MSC – Marine Stewardship Council

Product Provenance (KDEs) project update

May 2017
Project lead: Leah Buckley

1. Summary
This update is intended to keep stakeholders informed on the progress made on the Product
Provenance (KDEs) project, the pilots, proposals for consideration, and next steps.

2. Overview and Past Consultations

MSC ran a public consultation on the project from 1-30 September 2016. Additional in-
person, email and telephone consultation has been held since and will continue through
2017.
Consultation feedback highlights the need to further consult and explore the options
available to meet the objectives and address stakeholder needs and concerns. A summary
of the feedback can be found on the MSC website.
This project aims to provide a KDE solution for fishery/farm information with accompanying
certified products as they pass through the certified CoC supply chain. The following two
separate proposals have resulted from this consultation and are detailed below:

1. The introduction of new certification scope activities for supply chains that produce
and/or handle deal with related to ‘Fish oil’ and ‘Fishmeal’.
2. Introduce a voluntary system that will allow CoC certificate holders the ability to pass
certain KDE information on the species, the certified fishery and Unit of Certification
(UoC) to a batch level.

Project updates
Objectives
The revised objectives of the project have been formed based on feedback received from
different geographical regions and sectors of the supply chain:
a. Improve the ability of the MSC to undertake increased supply chain integrity
monitoring, in response to increases in perceived risk in some supply chain areas
and increased volumes of MSC certified seafood being traded, by allowing for more
traceback checks to be conducted with a lower direct impact on the supply chain
companies affected.
b. Meet growing industry demands for more transparent and higher quality traceability
data reporting which will increase the value proposition for MSC CoC certificate
holders.
c. Providing an additional mechanism to support MSC CoC certificate holders in their
efforts to comply with new requirements for seafood traceability and eliminating IUU
from entering supply chains.

3. Policy Options
a. Introduction new certification scope activities for ‘Fish oil’ and ‘Fishmeal’
Regarding the proposal to introduce new certification scope activities for ‘Fish oil’ and
‘Fishmeal’, it has been recommended to move ahead as described in the original proposal.
The Executive will continue to work closely with the ASC Feed/Mass Balance Standard to
ensure consistency and coherence in language.

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 b. Passing information on the species, fishery of origin and country of origin
MSC received extremely useful feedback from the first consultation, and we have revised the
proposal in light of this feedback (Table 1). Several stakeholders noted that adjusting internal
management and information flow systems within companies would be challenging; and that
the added burden of collecting and transmitting provenance information should be
minimised. We propose now that the system requires only a minimum set of data elements,
with the potential for others to be added as required by the user, and that the KDE
information be reduced to a single randomly generated code that would be placed alongside
the MSC reference on invoices, all of which should reduce implementation costs.
A second set of comments related to confidentiality and concern that the MSC should have
access only to the information it needs to conduct more efficient traceback and integrity
checks, and not to deeply granular data or data of a commercial nature. In response, we
propose that the KDE information would be held in a secure database maintained by a third-
party company with high levels of data security, which would provide only the randomised
code to companies to use on invoices. Access to data by MSC would be restricted to specific
traceback integrity requests, not trace-forward requests, and to data fields required for those
checks, in line with clause 5.5.1 of the COC standard. Finally, in response to all the concerns
above, MSC now plans a paced and voluntary roll-out for 2018 which would be preceded by
trials conducted in 2017 – 2018.

4. Opportunity and risks of the KDE proposal

The KDE proposal seeks a solution to improve the ability of the MSC to undertake increased
supply chain integrity monitoring; meet growing industry demands for more transparency and
higher quality traceability data; and, support MSC CoC certificate holders as traceability and
provenance requirements increase (retail, NGOs, government).
Tracebacks can take the MSC anywhere from several weeks upwards of several months.
The resources required mean that the same number of tracebacks are conducted in 2017
with 3700 CoC certificate holders compared with 2010 when the program had less than 2000
participants. To ensure the scalability of the CoC program and its high level of integrity, the
KDE proposal is put forward as a new tool to match the number of tracebacks and ability to
undertake an investigation to the size of the program.
The outcomes of the consultation events highlighted the need for us to better communicate
the benefits and opportunities of the proposal, as well as the risks of not proceeding. Some
of these are highlighted in Table 1.

Table 1: Opportunities and risks of the KDE proposal

Perceived benefits
 Improve response times to inquiries on MSC certified
fisheries allegations to integrity.
 Provide greater granularity for supply chain integrity
checks and investigations
 Further mitigate fraud opportunities, e.g. IUU
 Create more confidence and reassurance within the
supply chain
 Ensure greater recognition for certified fisheries and
supply chains
 Potential for cost reduction for the supply chain if
MSC CoC provides information that is being requested
for other market traceability requests.


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 Potential benefit
Risks of proceeding with
the project
Risks of not going
forward with the project
 KDE platform could help facilitate data transaction
between fishery and fishery buyer to ensure only
certified product is sold as certified, and to uphold any
client group restrictions within a certificate sharing
agreement
 Potential challenges with voluntary implementation,
such as verification and participation of supply chain
companies
 Concerns that this information will be used to
undermine certified fisheries based on campaigns, for
example, against certain gear types.1
 Increased potential of mislabelling occurring within
MSC labelled seafood products especially in more
complex supply chains
 Less accurate and slower response to media/
consumers/ eNGOs in cases of e.g. (perceived)
mislabelling or eNGO campaigns targeting particular
species, impacting on MSCs and (fisheries) credibility.
 Perceived reduction in confidence in the MSC CoC
program by the supply chain and consumer
 Duplicated efforts and higher costs, through
additional requests from supply chains or regulators
not aligned or integrated with MSC CoC

5. Opportunities through Digital Traceability work stream

The KDE project is part of a broader scope of work on the MSC CoC program to recognise
and encourage uptake of good digital systems. The seafood industry is constantly
transforming and there are new initiatives and products being developed that offer more
detailed and robust traceability services. As part of this work stream, we are investigating
opportunities to:

 Reduce the audit effort

 Reward good compliance
 Support use of digital systems

The goal of this work stream to maintain the MSC CoC program’s ‘best in class’ standard
while making the program more accessible and efficient for all our supply chain partners.

1
The Unit of Certification (UoC) information includes gear types, which is present currently in all the
transparent information on the MSC website. The MSC has no intention to call out specific gear types in
addition to the UoC information.

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6. Next Steps
The recommendation is to roll-out the MSC KDE proposal in 2018 on a voluntary basis for
interested participants. This will provide additional time to develop the proposal and conduct
pilots to test how the proposal could be implemented and whether it meets the stated
objectives and addresses stakeholder concerns. The proposed next steps are:
Jan 2018: System
in place for wider
use and testing

7. Contact
If you would like further detail on any of the elements of this proposal, have any questions,
and/or are interested in providing feedback, please contact:
Leah Buckley: leah.buckley@msc.org

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