This paper may be helpful to the MSC when thinking about what kind of commitments organizations could make to exclude IUU materials. [Respondent] recommends that organizations implement due diligence measures to address and minimize the risks for the species identified in this paper. Traceability, Thank you for the suggestions. A range of references have been included as potential means of verification in the revised draft (see MSC Mass Balance Standard, Appendix 1, Table 2.1, and additional references provided as background information (see Additional resources on IUU fishing, below Table 2.1). Mass Balance - Consultation feedback and 5

6 Mislabeling, IUU Fishing, and Human Rights Risk Assessment Data Sources ( wp- content/uploads/2017/02/ _fishwise-risk- Assessment.pdf): Summarizes a number of helpful anti-iuu fishing resources within the IUU Fishing risk category in our list of risk assessment data sources. [Respondent] encourages the MSC to consider if this Mass Balance CoC standard should only address illegal within 'illegal, unreported, and unregulated' fishing. [Respondent] recommends that the MSC Fishery Standard address the unreported' and 'unregulated' issues of IUU as well. Being clear around the goals of addressing all three components of IUU fishing, or just the illegal component will be important. Each component of IUU can consist of varying fishing violations, and the solutions needed to address each one may differ. While IUU fishing violations and human rights violations in seafood supply chains do not always co-occur, they can be linked. [Respondent] strongly encourages the MSC to adopt social responsibility standards that address human rights and labor abuses that can occur in seafood supply chains on vessels and facilities on land. [Respondent] also recommends the MSC require that certified organizations put policies in place to reduce risks of human rights abuses and implement fair labor practices in seafood supply chains." Respondent c) "The following should specifically be excluded: Material sourced from vessels on RFMO blacklists Material sourced from vessels with EU and US IUU identifications (or designations from other multi- or bi-lateral state commissions) Material sourced from credible NGO blacklists Material sourced from fisheries using as gear explosives, poison, noxious substances Material sourced from ETP species" Thank you for the suggestions. A range of references have been included as potential means of verification in the revised draft (see MSC Mass Balance Standard, Appendix 1, Table 2.1). However, the draft focuses only on state-based determinations, rather than NGO blacklists. Further comment on this issue would be welcomed. Sources that are likely to have a major negative impact on ETP species will be subject to a due diligence process, but work on this has been deferred until initial responses have been received in relation to the approach as applied to IUU fishing. Suggestions are especially welcome in the consultation period 1 st September 30 th September 2017 (see Consultation Question 2). Respondent d) No. MSC CoC stakeholders already bound by agreeing to no purchasing or using vessels, vehicles or companies that are blacklisted. Additional commitments only add financial cost with no additional benefit. The general response of consultees has been in the direction of tighter restrictions on the use of sources associated with IUU fishing, as the quid pro quo for acceptance of any kind of CoC system in which noncertified sources may be mixed in with approved sources of marine material, as is inherent in the mass balance approach. This more restrictive approach was strongly endorsed by the MSC TAB. Further comment in Mass Balance - Consultation feedback and 6

7 the consultation period 1 st September 30 th September 2017 is welcome. Q3. How should organisations make their Organisation Sourcing Policy under Principle 1 publicly available? Respondent a) company website with direction from audit report Respondent b) [Respondent] supports the language on page 7 of the Consultation Document Mass Balance CoC Standard that states The organisation shall define and make public a general sourcing policy that commits the organisation to not use of material sourced from vessels listed on Regional Fisheries Management Organisations (RFMO) blacklists. [Respondent] recommends that companies make their sourcing policies easily accessible on their website. If the company does not have a website, [respondent] suggests that the MSC have a Sourcing Policies component added to their website, where certified companies are listed along with their public commitments. As best practice, organizations should communicate their sourcing policy and expectations in this policy to all participants within their supply chains. This can be done through a Supplier Code of Conduct, a Supplier Expectations Letter, written into a business contract, or incorporated into product specifications. As a fellow member of the Conservation Alliance for Seafood Solutions ( [Respondent] recommends that the MSC ask organizations to adopt the recommendations made in the Alliance s A Common Vision for Sustainable Seafood ( wp - content/uploads/2014/10/a-common-vision-for-sustainable- Seafood.pdf). [Respondent] encourages the MSC to review Step 1 of the Common Vision, Make a Public Commitment, to align their asks of certified organizations with the recommendations outlined in the Common Vision. Respondent c) The policy should be posted on their own website (if they have one) and posted on the MSC website, and possibly also in their annual report. The requirement for a publicly available Responsible Sourcing Policy is specified in the ASC Feed Standard (see Criterion 2.1, ASC Feed Standard, 2 nd Draft published for public consultation, August 2017), which must be used together with the MSC Mass Balance Standard, and specific reference has been removed from the MSC Mass Balance Standard to avoid duplication. Footnote 47 of the ASC Feed Standard specifies that the Responsible Sourcing Policy must be made available via the website of the feed mill in local language and English. The policy must also be communicated to all purchasing staff and direct suppliers (see Criterion 2.3.2, ASC Feed Standard, 2 nd Draft published for public consultation, August 2017). Q4. Principle 5: Management System Requirements The organisation shall operate a management system, documented in a formal manual or equivalent written procedures, that addresses all requirements in this standard including specifying what records are kept and assigning responsibilities for its implementation. Should this clause say: a. What it says in the current draft. (Requiring formal documentation, specifying records kept and assignment of responsibilities for implementation). Or b. The organisation shall operate a management system that addresses all requirements in this standard. (As per the current MSC CoC Default Standard). Respondent a) The organisation shall operate a management system that addresses all requirements in this standard. (As per the current MSC CoC Default Standard). Respondent b) The revised draft specifies that the organisation shall operate a management system, documented in or formal manual or equivalent written procedures (see MSC Mass Balance Standard, clause 5.1.1). This is in line with the majority of the comments received. Mass Balance - Consultation feedback and 7

8 What it says in the current draft. (Requiring formal documentation, specifying records kept and assignment of responsibilities for implementation). Respondent c) What it says in the current draft. (Requiring formal documentation, specifying records kept and assignment of responsibilities for implementation) references the need for responsible personnel, but the reference in the earlier draft was deemed to be redundant, given the requirement that the manual must address all requirements in this standard. Respondent d) What it says in the current draft. (Requiring formal documentation, specifying records kept and assignment of responsibilities for implementation). Q5. What references to, or recognition of, other relevant standards schemes or benchmarking systems should be included in the Mass Balance Standard, if any? Respondent a) none Respondent b) The Seafood Task Force ( al/) is a group of seafood processors, feed producers, buyers, retailers, and NGOs who have come together to drive measurable social and environmental change in the Thai seafood industry through greater supply chain accountability, verification, and transparency. Particular emphasis is being placed on feed for farmed shrimp, tuna from Thailand and the Western Central Pacific, and aims to expand to other seafood products over time. [Respondent] recommends that the MSC connect with the Seafood Task Force, as they are thinking about ways to address mass balance for wild-caught fish that are processed into feed for shrimp aquaculture production. Please contact Martin Thurley (secretariat@seafoodtaskforce.global) to learn more about the Task Force s work and how the MSC can ensure alignment with this effort. MSC has taken this suggestion and is now connected and engaged with the Seafood Task Force. Respondent c) Reference to the ISO standard for fin-fish traceability; Reference to ILO standards Respondent e) It is noted that the requirements for CoC are fairly rigorous, but the requirements for the fishery (FIP engagement) are not. Should these not be equivalent? Might GSSI recognition (for example) be appropriate to identify a suitably well-managed fishery? The requirements in relation to recognition of CoC standards are addressed in Appendix 3 and Appendix 5 of the ASC Feed Standard. GSSI is one of the referenced benchmarks (see Appendix 3 & Appendix 5 of the ASC Feed Standard, 2 nd Draft published for public consultation, August 2017). The requirements in relation to recognition of fisheries standards are addressed in Appendix 3 of the ASC Feed Standard. GSSI is one of the referenced benchmarks (see Appendix 3, ASC Feed Standard, 2 nd Draft published for public consultation, August 2017). Mass Balance - Consultation feedback and 8

9 Q6. Are you a feed mill company or CAB interested in participating in a pilot of the MSC Mass Balance Standard, in conjunction with pilots of the ASC Feed Standard, around April May 2017? N/A Q7. Do you have suggestions on how the MSC Mass Balance Standard and the ASC Feed Standard should be implemented together (e.g., audit process, auditor competencies, timing, verification methods, checklist guidance, etc)? Respondent a) complementary modules MSC agrees the Mass Balance Standard and ASC Feed Standard should be implemented together to reduce resource, time and cost burden for feed mills seeking certification against both. Respondent b) [Respondent] recommends that the MSC Mass Balance Standard and the ASC Feed Standard be implemented in a way that reduces the resource and time burden on participating organizations. Alignment of requested information and general asks between the two standards will reduce confusion and information overload for participating organizations, enabling them to comply with greater ease. [Respondent] encourages the MSC Mass Balance Standard and the ASC Feed Standard to streamline its auditor visits, auditor costs, and trainings, along with additional aspects that can save participating organizations time and money, increasing their likelihood to continue to participate in both standards. [Respondent] recommends that both standards be implemented in a way that allows for end-to-end traceability throughout aquaculture feed supply chains, from the vessel to the feed mill and every step in between (vessel > landing > fishmeal plant > feed mill). [Respondent] also encourages the MSC and the ASC to clearly state when social or labor issues are not included as aspects of either standard at any point throughout the supply chain. The concept of mass balance CoC means certified ingredients processed at certified feed mills can be physically mixed according to specific and defined requirements. Records documenting inputs and outputs will still be required. Mass balance approaches will not be allowed for the processing of marine material prior to its supply to an MSC/ASC certified feed mill, so as to ensure that ALL material that is supplied to the feed mill MUST have passed at the least a due diligence assessment, and/or be from a recognised, certified fishery source. If processing takes place prior to the delivery of marine material to the feed mill, the material must have been segregated from any material that has not passed a due diligence test. Sources from fisheries at a number of different sustainability levels may be mixed together, prior to delivery to the feed mill. In this case the supplier must either specify the proportion of the material that meets different levels of sustainability, or must treat it all as being at the lowest sustainability level of the sources in the mixture. MSC agrees that the end goal for the full chain is segregation CoC, and a mass balance will help support this transition to occur as higher volumes of certified marine ingredients for feed become available. Respondent c) We feel these requirements and their implementation should be aligned, although it is difficult to tell at this point how that would look. We would like to see the MSC and ASC continue to work hard to ensure their processes are as aligned as possible. An MSC representative participates on the ASC Standards Committee for Mass Balance - Consultation feedback and 9

10 development of the mass balance approach more closely tied to the ASC feed standard process. These conversations are overlapping and should not be disjointed or held in parallel it seems that this may be the case currently. Respondent d) Absolutely not implemented together see response one. development of the ASC Feed Standard, and ASC personnel are kept fully informed at all stages of development of the MSC Mass Balance Standard. MSC and ASC draft standards will undergo public consultation at the same time, so that comments and potential revisions can subsequently be considered in parallel. Joint ASC/MSC field testing is planned to take place before the end of The MSC Mass Balance CoC Standard will only be available to ASC certified feed mills. It will not be available for certified products using the MSC ecolabel. by [Respondent] has concerns that ITM and FIP-sourced product is to be allowed as equivalent to MSC-certified product. This presents a difficult precedent GSSI recognition of the source fishery may be a better entry requirement. This is a particular issue as the LTL requirements may well be prejudicial to many feed-orientated fisheries ever being MSC certified. This issue should be considered in tandem with the ITM proposals. [Respondent] has completed the online feedback survey for the Mass Balance CoC Standard consultation. On behalf of the [Respondent] Network I would also like to submit the following comments: We feel the MSC should be striving for full traceability and separation, including for fish meal ingredients. Just because some mills don t currently segregate does not mean they shouldn t have an immediate incentive to move in that direction by way of an MSC requirement. We find the claim that mixing is necessary for uptake of the standard unconvincing, particularly without clear timelines to a segregation model approach. The requirements in relation to recognition of fisheries standards are addressed in Appendix 3 of the ASC Feed Standard. GSSI is one of the referenced benchmarks (see Appendix 3, ASC Feed Standard, 2 nd Draft published for public consultation, August 2017). There is communication between the Mass Balance and ITM project development. MSC will consider your comment about GSSI recognition and how certified versus ITM/ FIP-sourced materials could be given different weightings in the mass balance calculation. MSC agrees that the end goal for the full chain is segregation CoC, but believes that a mass balance will help support this transition to occur as higher volumes of certified marine ingredients for feed become available, and will also support efforts to address the issue of IUU fishing. We see high risk of having ASC certified fishmeal that is connected with environmentally high-impact issues that might fall out of the current proposal for excluding IUU blacklisted vessels for instance, bycatch of endangered The ASC due diligence approach is explicitly intended to address the issues of child labour, forced labour, and fishing that has a major Mass Balance - Consultation feedback and 10

11 species, some of the worst managed fisheries that aren t listed by an RFMO, or even slave labor. Even if X% of the feed comes from a designated source there is still be an immediate need to solve egregious impacts or risks in the remainder IUU and otherwise. Appropriate exclusions and incentives for continued improvement should be developed accordingly. The reference to Fishery Improvement Plans should be instead Fishery Improvement Projects, and also reference listing on fisheryprogress.org. It should be made clear that input material under the current definition of MSC Mass Balance Recognised Marine Material will not reflect sustainability requirements (e.g., p. 3) and could be far from meeting the MSC standard. It is unclear how the mass balance approach would work in the ASC feed ladder and difficult to comment on it without the categories clearly defined. We agree that input material from MSC certified fisheries and comprehensive FIPs recognized on fisheryprogress.org is good. All other categories are currently unclear, including the actual definition of MSC s own ITM program. Would an MSC label for mass balance feed (4.12) cover all of these source categories for fishmeal? detrimental impact on ETP species. MSC is seeking feedback initially on the due diligence approach as it applies to IUU fishing, but intends to extend the approach to cover these other egregious impacts/risk prior to finalisation of the standard. Further input on these issues is being explicitly sought (see Consultation Question 2) The requirements in relation to recognition of fisheries standards are addressed in Appendix 3 of the ASC Feed Standard. GSSI is one of the referenced benchmarks (see Appendix 3, ASC Feed Standard, 2 nd Draft published for public consultation, August 2017). We hope this is clear in the current draft, and in the associated ASC Feed Standard. The ASC Feed Standard has been extensively revised since the first consultation period in 2016, and is now out for a second consultation. Considerable work has gone into a clarification of the ASC ladder for the continuous improvement of marine ingredients sourcing (now Principle 4 of the ASC Feed Standard, 2 nd Draft published for public consultation, August 2017). The link between the ASC Feed Standard and the MSC Mass Balance Standard is specified in Principle 7 of the ASC Feed Standard. We recommend that further comment is addressed primarily to ASC at this point in the development process, but would welcome further insight as it applies to the MSC Mass Balance standard as well. Pursuant to the above, we will need to consider whether the mass balance definition will create products that we could support. This may depend on the approach to and incentives for improvement up the ladder that are put into place. Without information on how this is done, we find it difficult to comment on the weight conversion volume/input/output methods proposed. To be clear, requirements in refer only to B2B labelling and claims, not consumer-facing? See above. See above. The intention is that there will not be an MSC ecolabel on mass balance certified feed products (see clause Mass Balance - Consultation feedback and 11

12 2.1.4); instead producers will be able to claim that feed products are ASC Feed Standard compliant which will require them to have met the MSC Mass Balance Standard to be able to make this claim. Wording in relation to claims made using the ASC logo are to be addressed and controlled by ASC (see Principle 8 of the ASC Feed Standard, 2 nd Draft published for public consultation, August 2017). Mass Balance - Consultation feedback and 12