FAO Guidance Advanced End To End Traceability

GUIDANCE DOCUMENT:
ADVANCING END-TO-END TRACEABILITY

Critical tracking events and key data elements
along capture fisheries and aquaculture value chains
01
GUIDANCE DOCUMENT:
Critical tracking events and key data elements
along capture fisheries and aquaculture value chains
by
Francisco Blaha
Vincent André
Yahira Piedrahita
FOOD AND AGRICULTURE ORGANIZATION OF THE UNITED NATIONS

ROME, 2023
Required citation
Blaha, F., Vincent, A. & Piedrahita, Y. 2023. Guidance document: Advancing end-to-end traceability – Critical tracking
events and key data elements along capture fisheries and aquaculture value chains. Rome, FAO. https://doi.org/10.4060/
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Cover illustration: © FAO/Zoe Brandizzi

PREPARATION OF THIS
DOCUMENT
Preparation of this guidance document was coordinated by the Value Chain Development Team, FAO
Fisheries and Aquaculture Division, as part of FAO’s Strategic Framework (Better Production, Better
Nutrition, Better Environment and Better Life), and the Blue Transformation Roadmap Objective:
Upgraded value chains ensure the social, economic and environmental viability of aquatic food
systems. This publication will contribute to equipping stakeholders with technical capacities to
support inclusive, transparent, efficient and sustainable aquatic food systems, thus enabling a more
efficient market access for fisheries and aquaculture products. In particular, this guidance document
assists countries to ensure the identification of the origin of fish and fishery products as specified
under Article 11.1.11 of the Code of Conduct for Responsible Fisheries (CCRF).
The development of this guidance document spanned over the period of 2020-2022 where a first
version was released for an electronic public consultation, in March-April 2021, that was commented
on by a wide range of stakeholders from 42 countries globally. A second version underwent three
regional virtual consultations in 2021 and 2022 with the participation of more than 120 representatives
from 34 countries and 6 international and regional fishery and aquaculture organizations from Asia,
Near East and North Africa, and Latin America.
The paper was written by Francisco Blaha, Vincent André and Yahira Piedrahita, FAO consultants
and international traceability experts, under the lead of Nianjun Shen, Senior Fishery Officer, and Nada
Bougouss, Fishery Officer. Revisions were provided by Mariah Boyle, John Bostock, Dimitar Taskov,
Seonyoung Park and Lucia Lopez de Aragon, FAO consultants. Assistance from Claire Ward for language
editing, and Zoe Brandizzi for the layout are gratefully acknowledged.
iii
CONTENTS
Preparation of this document iii

Preface vii
Abbreviations and acronyms viii
1. INTRODUCTION 1
1.1 Scope and development process 1
2. TRACEABILITY IN CAPTURE FISHERIES AND AQUACULTURE VALUE CHAINS 3

2.1 The application of traceability 4
2.2 The regulatory realm (official guarantees) 6
2.2.1 Capture fisheries 7
2.2.2 Aquaculture 8
2.3 The non-regulatory realm 9
2.4 Traceability standards and technology 10
3. CRITICAL TRACKING EVENTS AND KEY DATA ELEMENTS 13

IN WILD CAPTURE FISHERIES
3.1 Introduction 13
3.2 Fundamentals for operators and raw materials/products 13
3.3 Fundamentals of flag state responsibility 15
3.4 Coastal states 20
3.5 Port states 22
3.6 Processing states 26
3.7 End market states 29
4. CRITICAL TRACKING EVENTS AND KEY DATA ELEMENTS IN AQUACULTURE 32

4.1 Introduction 32
4.2 Feed production and distributors 32
4.3 Hatchery/nursery/seed growing 34
4.4 Farms/growing areas 37
4.5 Collector/distributor/traders/aggregators 40
4.6 Processing 41
4.7 Special considerations for bivalves 43
v
5. DISCUSSION 45
6. RECOMMENDATIONS 47
7. REFERENCES 49
TABLES
1. Main KDEs for the operators’ unique identity and unique seafood material identifiers 14
2. Main supply chain stops, identified CTEs and KDEs to be overseen by a flag state 16
3. Main supply chain stops, CTEs and KDEs identified for a standard supply 20
chain overseen by a coastal state
chain overseen by a port state
chain overseen by a processing state
chain overseen by an end market state
7. Main supply chain stops, CTEs and KDEs identified for feed production 33
and distribution
8. Main supply chain stops, CTEs and KDEs identified for hatchery/seed growing 35
9. Main supply chain stops, CTEs and KDEs identified for farms/growing areas 38
10. Main supply chain stops, CTEs and KDEs identified for processing 42
of aquaculture products
11. Particular supply chain stops, CTEs and KDEs identified for bivalve 44
aquaculture products
vi
PREFACE
The Guidance document: Advancing end-to-end traceability responds to a critical need for consensus
towards establishing end-to-end traceability through globally agreed and standardized understanding
of the critical tracking events (CTEs) along the fish value chain, as well as sources of key data elements
(KDEs) related to fish production and product identification.
In particular, the Guidance aims at developing insights and addressing gaps in developing and
implementing traceability systems for both the private sector and government. Supported by
deliberations through various consultations between 2021 and 2022 (FAO, 2022b), it also provides
technical advice in the enforcement and adequate verification of traceability in fish value chains, and
seeks to act as a benchmark of existing traceability systems to evaluate their efficacy and identify
associated gaps.
The document addresses these objectives through the identification of CTEs and KDEs along the
fish value chain (sections 3 and 4) and, where possible, the identification of supporting standards based
on the standards and guidelines of the Global Dialogue on Seafood Traceability (GDST).
It includes discussion and recommendation narrative (sections 5 and 6) whereby the overarching
takeaways and advice is to: a) identify and define standardized KDEs and CTEs for commercial and
regulatory traceability; and b) follow strict due diligence using a holistic and integrated approach
involving all stakeholders at legal, commercial and operational level prior to commitment.
The Guidance recognizes the globalized landscape in the trade of fisheries and aquaculture products,
coupled with the inherent fragmentation of associated value chains rendering the implementation of
efficient traceability systems rather challenging. It also recognizes the particular challenges for small-
scale producers and developing countries.
vii
ABBREVIATIONS AND ACRONYMS
AIS automatic identification system

ASFIS Aquatic Sciences and Fisheries Information System
BSI British Standards Institution
CA competent authority
CCRF Code of Conduct for Responsible Fisheries
COFI Committee on Fisheries
COFI: FT COFI Subcommittee on Fish Trade
CTE critical tracking event
EEZ exclusive economic zone
EPCIS Electronic Product Code Information Services
EU European Union
GDST Global Dialogue on Seafood Traceability
GPS global positioning system
GTIN global trade item number
HACCP Hazard Analysis Critical Control Points
IMO International Maritime Organization
IRCS international radio call sign
ISO International Organization for Standardization
IUU illegal, unreported and unregulated (fishing)
KDE key data element
MCS monitoring, control and surveillance
MMSI maritime mobile service identity
MTU mobile transmitting unit
NGO non-governmental organization
PSMA Agreement on Port State Measures
RFMO regional fisheries management organization
SKU stock keeping unit
TRU traceable resource units
UNCLOS United Nations Convention on the Law of the Sea (1982)
UNFSA United Nations Fish Stocks Agreement (1995)
UPC universal product code
VMS vessel monitoring system
viii
1. INTRODUCTION
There is no single global prescriptive approach or tool for managing fish traceability, yet there
is a level of consensus that stakeholders should be working towards end-to-end, electronic and
interoperable traceability.
Bhatt et al. (2016) note that to reach such a point, there first needs to be a globally agreed and
standardized understanding of the CTEs along the fish value chain, as well as sources of KDEs related
to fish production and product identification.
Their definitions are:
CTEs – critical tracking event point at which product is moved between premises or is
transformed, or which is determined to be a point where data capture is necessary to
maintain traceability; and
KDEs – key data element input required to successfully trace a product and/or its ingredients
through all relevant CTEs.
The objective of this guidance document is to support standardized understanding of the CTEs and
sources of KDEs for capture fisheries and aquaculture supply chains. This, in turn, should support the
advances in information technology that have given rise to a broad range of digital food traceability
initiatives and systems, by establishing a standardized vocabulary and data formatting.
The document endeavours to assist operators and authorities to identify the data that needs to be
traced, and to define the parameters of traceability.
1.1 SCOPE AND DEVELOPMENT PROCESS
Scope
This guidance document is intended to support countries in implementing traceability in fisheries and
aquaculture value chains. It discusses the role of traceability for official assurance, yet it draws on the
efforts and learning from initiatives led by the private sector in implementing traceability throughout
the fish value chain.
In the context of value chains, the document considers that value chains for capture and culture
fisheries differ from fish to fish and from country to country, and frequently within regions. In this
respect it concurs with a study prepared for FAO by De Silva in 2011.
Moreover, a fish value chain can be defined as interlinked value adding activities that convert inputs
into outputs, which in turn add to the bottom line and help to create a competitive advantage. A value chain
typically consists of inbound distribution or logistics, manufacturing operations, outbound distribution
or logistics, marketing and selling and after-sales service. These activities are supported by purchasing
or procurement, research and development, human resource development and corporate infrastructure.
1
Guidance document: Advancing end-to-end traceability
Most of the analysis in this guidance document and the resulting recommendations are based on
the identification of CTEs and KDEs under the purview of the “regulatory realm” (see Section 2.2) for
specific state actors; how they are covered and how country-level mechanisms could or should serve
to support them or supply traceability solutions in segments where solutions are absent and must be
provided by individual states.
This guidance document uses for its analysis the literature and initiatives identifying KDEs as
well as traceability standards developed by different industries and non-governmental organizations
(NGOs), as well as non-regulatory standards from the “non-regulatory realm” (see Section 2.3). Yet, it
does not propose any specific KDEs or standards for non-regulatory purposes, such as any form of
private certifications, ecolabels, fair trade or social standards, and does not enter the area of organic
or bio-certification.
Development process
A two-part process was followed in the development of this guidance document. The first part consisted
of a desk study based on secondary sources, bibliographies and the analysis of initiatives by NGOs,
governments, the private sector and independent experts, followed by an online public consultation
that took place during March and April 2021. Comments and feedback were collected from a wide range
of stakeholders from 42 countries.
The second part was the organization of three virtual regional consultations in 2021 and 2022
(Asia, North Africa and the Near East, and Latin America [(FAO, 2022b)]) with the participation of more
than 120 representatives from 34 countries and six international and regional fishery and aquaculture
organizations. Delegates and participants deliberated on the CTE and KDE listings and provided
additional comments to corroborate their relevance and comprehensiveness.
2
2. TRACEABILITY IN CAPTURE
FISHERIES AND AQUACULTURE
VALUE CHAINS
Fish and fishery products remain some of the most traded food commodities in the world. In 2018, 67
million tonnes, or 38 percent of total fisheries and aquaculture production, were traded internationally
(FAO, 2018). A total of 221 states and territories reported some fish trading activity, exposing about 78
percent of fish and fishery products to competition from international trade.
Overall, from 1976 to 2018, the value of global fish exports increased from USD 7.8 billion to peak
at USD 164 billion, at an annual growth rate of 8 percent in nominal terms and 4 percent in real terms
(adjusted for inflation). Over the same period, global exports in terms of quantity increased at an annual
growth rate of 3 percent, from 17.3 million tonnes. Exports of fish and fish products represent about 11
percent of the export value of agricultural products (excluding forest products).
For the 1976 to 2018 period, exports from developing countries increased by an average of 8.4
percent per year in value terms, compared with 6.8 percent for developed countries. In this same
period, developing countries’ share of trade in fish and fish products increased from 38 percent of
global export value to 54 percent, and from 39 percent to 60 percent of total quantity (in live weight
equivalent), supported by strong aquaculture production growth and heavy investment in export
market development.
Traceability and its key role in terms of market access for both food safety and legal origin underpin
international trade. The steady increase in developing countries’ share of international trade flows,
with faster rates of growth compared with developed countries, has been a defining feature of the
development of the global fish market.
Based on FAO literature (Borit and Olsen, 2016) and experience from the field, gaps and inconsistencies
in traceability in fishery and aquaculture value chains might be explained by the following:
Standards gap: there might be a lack of written requirements or published standards for
information gathering and sharing that are needed for effective traceability.
Awareness gap: there might be a lack of understanding on what traceability is, and how it differs
from other principles that are seen to be similar to safety and quality standards.
Commitment gap: commitment with respect to implementing traceability is probably related
to the awareness gap. In addition, the most significant commitment gap is related to companies
not understanding how traceability can benefit them financially (see the economic gap below).
Implementation gap: there is often a gap between regulatory requirements and the feasibility of
industry implementation. This may come from several factors such as insufficient maintenance
of a batch integrity (too much mixing), inadequate document security and, most often, a lack of
food safety management control.
Technology gap: there are still challenges related to the availability of technology. Most
companies have less robust traceability practices than they could have given their marketing
strategy and economic interest. There might also be a lack of affordable, functional and robust
technology for automatic data capture. The most significant time and cost related to the
3
operation of a traceability system is the cost associated with initial data entry that is frequently
performed manually. In addition, when data entry has to be performed by small-scale farmers,
the capabilities and capacities of the farmers may be a limitation.
Economic gap: it is widely documented that good traceability not only fulfils legislative and
commercial requirements, but it also reduces operating costs and underpins company branding
and marketing strategies. However, operators required to implement more record keeping, or
change working habits, often question the nature of the incentives that they will receive. A
cost–benefit analysis of investment in improved traceability is difficult to perform.
2.1 THE APPLICATION OF TRACEABILITY
This guidance document uses the definition of traceability from ISO 9000:2015 (ISO, 2022a) as this
incorporates all the critical properties of a traceability system as described in the scientific literature.
Thus, traceability of any given product refers to “the ability to trace the history, application or location
of an object.”
In a product sense, it may relate to: the origin of materials and parts, the product processing
history, and the distribution and location of the product after delivery. This definition clearly states
what should be traced (history, application and location) and what events should be tracked.
There are several principles or requirements that must be followed for a traceability system to be
effective. It is critical that recordings are interconnected and in a format that allows the product to be
tracked along the entire supply chain. Thus, units that are traced (traceable resource units [TRUs], e.g.
a box of mackerel), and identification or numbering schemes that provide codes/numbers used for the
unique identification of TRUs (e.g. GS1 barcodes) are parts of a traceability system.
For this system to be effective, it is essential that the codes of a TRU (either as a raw material or
semi-finished product) entering a link in the supply chain are associated uniquely with those of the
same item (semi-finished or end product) leaving the link. This ability to identify products individually is
the basis of product traceability. Equally critical is maintaining accurate records of the transformation
(e.g. splitting, joining) that the TRU undergoes, and sharing the TRU identification code with partners
in the supply chain. This approach is consistent with the FAO guidelines on traceability (FAO, 2013).
Based on these arguments, this document maintains that traceability is an infrastructure that can
be used by control agencies for two purposes. The first purpose is to retrieve different data for various
reasons (such as legal harvest, origin, eligibility, food safety, fisheries management, etc.).1 The second
purpose is to support the verification of these data with other specific tools, e.g. genetic identification
of species such as in the case of fish mislabelling.
As discussed in the literature, “a traceability system is quite similar to a filing cabinet in that they
both deal with systematic storing and retrieving of data. Importantly, neither a traceability system nor
a filing cabinet care about what types of data are being stored” (Olsen and Borit, 2012). This notion has
several important consequences. For instance, there is no guarantee that the recordings are true or
complete, as both error and fraud can lead to false claims about the properties of the food product,
including its origin. There is a clear need to verify these claims and in this area analytical methods and
instruments play a crucial role. Similarly, documenting traceability and documenting an ecolabel-
type chain of custody are two different concepts. Although traceability can be used as a tool in the
1
Increasingly there is a call for the use of such data for the labour rights of the crew/seafood workers.
4
2. Traceability in capture fisheries and aquaculture value chains
certification process, traceability and certification are nonetheless different processes (Borit and
Olsen, 2012).
Traceability by itself makes no claim as to the state of the product or information that can be
followed from one point to another through a system. In order to claim that a product has certain
values, those values have to be verified, even if the product is traceable back to a specific origin.
The implementation of traceability systems in fisheries value chains was catalysed by market access
requirements, which initially were the domain of the European Union health certification (2005) and
later on (after 2010) supplemented by the European Union catch certification scheme.
As outlined in the FishWise (2018) paper on traceability: increasingly, companies are publicly
committing to sustainable fish sourcing policies, and the challenge is now for those companies to
be able to track the origin of their products to ensure that species and attributes of the products are
meeting their policies and communicated to the customer accurately. For companies that buy and sell
fish, the lack of product origin information and supply chain transparency can pose significant risks.
In the past, industry’s traceability focus was primarily on food safety concerns. However, the increase
in media coverage about the environmental, social, and legal issues associated with fish has led to
significant shareholder concerns, potential impacts on brand value, and challenges to the corporate
social responsibility initiatives of companies.
The first step towards mitigating and eventually eliminating these risks is to ensure end-to-end,
electronic and interoperable traceability systems are in place throughout the supply chain. This work
is already underway, with some groups of companies instituting traceability policies and setting
standards, often with the assistance of NGOs, government bodies and technology companies.
Borit and Olsen (2020) identified three main categories of traceability standards and norms, which
this document also follows: international standards and guidelines, regulatory standards, and industry
and NGO non-regulatory standards.
These provide the basis for identifying two main classes of drivers relating to the benefits of traceability:
“Negative drivers” are related to what the firm must do, or more or less feel forced to do. They
include meeting specific traceability requirements in legislation, in standards that the firm has
adopted, or have been requested by the buyers, customers, consumers and market in question.
They also include drivers related to reducing risks, in particular in relation to food safety and
food fraud, and to short-term reduction in costs, resource use and waste.
“Positive drivers” are voluntary and relate to the potential for using traceability to add value to
the product, improve quality, and aid communication and information interchange in the supply
chain. In particular, they include drivers related to brand trust, product differentiation and
storytelling, sustainability and ethics beyond what is legally or contractually required.
The distinction between negative and positive drivers is not binary, and the drivers should be viewed
as being on a continuous scale ranging from “absolute requirements, all companies must have this
degree of traceability, otherwise they cannot operate” (negative), through to drivers only applicable
for companies that have traceability and transparency as part of their branding and that will or might
record anything that can add value to the product or the production process (positive). This division
also sets the two realms in which traceability operates and in which we will base part of the analysis;
the regulatory and the non-regulatory (voluntary).
While we recognize the complementarity between both, based on the institutional support nature
of the FAO mandate, most of the analysis in this document and the resulting recommendations are
5
based on the identification of CTEs and KDEs under the purview of the “regulatory realm” for specific
state actors: how they are covered and how country-level mechanisms could or should serve to support
them or supply traceability solutions in segments where solutions are absent and must be provided by
individual states.
Nevertheless, this document uses for its analysis the substantial volume of literature and initiatives
identifying CTEs and KDEs as well as traceability standards developed by different industry and NGO
non-regulatory standards in the “non regulatory realm”.
2.2 THE REGULATORY REALM (OFFICIAL GUARANTEES)
Regulatory requirements exist for all business operators along the value chain, and they are linked to
minimum requirements related to what the company needs to do to comply with laws, regulations
and standards in order to meet market requirements for traceability, transparency and product
documentation, and to keep costs low.
Regulatory requirements for traceability are not uniformly established among the international
community, and they vary immensely among countries. Inside each country they may be required for
one aspect (e.g. food safety) and not for others (e.g. illegal, unreported and unregulated [IUU] fishing).
Blaha, Borit and Thompson (2015) analysed traceability systems in ten countries, and in all cases the
level and extent of the implementation of traceability requirements was driven by official food safety
bodies (many in response to market access issues) that did not coordinate their work with that of any
other interested parties (i.e. fisheries and customs).
Furthermore, different countries or groups of countries may have requirements of traceability that
apply in three different scenarios:
Within an organization: internal traceability, specific to a company or enterprise, is used to meet

many business needs (e.g. official regulatory compliance and inventory management), but for
the purposes of interoperable end-to-end traceability, the system elements are straightforward.
In between organizations across the national fish supply chain: connecting an internal
traceability system to upstream and downstream systems. For example, the New Zealand
Ministry of Primary Production requires that anyone processing or storing fish products must
record any movement of product between premises or owners in the mandated national E-cert
system (MPI, 2023).
In between different countries: connecting a national traceability system to upstream and
downstream systems in other countries. For example, TRACES is an online platform run by the
European Union Directorate General for Health and Food Safety that enables communication
among the competent authorities (CAs) in the European Union, European Free Trade Area
countries and non-European Union countries. The objective is to guarantee that the European
requirements under its sanitary and phytosanitary measures for animal health, animal welfare
and veterinary public health are met. In addition, the European Trade Centre’s INTRASTAT system
focuses on trade among European Union countries and re-exports from the European Union, but
only after a consignment has entered the European Union under its importation protocol.
Many different administrations and regulatory bodies are involved from catch to consumer in most
international fish value chains.
6
The needs, requirements and implementation capacities from these regulatory-based systems are
quite unique because they imply the need for official guarantees provided at different CTEs along the
value chain inside an organization, inside a country and in between countries.
There is limited information available on which CTEs and KDEs are applicable to these three
regulatory-based scenarios. For capture fisheries this guidance document will follow the strategy
already established by two FAO publications: Seafood traceability for fisheries compliance – Country
level support for catch documentation schemes (Hosch and Blaha, 2017) and Blockchain application in
seafood value chains (Blaha and Katafono, 2020).
These two publications analyse the interrelation of traceability along the value chain based on
country-specific traceability mechanisms that are often essential for verifying and corroborating
submitted data, based on the state types involved in fishing, landing, processing and trading of fisheries
products along the supply chain (i.e. flag, coastal, port, processing and end-market states).
Each type of state carries out functions that contribute to the success of traceability under defined
groups of CTEs and a less standardized group of KDEs that relate to the scope and specific application
of the expected traceability function or outcome (e.g. food safety or IUU).
In the case of aquaculture, the state type concept is not as clear as it is in the wild capture sector, yet
we can identify producer state for feed, hatcheries and farms, processing state(s) and market state(s).
In both cases, it is important to recognize that a single state can act as all of the state types, as
is the case of many developing states that focus on capture/production and processing, while many
developed economies are the market state for their products. Under this reality, there are specific
regulatory requirements that apply to the different CTEs along the value chain and are validated by the
collection and verification of KDEs, whose identification is central to the objective of this document.
In addition, a 2021 report by the Seafood Alliance for Legality and Traceability outlines Comprehensive
electronic and catch documentation and traceability (eCDT) principles for governments that produce or
are a source for seafood (SALT, 2021).
2.2.1 CAPTURE FISHERIES
For capture fisheries this segment of the analysis considers the types of states (flag, coastal, port,
processing and end market) that have custody of fishery products moving through national supply
chains from harvesting, transshipment, landing and processing to the consumer end market.
Each section on a type of state identifies general control elements that should be in place. The types
of state analysed in this document for the capture fisheries value chain are:
Flag state: this is the state whose flag is flown by fishing vessels, whose activities it is obliged to
authorize and monitor under international law. In international fisheries, targeting species under
the management of a regional fisheries management organization (RFMO), flag states also have
reporting obligations to the international body as to the activities and catches of their fleet(s).
Oversight by the flag state covers harvesting, transshipment and landing operations, the latter
typically regarded as the last transaction related to fishing.
Coastal state: this is the state in whose waters a fishing operation may be taking place, in
which case the coastal state must provide the necessary oversight to ensure that foreign vessels
entering its waters are authorized to operate, and report operations and catches to relevant
coastal state authorities.
7
Port state: this is the state in whose port(s) fish are landed. The port state has legal obligations
under the Agreement on Port State Measures (PSMA) or port state measures best practices to
ensure that only legal fish are landed by carrying out rigorous in-port inspections of vessels flying
a flag other than that of the port state and voluntarily entering its ports to land fish, as well as the
applicable requirements for its own flagged vessels.
Processing state: this is the state in which raw products are converted into semi-processed
products or end products. The processing state may be the same as the port state, or fisheries
products for processing may enter the processing state by sea, air or land. Processing states are
important in terms of ensuring that only legally caught, certified2 fishery products are imported,
processed or sold for domestic consumption, export or re-export. The “laundering” of fisheries
products into legally certified supply streams occurs mostly at this level.
End-market state: this is the territory in which final consumer products are placed on the market,
acquired by customers and consumed, often after importation. The action of the end market state
is limited to ensuring that non-certified3 products cannot gain access to its consumer markets.
2.2.2 AQUACULTURE
For aquaculture, the analysis of standard workflow showing the links between the different operators
in aquaculture supply chains is necessary to the implementation of a traceability system. Yet the role
of “states” is not as defined as in the case of wild caught fishery products. Nevertheless, traceability is
only possible when the operators in the aquaculture value chain implement elements of a traceability
system, such as unique identification of operators and products, record keeping, data communication,
etc., within the actors of the supply chain.
Standard supply chains include hatcheries/nurseries, feed producers, farmers, collectors and
processing plants. The role of the state – later called “authorities” in this section – of the producing
country/ies is to make sure that these operators comply with regulatory requirements (e.g. food
safety, sustainability of products, feed and other inputs, among others). These requirements mean
all applicable government-issued approvals, licenses, registrations, authorizations and verification of
good practices along the supply chain must be recorded. The operators (value chain companies) are
responsible for the traceability of the products that they put on the market.
Feed producers and distributors are responsible for ensuring that only traceable and safe
ingredients are used in the feed manufacturing, and that fishmeal sourcing must be in line with the
applicable regulatory requirements. This is a unique juncture where capture fisheries are often a
source of ingredients for aquaculture feed. Aquafeed should also be produced with the applicable
traceability requirements in the feed production process and distribution.
Hatcheries are responsible for seed production based on the required minimum traceability
standards. Hatcheries should therefore establish and maintain effective record keeping from the
receiving of the broodstock and/or seeds of aquaculture and subsequently cultivate them into
shrimp seedlings, bivalves or fish fry.
Farms (or growing farms) are responsible for their registration with the required authorities
and the basic information required (i.e. location, facility identification), as well as land and water
2
Certified by government through a catch certificate for example. We are not referring to private/ecolabel certifications.
3
By the processing state.
8
use for the farming process. This is usually done through a licence to operate which is given to
the farm for a definite period. The traceability requirements extend normally to the origin of the
seeds, feed, drugs and chemicals used, along with the harvest quantities and other information
(e.g. timing, dispatch information, destination, etc.).
Collectors/distributors/traders or intermediaries are responsible for their registration with
the required authorities and providing the basic information to keep track of the movement
of the aquaculture products, information on the traders or tiers of traders, and the dates and
volume of each product purchased until it is sold.
Processing plants are responsible for their official state-type authorization based on regulatory
requirements. This is usually done through a licence to operate which is given to the processor
based on food safety and other regulatory requirements. This implies the implementation of
minimum food safety and traceability requirements. As processors are the final step before
products enter the market, processing plants are a critical component in terms of ensuring
that raw materials and processing inputs that lack origin and traceability information are not
imported, processed or sold for domestic consumption, exported or re-exported.
2.3 THE NON-REGULATORY REALM
The positive drivers exist only for companies that want to use traceability and improved product
documentation as part of value adding and branding.
Borit and Olsen (2020) devote a substantial part of their findings to identify selected voluntary
food traceability success stories from various world regions, stemming from different initiatives, and
expressed in a multitude of forms – from structured reports to short information, and from websites
to accounts in online media outlets.
Unlike the regulatory realm, there is substantial information available on which CTEs and KDEs are
identified for both the aquaculture and capture fisheries sector-based traceability practices within an
organization and across the seafood supply chain.
In addition to required and voluntary governmental requirements, CTE and KDE recommendations
are included in certifications and standards, industry guides and projects, and NGO and expert
reports. In 2017, FishWise summarized these KDEs in a white paper. In 2020, several NGOs published
a “comparative study of key data elements in import control schemes aimed at tackling illegal,
unreported and unregulated fishing in the top three seafood markets: the EU, US, and Japan” (EJF,
OCEANA, The Nature Conservancy, The Pew Charitable Trusts and WWF, 2020) and a blog shared a
side-by-side comparison of the United States of America’s Seafood Import Monitoring Programme and
the European Union KDEs (Blaha, 2019).
Numerous other guidance documents exist for specific countries and aspects of traceability and
combating IUU fishing, e.g. British Standards Institution (BSI, 2017).
Yet, the world of private certifications and ecolabeling is a confounding one. Scores of certifications
overlap, compete and sometimes contradict one another. Establishing how they work, what they cover,
who operates them and how robust their standards are can be a time consuming, and sometimes almost
impossible task. And, while some efforts to benchmark standards have taken place (e.g. the Global
Sustainable Seafood Initiative, [GSSI, 2023]) they usually focus on a specific group of certifications,
instead of all that may be encountered in a global value chain.
9
The Seafood Certifications Guide (Seafood Source, 2020) identifies and describes 87 different
private certifications. In 2007, Corsin, Funge-Smith and Clausen provided an overview of aquaculture
standards and certification schemes to show the multitude of sources in which 30 certification
schemes and eight key international agreements relevant to aquaculture certification were identified
as addressing sustainability issues and creating a framework for differentiating sources of aquatic
products in this respect.
As outlined in the section below, this guidance document uses some of the types of resources listed
above to add KDEs to the GDST’s KDE list. Many of the GDST’s KDEs overlap with the KDEs in use
by regulatory and non-regulatory schemes in existence today. The non-GDST listed KDEs presented
originate from the quoted FAO publications and the authors’ experiences.
2.4 TRACEABILITY STANDARDS AND TECHNOLOGY
It is not the role of this guidance document to recommend a particular set of standards or a type
of technology. Yet, it is critical that traceability systems are aligned with international e-business
standards such as the one developed by the United Nations Centre for Trade Facilitation and Electronic
Business (UN/CEFACT). The UN/CEFACT has adopted the Fisheries Language for Universal Exchange
(FLUX) – a harmonized message standard allowing fishery management organizations to automatically
access electronic data from fishing vessels (UNECE, 2016).
This global body for the exchange of electronic business information has developed specific agri-
food sector standards that are endorsed by governments and intergovernmental organizations such as
the World Trade Organization, the World Customs Organization and FAO.
The structure of traceability systems must be standardized to facilitate inter-operability. For this
purpose, the International Organization for Standardization (ISO) has produced ISO 12875:2011, which
specifies how traded fishery products are to be identified and the information to be generated and held
by the food businesses that trade the products through supply chains (ISO, 2022b). The standard deals
with the distribution of finfish and their products for human consumption, from catch to retailers and
caterers, but it does not cover data migration from one stage to another.
Similarly, GS1 (2023) is a vendor-neutral not-for-profit organization that develops freely available
standards for global use. It has developed standards for electronic data sharing – GS1 EANCOM and
GS1 XML – and the 2015 GS1 Foundation for fish, seafood and aquaculture traceability implementation
guideline (GS1, 2019).
The role of standards cannot be understated, as interoperability and verifiability among information
systems are basic prerequisites for twenty-first century global commerce. Yet, as was the case for the
communication and banking sectors, various challenges with regard to operating platforms and shared
standards must be overcome:
1 _ A platform has to be designed that can accommodate all permutations and scenarios as they
occur in reality, so that all movements and transaction types can be logged.
2 _ Industry has to be persuaded to accept the technology and its requirements.
3 _ The cost of developing and rolling out the system and related training can be substantial.
To meet these challenges, the seafood industry needs a unified set of standards and guidelines
to enable coherence and interoperability among seafood traceability systems and to help ensure the
verifiability of the data those systems contain.
10
As a critical initial step, there is a need to establish common global expectations and practices
regarding two fundamental things:
1 _ the nature of the information to be routinely associated with seafood products (i.e. the
KDEs); and
2 _ the technical design specifications allowing diverse digital traceability systems to
communicate with one another (known as interoperability).
Meeting these needs was the purpose of the GDST and the GDST standards and guidelines published
in February 2020 (GDST, 2022). The GDST is one of the largest and most diverse business to business
seafood industry forums, that includes some of the most important retailers, brands and mid-supply
chain processors from around the world and across the entire seafood supply chain (IFT, 2020). The
GDST released its Standards and guidelines for interoperable seafood traceability systems v1.0. in order
to enable interoperability and significantly improve the verifiability for all seafood traceability systems.
The GDST standards have two main parts:
1 _ Standards identifying the minimum data elements that need to be documented and
transmitted within GDST-compliant seafood supply chains. These are described in technical
detail in the GDST’s “Basic universal list of key data elements,” covering both wild-capture
and aquaculture products.
2 _ Standards governing the technical formats and nomenclatures for sharing data among
interoperable traceability systems.
In technical terms, GDST 1.0 is built as an extension of the international traceability standard
known as GS1 Electronic Product Code Information Services (EPCIS), which is widely used by major
retailers, brands and supply chains across food and non-food product classes (e.g. it is used in the
pharmaceutical industry).
The GDST has refined and adapted the EPCIS standard to be “fit for purpose” for the seafood
industry and to include innovations that allow companies to integrate with GS1-based systems without
making commercial commitments to use proprietary GS1 traceability solution products.
The GDST standards are designed to meet operational business needs. They enable companies to
gain insight into their supply chains while allowing them to maintain data access controls to protect
business-sensitive information.
Digital record keeping and traceability systems are the future of the seafood industry, with companies
that remain dependent on paper-based systems increasingly face competitive disadvantages. However,
digitization may remain a challenge, especially for smaller actors in developing countries. This is why
the GDST does not require complete digitization of internal company operations but focuses only on
digital data transfer between supply chain partners.
As the GDST standards are recent (in line with GS1), have substantial industry input and support,
and include KDEs present in major market access requirements, this document uses many of the GDST
KDEs. These are referenced in the analysis tables and this report adds supplementary KDEs that relate
to regulatory aspects (as the GDST standard was created for supply chain operators). With regard to
the standards per se, the logic and language proposed by the GDST can be adapted for use with nearly
all the KDEs identified.
For easy reference between this document and the GDST KDEs, we identify them by number in the
analysis tables in the next section, and maintain as far as possible the original text.
11
3. CRITICAL TRACKING EVENTS
AND KEY DATA ELEMENTS
IN WILD CAPTURE FISHERIES
3.1 INTRODUCTION
The identification of CTEs and KDEs for capture fisheries under this section expands on those already
established by two FAO publications (Hosch and Blaha, 2017; Blaha and Katafono, 2020), as well as the
incorporation of all the applicable KDEs in the GDST basic universal list.
The KDE tables initially identify those that are independent of the type of state, and then identify
those considered necessary under the regulatory realm of traceability for each type of state, largely but
not exclusively from the perspective of a catch documentation scheme.
3.2 FUNDAMENTALS FOR OPERATORS

AND RAW MATERIALS/PRODUCTS
For a traceability system to be most effective it needs to cover the entire chain of events at each type
of state. In addition, there is a need for traceability systems that cover events between entry and exit
“gates” (into and out of the type of state jurisdictions), so that regulatory controls can establish where
anomalies occur and identify those responsible. These controls must cover:
Registration and licensing of the fishing operation, storage and processing premises to identify
value chain operators. In most countries, vessels, fish storage and processing premises must be
licensed and controlled by health and/or fisheries authorities, which amounts to a traceability
and record keeping system that can support traceability.
Registration and licensing of all value chain operators. Having a unique identifier and a structure
of control for each operator in the supply chain is fundamental for any form of traceability.
Distribution and transfers among operators’ premises or entities. Registration of internal
movements of declared species and volumes makes them traceable; this requires six KDEs that
must be recorded at every step along a supply chain, namely:
à unique product identifier;
à product source – seller and previous owner of the product;
à product destination – buyer and new owner of the product;
à species;
à volume; and
à product forms.
All co-mingling or mixing, aggregation, and disaggregation or splitting of batches or units
must be tracked and all KDEs associated with new units and previous units must be tracked. In
addition, changes of legal ownership or physical possession (e.g. a transportation subcontractor)
must be tracked. These events are not included in every table, as this could happen throughout
13
supply chains, and even several times under the oversight of one “owner” or during one “event”.
The GDST Core Normative Standard addresses this topic in more detail.
Table 1 summarizes the main KDEs required for the operators’ unique identity and unique seafood
material identifiers.
► TABLE 1
Main KDEs for the operators’ unique identity and unique seafood material identifiers
CTEs Main KDEs Data source Comments
Operators Unique Unique operator identifier Legal fisheries and business The need to give all operators in
operator Identifier associated with the operator are to be registered for a value chain a unique identity
identity operator for the duration of its existing regulatory frameworks is overlooked many times. The
existence that cannot be re- such as fisheries, health, tax, more that identity is shared
used by any other operator labour, etc. among government institutions,
the easier common actions are
facilitated. A fiscal identity for
taxing purposes is normally
necessary for any commercial
activity, and that identity can
be used by other government
organizations.
Raw materials Unique Unique identifier for item/stock Weight ticket, production No single source exists, yet the
and products seafood keeping unit (SKU)/universal records, packing lists, etc. more standardization, the better
material product code (UPC)/global trade Codes on inventory, etc.
identifiers item number (GTIN)
identifier of seafood material to
distinguish it within a particular
facility, company, or globally.
GDST KDE W01
Linking KDE Weight ticket, production Individual facility/supply chain

identifier associated with records, packing lists, etc. actor in most cases, yet the
physical product marking a Codes on inventory, etc. more standardization, the better
particular instance of seafood
material such as a batch/
lot number, serial number, or
container number.
GDST KDE W02
Product source – seller and Invoices, weight ticket,

previous owner of the product; production records, packing
refer to unique operator identity lists, codes on inventory, etc.
Product destination – buyer and Invoices, weight ticket,

new owner of the product; refer production records, packing
to unique operator identity lists, etc.
Codes on inventory, etc.
Species name Aquatic Sciences and Fisheries

GDST KDE W15 Information System (ASFIS) list
of species, scientific name/
FAO 3-alpha code (e.g. YFT for
yellowfin tuna)
Vessel’s logbook/harvest
records
Volume/weight/quantity Weight ticket, invoices, Codes for units of measure used

numerically quantifiable amount production records, packing in international trade
of seafood with a standard Unit lists, inventory, etc.
of Measure.
GDST KDE W03
14
3. Critical tracking events and key data elements in wild capture fisheries
(Cont.)
CTEs Main KDEs Data source Comments
Raw materials Unique Product form Vessel’s logbook/harvest No single source exists, yet the
and products seafood commercial short-hand records, weight ticket, more standardization, the better
material reference of the degree of production records, packing
identifiers transformation of seafood from lists, etc.
its original living form.
GDST KDE W16
Expiry/production date Calendar date associated with a

GDST KDE W23 particular instance of a seafood
product indicating the key date
in its life cycle
Production method Categorization on the spectrum

GDST KDE W24 of wild capture to captive
culture; of the general seafood
harvest method
Product origin Country where seafood

GDST KDE W25 underwent the last substantial
transformation
Source: Authors’ own elaboration.
3.3 FUNDAMENTALS OF FLAG STATE RESPONSIBILITY
Under the United Nations Convention on the Law of the Sea (UNCLOS),4 flag states must oversee the
operations of fishing vessels flying their flags. The 1995 United Nations Fish Stocks Agreement (UNFSA)
(UN, 2021) also mandates this and obliges flag states to investigate alleged violations of conservation and
management measures and apply sanctions against non-compliant fishing vessels. The 1995 Code of
Conduct for Responsible Fisheries (FAO, 1995) also mandates this approach and places more emphasis
on the enforcement regimes of flag states.
Vessel registrations, license registers, vessel monitoring systems (VMS), logbooks, observer
programmes, transshipment and landing authorizations5 enable flag states to discharge their
responsibilities under international law and to oversee fishing vessels flying their flags. To provide
sound assurances that vessels are operating legally, flag states must ensure that they have verified data
that can be supplied to traceability systems, through the following mechanisms:
Registration and licensing of fishing vessels are conditionally linked, and that registration and
licence lists are accessible to and shared by the CA.
Fishing vessel licences, authorizations or permits may vary in scope and according to the type
of fishery.
The implementation and enforcement of VMS, automatic identification system (AIS) and logbook
regimes should be independent of whether the vessels are operating in waters beyond national
jurisdiction.
Standardized logbooks (either electronic or paper-based) that record fishing operations are also
a licensing requirement in coastal states and RFMOs.
A fisheries observer and/or complementary electronic monitoring programme should be
implemented and coordinated with those operated by RFMOs or coastal states in which the
fleet operates.
4
See UNCLOS, Article 94.
5
As defined in the FAO Voluntary guidelines for transshipment (2022).
15
Unloading events should be communicated, and where appropriate, authorized by the relevant
authorities.
Transshipments, transfers and landings are regulated, directly or indirectly monitored and
recorded.
The more efficiently flag states carry out their functions, the stronger the assurances that IUU
catches are denied entry into supply chains. Flag states also have a fundamental role in terms of food
safety assurances for products on their vessels, including those that operate in distant waters. These
responsibilities are based on the sanitary requirements for fishing vessels, either under national
legislation or by market access conditions, as in the case of access to the European Union market.
In general terms, fish processing establishments in a country intending to export products should be
registered and approved under the control of the national CA6 against the applicable standards (which
include specific requirements normally referring to good manufacturing practices, infrastructure,
hygienic conditions, Hazard Analysis Critical Control Points (HACCP), operations, traceability, labelling,
etc.). The same principle applies to fishing vessels on which processing takes place (i.e. freezer vessels
and factory vessels). Non-processing vessels (such as ice vessels, small-scale crafts, etc.) may also need
to be registered and approved before they can be used to supply exporting establishments.
In order to demonstrate and provide assurances that processing-vessels comply with required
standards, flag states must ensure that they have directly or indirectly validated data that can be
entered into regulatory traceability systems, through the following mechanisms:
Fishing vessels are controlled through sanitary inspections and, if in compliance, their processing
licences, authorizations or permits under a unique identification are maintained.
The implementation and enforcement of sanitary regimes for fishing vessels should be
independent of whether the vessels are operating in waters of the flag state or in waters beyond
national jurisdiction.
Standard food safety plans and their records are kept for verification.
Table 2 summarizes the main supply chain events and CTEs and KDEs to be overseen by a flag state.
► TABLE 2
Main supply chain stops, identified CTEs and KDEs to be overseen by a flag state
Flag state
Supply chain CTEs Main KDEs Data source Comments

stop
Harvesting Fishing vessel National flag of vessel Vessel registration from flag Name or ISO two-letter country
identity GDST KDE W07 state code list – ISO 3166
Small-scale fishing boats should
bear some minimum form of
identification. This identification
should ideally be linked to an
official registration/licence by
the authorities of the flag state
6
State authority with the competency for a specific area.
16
(Cont.)
Flag state
Supply chain stop CTEs Main KDEs Data source Comments
Harvesting Fishing vessel International Maritime Maritime authority on behalf Specific to a vessel and should
identity OrgaAnization (IMO) of the IMO not change when a vessel
number/unique vessel changes flag
identifier (UVI)
GDST KDE W06
Vessel registration number Vessel registration from flag Specific to a vessel but changes
GDST KDE W05 state when a vessel changes flag
Name of fishing vessel Vessel registration from flag Databases tend to work on
GDST KDE W04 state the Latin alphabet, numbers
and punctuation but the
Romanization of names in non-
Latin alphabets is complex (e.g.
the vessel name 嘉吉滿 can be
written in at least 36 different
ways in English)
International radio call sign Vessel registration from flag Up to seven characters assigned
(IRCS) state to the vessel by its country of
registry; specific to a vessel but
changes when a vessel changes
flag
RFMO vessel number RFMO list of vessels Specific to the vessels but
flag; in some cases is based on
the IRCS
Satellite vessel tracking VMS: mobile transmitting unit VMS: issued by the flag state
authority (MTU) identifier and/or coastal state and/
VMS and/or IAS IAS: maritime mobile service or RFMOs (when vessels are
GDST KDE W13 identity (MMSI) registered to more than one)
can be more than one. Use is
compulsory but data is not
normally seen in the public
domain
MMSI: a unique nine-digit
identification number; use is
compulsory under maritime
safety regimes (but not always
for fisheries) and data can be
seen in the public domain
Specific to the vessels but
flag
Fishing Fishing authorization Licence on board/or present Unique identifier of the licence,
vessels’ (license number) in a database by the fisheries format depends on the country
authorization GDST KDE W11 authority of the flag state
to fish (by the
flag state) Fishing licence validity Licence on board/or present Period of time for which the
in a database by the fisheries fishing license is valid (normally
authority of the flag state stated in the licence)
Licensed fishing area(s) Licence on board/or present Licences can cover fishing in
in a database by the fisheries a specific area or the whole
authority of the flag state, exclusive economic zone (EEZ)
coastal state or RFMO of the flag state and/or outside
the EEZ. High seas fishing is
normally under a RFMO (if one
exists for the region). Licences
do not cover fishing in other
countries’ EEZs as these are
provided by coastal states.
Fishing gear(s) type Fishing gear/s used aligned Normally described in the

GDST KDE W10 with FAO’s International licence conditions in reference
Standard Statistical to the fishing event. Some
Classification of Fishing Gear vessels are able to operate with
more than one type of gear and
the licence should reflect this
17
(Cont.)
Flag state
Harvesting Fishing Sanitary licence ID/ Sanitary CA of the flag state Can be needed for market
vessels’ approval ID access (e.g. European Union and
authorization China)
to fish (by the
flag state)
Fishing Fishing zone/catch area VMS/AIS/logbook controls FAO major fishing area, EEZ,
operations GDST KDE W14.1-14.4 RFMO or subnational permit
dates and areas
zones (shared
with coastal Availability of catch Indicate whether global
state if coordinates positioning system (GPS)
applicable) GDST KDE W12 coordinates were collected
and are available
Start and end dates of Reporting/logbook Can be validated by VMS/AIS to

vessel trip and date(s) of some extent
captures
GDST KDE W08, W09
End of fishing Unloading/port entry Reporting/logbook Flag state best practice is

(reporting) request Port entry request to request vessels to seek
(shared with unloading authorization from
flag state if flag state (independent of port
applicable) entry or transshipment at sea)
For the port state, port entry
request implies the end of
fishing operations
Species name Vessel’s logbook/harvest

GDST KDE W15 records/electronic reporting
ASFIS list of species
Scientific name/FAO 3-Alpha
code (e.g. YFT)
Estimated volume/weight / Vessel’s logbook/harvest Numerically quantifiable amount

quantity records/electronic reporting of seafood with a standard unit
GDST KDE W03 of measure
Product form Vessel’s logbook/harvest Commercial short-hand

GDST KDE W16 records, weight ticket, reference of the degree of
production records, packing transformation of seafood from
lists, etc. its original living form. No single
source exists, yet the more
standardization, the better
Unloading Type of Landing or transshipment Reporting/logbook Flag state best practices request
(transshipment unloading (unloading) authorization Port entry request, vessels to seek unloading
at sea, in port or authorized GDST KDE W33, W31 transshipment authority list of authorization from flag state
landing, or any authorizations (independent of port entry or
combination transshipment at sea)
thereof) For the port state, port entry
request implies the end of
fishing operations

Estimated volume to be Vessel’s logbook/harvest Codes for units of measure used
unloaded (per product type) records in international trade
Volume/weight /quantity Species’ scientific name (ASFIS/
GDST KDE W03 FAO 3-Alpha code [e.g. YFT])

Transshipment Receiving vessel’s ID (same These include all vessel’s ID In the case of transshipment to
at sea requirements as a fishing requirements, as for a fishing more than one receiving vessel,
vessel’s ID) vessel information needs to capture all
GDST KDE W19, W20, W29 receiving vessels
W30
Receiving vessel’s licensing These include all vessel’s ID Carriers have to be licensed in
requirements, as for a fishing the case of transshipment to
vessel more than one receiving vessel;
information needs to capture all
receiving vessels
18
(Cont.)
Flag state
Unloading Transshipment Sanitary licence ID/ Sanitary CA of the flag state Can be needed for market
(transshipment at sea approval ID access (e.g. European Union and
at sea, in port or China)
landing, or any
combination Dates of transshipment Fishing vessel captain/ Can be validated by VMS to some
thereof) (start and end) master’s records and extent
GDST KDE W18 transshipment vessel captain/
master’s records
Transshipment location Rendezvous area GPS Can be validated by VMS to some

GDST KDE W17 coordinates extent
Fishing vessel captain/
master’s records and
transshipment vessel captain/
master’s records
Transshipment Receiving vessel’s ID (same These include all vessel’s ID In the case of transshipment to
in port requirements as a fishing requirements, as for a fishing more than one receiving vessel;
(shared with vessel’s ID) vessel information needs to capture all
port state) GDST KDE W19, W20, W29, receiving vessels
W30

Receiving vessels’ licensing Similar to a fishing vessel Carriers have to be licensed in
the case of transshipment to
more than one receiving vessel;
information needs to capture all
receiving vessels
Sanitary licence ID/approval Sanitary CA of the flag state Can be needed for market
ID access (e.g. European Union and
China)
Dates of transshipment Fishing vessel captain/ Can be validated by VMS to some

(start and end) master’s records and extent
GDST KDE W18 transshipment vessel captain/
master’s records
Transshipment location Port name and country/ Port name or rendezvous

GDST KDE W17 designated port code if flag coordinates if outside port zone
and port state are signatory
to PSMA
Fishing vessel captain/

master’s records and
transshipment vessel captain/
master’s records
Landing Location Unloading vessel (fishing Port name and country/

(shared with GDST KDE W21 or transshipment) captain’s designated port code if flag
port state) records and port state are signatory to
PSMA, or GPS coordinate for
non-port landing
Dates of landing (start and Reporting/logbook

end) Port information
GDST KDE W22 Unloading vessel (fishing
or transshipment) captain’s
records
First buyer Flag state best practices This is similar to identifying

Unique operator identity should request vessels to seek the receiving vessels in case of
unloading authorization from transshipment
flag state (independent of
port entry or transshipment
at sea) and report first buyer
of product
19
3.4 COASTAL STATES
Although international law provides that coastal states have the sovereign right and duty to manage
fisheries in waters under their jurisdiction, their current role in traceability is limited.
Vessels registered in coastal states, or foreign vessels operating in the coastal state’s waters need
to abide by coastal state requirements, therefore it is the duty of coastal and flag states to ensure that
fishing operations are legal and monitored.
Access for foreign vessels is to be established in a supportive manner with other flag and port states
in the same fishery, particularly if transboundary and straddling stocks are involved. Participation
by coastal states in RFMO decision-making and the incorporation of the resulting conservation and
management measures into their legal frameworks is a basic way in which coastal states can control
the operations of foreign vessels in the same way that flag states do.
The most common approach to access is through fisheries agreements between coastal and flag
states that set out the terms and conditions of individual fishing permits and define the obligations of
flag states with respect to fishing operations carried out by their vessels.
From a traceability for regulatory compliance perspective, the coastal state’s CTEs and KDEs relate
to fishing operations and therefore overlap and in many cases supplement the ones requested from
flag states.
The licences issued by coastal states normally impose operational conditions that are supplementary
to those that may be imposed by the flag state on vessels operating in coastal state waters. The
monitoring, control and surveillance (MCS) tools used by coastal states, such as VMS, logbooks and
EEZ entry and exit conditions, supplemented by an observer or e-monitoring programmes, enable a
coastal state to determine the legality of harvests in waters under its jurisdiction.
The enforcement capacities of coastal states in cases of suspected infringements are often limited,
particularly when vessels unload in jurisdictions outside a coastal state. It is essential that coastal
states participate in decisions about the validity of data for traceability purposes on the basis of their
control of foreign fishing operations in their EEZ.
Table 3 summarizes the main supply chain stops, CTEs and KDEs for a standard supply chain
overseen by a coastal state.
► TABLE 3
Main supply chain stops, CTEs and KDEs identified for a standard supply chain overseen by a
coastal state
Coastal state
Harvesting Fishing vessel Unique fishing vessel ID(s) Vessel registration from flag Usually as defined for the flag
(access/ See Table 2 state state in section above
permission to Pre-fishing authorization Coastal state best practices
fish) check normally include a pre-licensing
inspection to confirm identity
of vessel
Fishing Fishing authorization Licence on board/or present Unique identifier of the licence,
vessel’s (license number) in a database by the fisheries format depends on the country
authorization GDST KDE W11 authority of the coastal state
to fish
(by the coastal
state)
20
(Cont.)
Coastal state
Harvesting Fishing Fishing licence validity Licence on board/or present Period of time for which the
vessel’s in a database by the fisheries fishing licence is valid (normally
authorization authority of the coastal state stated in the licence)
to fish
(by the coastal Licensed fishing area(s) Licence on board/or present They can cover fishing in a
state) in a database by the fisheries specific area or the whole of the
authority of the coastal state flag state’s EEZ and/or outside
(high seas normally under a
RFMO) but not in other countries’
EEZs
Fishing gear type (s) Fishing gear/s used aligned Normally described in the
GDST KDE W10 with FAO’s International licence conditions in reference
Standard Statistical to the fishing event. Some
Classification of Fishing Gear vessels are able to operate with
more than one type of gear and
the licence should reflect this
Coastal state VMS: MTU identifier VMS: issued by the flag state
Satellite vessel tracking and/or coastal state, and/
authority or RFMOs (when vessels are
VMS and or AIS IAS: MMSI registered to more than one).
GDST KDE W13 Use is compulsory but data is
not normally seen in the public
domain
MMSI: a unique nine-digit
identification number. Use is
compulsory under maritime
safety regimes (but not always
for fisheries); data can be in the
public domain via NGOs (e.g.
GlobalFishingWatch.org)
Specific to a vessel but changes
when a vessel changes flag
Fishing Coastal zone entry and exits Communication with coastal Normally set as condition in the
operations state fishing authority licence
dates and Reporting/logbook
zones
(shared with Fishing zone/catch area VMS/AIS/logbook controls FAO major fishing area, EEZ,
flag state if GDST KDE W14.1-14.4 RFMO or subnational permit
applicable) areas

Availability of catch Indicator whether GPS
coordinates coordinates were collected
GDST KDE W12 and are available
Start and end dates of Reporting/logbook Can be validated by VMS/AIS to

vessel trip and date(s) of some extent
captures
GDST KDE W08, W09
End of fishing Species name ASFIS list of species

(reporting) GDST KDE W15 Scientific name/FAO 3-Alpha
(at zone exits code (e.g. YFT)
if applicable Vessel’s logbook/harvest
under records/electronic reporting
coastal state
licensing) Estimated volume/weight/ Vessel’s logbook/harvest Numerically quantifiable amount
of measure
GDST KDE W03

lists, etc. its original living form. No single
source exists, yet the more
standardization, the better
21
(Cont.)
Coastal state
Harvesting End of fishing Unloading (if known) Vessel’s logbook/harvest Complex because distant-water
(reporting) See Table 2 records/electronic reporting fishing nations in a coastal
(at zone exits state’s EEZ do not normally
if applicable notify coastal states about
under future unloading as they exit
coastal state the EEZ
licensing)
3.5 PORT STATES
Fishing vessels bring their catch to port for landing directly as catchers, or indirectly on reefers/
carriers. The port is the point at which fisheries products move from the seaborne to the land-based
supply chain. Few other points are as important for full traceability of fish and fishery products. The
use of port state measures to enforce domestic and international fishery laws is now understood as a
right and a duty of port states.
The 2009 PSMA requires port states to designate their fishing ports (the ports to which fishing
vessels are limited). The PSMA also requires that foreign fishing vessels must be consistently monitored
in such ports, and that full dockside inspections may be carried out.
Inspections should not be limited to foreign fishing vessels, even though in practice they are a
particular concern. Port and flag states are distinct entities and when fishing operations are at least
partly conducted in distant waters it complicates oversight by flag states and increases the relevance
of port states with regard to vessel compliance and oversight of foreign fishing.
International law recognizes that states have full sovereignty with respect to ports in their
territories, and a state may:
deny port access to vessels registered in other states;

prohibit vessels registered in other states from landing or transshipping fish in its ports;
require vessels seeking port access to provide information about their identity and activities; and
inspect vessels that are voluntarily in one of its ports.
In port, fishing vessels can be fully overseen because they are close to land-based facilities and the
authorities can access the vessels themselves. It is largely the quality of port state monitoring and the
work of port-based fisheries officers that reduce the risk of illegally sourced fish entering the land-
based supply chain.
Port states must therefore be in a position to monitor all fishery transactions in their ports – mainly
landings and transshipments7 – and subject selected transactions to full-scale inspections, as they are
the last line of defence for detecting infringements, denying certification of IUU-derived catches and
preventing their entry into land-based supply chains.
Fundamentally a system of authorizations for unloading should be in place to ensure that: 1)
permissions are denied in cases of suspected or established IUU fishing; and 2) volumes and species
unloaded from fishing vessels are recorded for traceability purposes.
7
As defined in the FAO Voluntary guidelines for transshipment (2022).
22
Certain supply chain points overseen by port states are particularly important for traceability:
End of fishing trip and port entry – submission of information to the port state authority
where the landing is planned prior to the arrival in port of any fishing vessel. Authorization to
unload requires compliance with applicable PSM conditions and an evaluation of the legality
of catches linking fishing trips to volumes and species unloaded.
Unloading – can happen in two ways:
à Transshipment in port – catch information must be handed from the fishing vessel to the
reefer master, and be counter-validated by the port state and entered into the traceability
system. Port state authorities therefore require a sound understanding of the fishery and
its regulatory framework governing in-port transshipments and standard MCS routines
and inspections. Reefers unload several harvests at once, making this step of checking
paperwork and data complex and essential for MCS controls.
à Landings in port – once authorization to land is granted, two essential data groups must be
completed, overseen and counter-validated by the port state authority:
The actual weights landed, in whatever form, must be verified and the means of
transport and storage established so that all transactions can be summed to account for
their full-landing equivalent weight. This is the first occasion where the accurate actual
weight of a harvest can be verified.
The amount acquired by every uniquely identified buyer in terms of species, volume
and form must be recorded, and the port state should have access to its own data for a
traceability system.
Port state authorities are crucial in counter-validating these data groups, which constitute the
foundation of national mass balance traceability.
The role of the port state also includes responsibilities in terms of food safety according to
national legislation and/or final market access conditions. Some states have specific infrastructure
requirements and operational conditions for the authorization of use of unloading places and their
unique identity. In the case of market access to the European Union, for example, the port state is to
be an authorized country (EC, 2023) otherwise the products are not eligible for this market. Therefore,
the country authorization status needs to be traceable.
Table 4 summarizes the main supply chain stops, CTEs and KDEs identified for a standard supply
chain overseen by a port state.
23
► TABLE 4
port state
Port state
Harvesting End of fishing End of fishing/port entry Port entry notice

(reporting) estimate
(shared with
flag State and Fishing vessel identity Port entry notice Usually as defined for the flag
coastal State (Based on the flag state state in section above
if applicable) KDEs, Table 2)
Fishing vessel’s Port entry notice Can be validated with access to

authorization to fish regional/RFMO licensing registry
(Based on the flag and Can include flag state, coastal
coastal State KDEs, Table state and RFMO
2 and 3)
Fishing operations dates Port entry notice Can be validated with access to
and zones EEZ; FAO fishing area, regional/RFMO VMS and/or IAS
(Based on the flag and sub-area and division(s) as
coastal State KDEs, Table applicable for RFMO reporting
2 and 3)
Species Name ASFIS list of species

GDST KDE W15 Scientific name/FAO 3-Alpha
code (e.g. YFT)
Vessel’s logbook/harvest
records/electronic reporting
Estimated volume /weight / Vessel’s logbook/harvest Numerically quantifiable amount

GDST KDE W03 of measure

lists, etc. its original living form
No single source exists, yet the
more standardization, the better
Unloading Transshipment Authorization to transship Port use/transshipment In the case of transshipment to

in port to fishing vessel based PSM authorization by the fisheries more than one receiving vessel
unique number associated authority as per PSM best information needs to capture all
with a regulatory document, practices of PSMA receiving vessels
from the relevant authority,
granting permission
GDST KDE W33
Carrier vessel’s ID (same Port entry notice Can be validated with access to
requirements as fishing regional/RFMO licensing registry
vessels ID, Table 2)
Carrier vessel licensing Port entry notice Can be validated with access to
Usually as defined for the regional/RFMO licensing registry
flag state and or coastal
states in sections above,
Tables 2 and 3
Details of species, product Port entry notice Can be validated on arrival

types and volumes on board Cargo manifest/hatch plan inspection
prior to entry to port (if any) Inspection report
GDST KDE W03, W15, W16
Sanitary license ID/approval Sanitary CA of the flag state Can be required for market
ID access (e.g. European Union and
China)
24
(Cont.)
Port state
Unloading Transshipment Dates of transshipment Fishing vessel captain/ Can be validated by

in port (start and end) master’s records and transshipment monitoring if in
GDST KDE W18 transshipment vessel captain/ existence
master’s records
Estimated volumes Mate’s receipt, transshipment Can be validated by

transshipped (per species/ monitoring estimates, hatch transshipment monitoring if in
product type) plan, etc. existence
Landing Landing authorization to Port use/landing authorization

unload a fishing vessel by the fisheries authority as
based on PSM per PSM best practices of
unique number associated PSMA
with a regulatory document,
from the relevant authority,
granting permission
GDST KDE W31
First buyer/unique operator Unique operator identifier This is no different to identifying

identifier the receiving vessels in the case
of transshipments. In the case
of landing in more than one
site, all information needs to be
captured
Landing location Designated landing site ID A port can have many designated
GDST KDE W21 In port landings: port name landing sites, either state or
Non-port landings: GPS privately owned
coordinates
Dates of landing (start and Reporting/logbook Can be validated by unloading

end dates) Port operations log by fishery monitoring if in existence
GDST KDE W22 or port authority
Volumes landed (per Estimated (i.e. containers, Codes for units of measure used
species/product type) truck weights) in international trade
GDST KDE W03, W15, W16 Verified, if in existence, ASFIS list of species
(weight ticket, docket, etc.) Species, scientific name/FAO
3-Alpha code (e.g. YFT)
If weights are verified in port,
implies a form of official
oversight and verification of
volumes and species
Distribution Factory/ Unique operator identifier Legal fisheries and business

warehouse operator are to be registered
“weigh in” for existing regulatory
frameworks under fisheries,
health, tax, etc.
Volumes received (per Port use/landing authorization Generally, the “weigh in” implies
species/product type) Invoices, weight ticket, a form of official oversight and
Verified net volume, forms production records, packing verification of volumes and
and species transferred to lists, codes on inventory, etc. species
individual buyers
25
3.6 PROCESSING STATES
The “processing state” concept is not recognized per se in international fisheries law – yet it is the most
important state type in terms of country-level traceability solutions. In principle, “processing” means
any action that substantially alters an initial product. It can be as simple as transforming a fish from
“whole” to “gutted” or “filleted” and includes changes by processes such as cooking, canning, drying
and extrusion, or a combination of such processes.
In some cases, “non-transforming” operations, such as grading and packing or storing, are referred
to as processing but they have no effect on product or unit weight.
The emergence of important processing states like Thailand, China and Viet Nam in the tuna
industry has drawn attention to the data management and traceability in these types of states, where
raw materials are imported, processed and then exported.
For robust traceability, processing states must:
Ensure that no illegal or unsafe raw materials or products enter their territories, whether landed
or imported.
Cover the entire chain of events by means of its national traceability system to trace product
from landing or importation at ports of arrival through ownership changes and processing
exportation, or re-exportation. Traceability systems should cover all critical tracking events
between entry and exit “gates” (into and out of the country) so that regulatory controls can
establish where anomalies occur and identify those responsible. These controls must cover:
à Registration and licensing of storage and processing premises to identify value chain operators.
In most countries fish storage and processing premises must be licensed and controlled by
health and or fisheries authorities, which requires a traceability and record-keeping system.
à Distribution and transfers between operators’ premises: registration of internal movements
of declared species and volumes makes them traceable. These require strict adherence to
the main KDEs identified for the operators’ unique identity and unique seafood material
identifiers in Section 3.2.
à Operations in storage and processing premises involve changes in weight from unprocessed
to processed product, providing opportunities for laundering fish from different origins into
supply streams. Therefore, fishery authorities must establish controls to:
check processing premises and cold stores to verify the accuracy of records and
inventories, account for volumes that have been split or mixed and verify the volumes
and forms of certified species entering supply chains and subsequently leaving them;
verify the reporting and monitoring of yield factors to eliminate fraud; and
record products leaving operators’ premises, regardless of destination. Regular verification
by fishery and sanitary CAs of pre-dispatch checks and consignment loading records will
ensure the effectiveness of traceability systems at the level of individual operators.
For any data entry into a regulatory traceability system, the following functions are essential for
private sector operators:
Product entry and creation of a product account link product entry to the premises with the
relevant documentation. Scanned supporting documents may be uploaded when creating the
26
product account and CAs then validate and authorize the product account. All transactions are
deducted from this account.
Product exit, subtraction from the product account and certification for product exit from a
supply chain to:
à another operator in a business to business transaction, with the acquired raw materials in
alignment with the details of species, volumes and form;
à a domestic market for local consumption, logged as above; and
à exportation, with supporting documentation and details of volume, form and species so that
log processing yields and any anomalies can be traced.
Product account balance is held by any operator, based on logged data and/or verified by
inspection.
Other important functions for private sector users involve mechanisms for queries and error
correction.
Authorities must have access and functions to enable them to:
validate requests submitted by industry operators for product movements, certificates and error
correction;
make queries to obtain an overview of the system and products within it; and
block or suspend product movement authorizations or certificates submitted for validation.
Overall the system must be capable of:
automated monitoring of product flows and yield factors throughout national supply chains as
product changes form, weight and ownership;
capturing processing yields on the basis of volume declarations for product in and product out
to establish a database; and
triggering alarms that signal the logging of anomalous data and which in turn trigger investigation.
Processing has been the purview of food safety authorities, for whom traceability is important in
terms of consumer safety, information and product origin. Hence, systems involved in tracing product
from landing at the port of arrival, importation, ownership changes and processing to domestic markets
or exports, are often already in place under specific legislation and/or market access requirements.
Regardless of whether fish are imported or landed, in most countries fish storage and processing
premises in the export value chain are licensed and under the control of health and/or fisheries
authorities, with particular regulatory conditions that apply according to the type of processing in
place. Therefore, fish storage and processing premises involved in the export supply chain need to be
licensed and under the control of the fisheries authority.
Non-compliance with license conditions should automatically result in sanctions, enforcement
measures and suspension of the license.
In complex national supply chains, which are the norm in advanced processing states, systems
must be developed to trace the movement of products from the entry gate to the exit gate so that
inspections can establish if compliance has been maintained along the different operators. Without
such traceability systems it may be impossible for a CA to establish the nature and cause of any
potential problems.
27
chain overseen by a processing state.
► TABLE 5
processing state
Processing state
Importation Authorization Point of importation Customs pre-clearance Coordination in between

of imports customs and fisheries is
fundamental
Unique operator identifier/ Customs pre-clearance Identifier associated with the

importer Legal fisheries and business operator for the duration of its
operator are to be registered existence that cannot be re-
for existing regulatory used by any other operator
customs, health, tax, etc.
Unique seafood material Unique identifier for item/ No single source exists, yet the
identifiers SKU/UPC/GTIN more standardization, the better
Batch/lot number, serial identifier of seafood material
number, or container to distinguish it within a
number particular facility, company, or
GDST KDE W01, W02 globally
Identifier associated with
physical product marking a
particular instance of seafood
material such as a batch/lot
number, serial number, or
container number
Verified net volume, forms ASFIS list of species Codes for units of measure used
and species received Species, scientific name/FAO in international trade
GDST KDE W03, W15, W16 3-Alpha code (e.g. YFT)
Detailed invoices, certificates,
packing lists and bill of landing
Sanitary status of imported Sanitary status of exporting Proof of sanitary status and
products country and harvesting vessel control by the CA
(from European Union or
Chinese listing)
Distribution Product splits Unique product identifier Unique identifier for item/
(initial and GDST KDE W01, W02 SKU/UPC/GTIN
later) Batch/lot number, serial
number or container number
Unique identifier of buyer Legal fisheries and business

operators are to be registered
for existing regulatory
health, tax, etc.
Verified net volume, forms ASFIS list of species Codes for units of measure used
and species received Species, scientific name/FAO in international trade
GDST KDE W03 W15, W16 3-Alpha code (e.g. YFT)
Detailed invoices, certificates,
packing lists
Lot tracing/product reports/
inventory
Receiving, Processing / Processing establishments Unique operator identifier Legal fisheries and business
storage and transformation unique operator identity identifier associated with the operators are to be registered
processing operator for the duration of its for existing regulatory
existence that cannot be re- frameworks under fisheries,
used by any other operator health, tax, etc.
28
(Cont.)
Processing state
Receiving, Processing / Unique product identifier Unique identifier for item/ Linking identifier associated
storage and transformation GDST KDE W01, W02 SKU/UPC/GTIN with physical product marking
processing Batch/lot number, serial a particular instance of seafood
number or container number material such as a batch/
lot number, serial number,
or container number from
reception to exit of the premises
is fundamental for these KDEs
Volumes, form and species Detailed invoices, certificates, Codes for units of measure used
acquired packing lists, lot allocation/ in international trade
GDST KDE W03, W15, W16 product reports/inventory ASFIS list of species
Species, scientific name/FAO
Volumes, form and species Lot tracing/product reports/

in storage inventory
Volumes, forms, and species Lot tracing/product reports/

entering processing inventory processing orders
Volumes, forms and species Lot tracing/product reports/

processed inventory processing orders
GDST KDE W03, W15, W16 Processing yields
Volume, form and species Lot tracing/product reports/

for rendering/fishmeal inventory processing orders
GDST KDE W03, W15, W16 Processing yields
Sanitary status of Proof of sanitary status and Market access condition

processing establishment control by the CA
Product dispatch Domestic Unique identifier of buyer Detailed invoices, certificates,

/ trade distribution packing lists
of finished
products Volume, form and species Detailed invoices, certificates,
sold packing lists
Exportation Name of buyer/foreign Detailed invoices, certificates,

or re- consignee packing lists and bill of landing
exportation
of semi- Volume, form and species, Detailed invoices, certificates,
finished/ batch number sold packing lists and bill of landing
finished GDST KDE W02, W03, W15, Batch/lot number, serial
products W16 number or container number
Sanitary status Health certificate Market access condition
3.7 END MARKET STATES
End market states are the states where fishery products are sold as consumer goods, albeit they can
also be flag, port and processing states simultaneously. This section considers the final importation
of fishery products as consumer goods. The main responsibility of end market states is to ensure that
imported fishery products do not enter national territories without valid traceability unique identifiers
linking to other types of states, CTEs and KDEs.
End market states need various mechanisms to implement their role in traceability.
29
The first is the involvement of fishery authorities in overseeing importation and legal requirements
before border clearance. This is because imported products normally enter countries through
commercial ports, which are often outside the purview of fishery authorities.
Fishery authorities must be involved in verification and authorization with customs, health and
biosecurity authorities to ensure that only legally sourced and certified products enter a territory.
The authority must have statutory powers to deny entry to non-compliant consignments, which
normally requires the development of new regulations.
A system of prior notification and authorization for imports must be in place. Fishery authorities
can either undertake their own verifications within a traceability system, or do so in coordination with
customs authorities.
In the case of fish fraud, to establish wrong-doing and to know a product’s place of origin or the
species in a sample or consignment, CAs must rely on other means of investigation, such as genetic
analysis.
As in the case of legality, the main responsibility at end market state level is to ensure that imported
fishery products do not enter national territories without valid sanitary certification and the traceability
associated with the value chain.
Any potential verification of the traceability systems of the providing states (e.g. port or processing)
is to be tested in a cooperative manner so as to be trusted by commercial partners.
chain overseen by an end market state.8
► TABLE 6
Main supply chain stops, CTEs and KDEs identified for a standard supply chain overseen by an
end market state
End market state
Importation Authorization Point of importation Customs pre-clearance

of imports
Unique operator identifier/ Customs pre-clearance Identifier associated with the

importer Legal fisheries and business operator for the duration of its
operator are to be registered existence that cannot be re-
for existing regulatory used by any other operator
health, tax, etc.
Unique seafood material Unique identifier for item/ Identifier of seafood material to
identifiers SKU/UPC/GTIN distinguish it within a particular
GDST KDE W01, W02 Batch/lot number, serial facility, company, or globally
number or container number
Verified net volume, forms Detailed invoices, certificates,

and species received packing lists and bill of landing
8
All co-mingling or mixing, aggregation and disaggregation, or splitting of batches or units must be tracked and all KDEs
associated with new units and previous units must be tracked. In addition, changes of legal ownership or physical possession (e.g.
a transportation subcontractor) must be tracked. These events are not included in every table, as this could happen throughout
supply chains, and even several times under the oversight of one “owner” or during one “event”. The GDST Core Normative Standard
addresses this topic in more detail.
30
(Cont.)
End market state
Importation Authorization Sanitary status of imported Sanitary status of exporting Proof of sanitary status and
of imports products country and harvesting vessel control by the CA
(from the European Union or
Chinese listing)
Domestic Distribution Unique seafood material Unique identifier for item/ Identifier of seafood material to
Distribution events, by identifiers SKU/UPC/GTIN distinguish it within a particular
importer GDST KDE W01, W02 Batch/lot number, serial facility, company, or globally
Product splits number or container number
(initial and
later) Unique identifier of buyer Legal fisheries and business
operator are to be registered
for existing regulatory
health, tax, etc.
Verified net volume, forms Detailed invoices, certificates,

and species received packing lists
Wholesaler Verified net volume, forms Detailed invoices, certificates,

buyer and species, batch number packing lists
received
GDST KDE W02, W03, W15,
W16
31
4. CRITICAL TRACKING EVENTS
AND KEY DATA ELEMENTS
IN AQUACULTURE
4.1 INTRODUCTION
In this section, we refer generally to “aquaculture products” as the culture of finfish, crustaceans and
molluscs.
The authorities regulating aquaculture play a crucial role in the development, planning and
implementation of production and trading systems. Hence, traceability requirements need to be
included from the earliest stages of development and verified all along the value chain.
The increasing complexity of aquaculture value chains is as a result of many requirements being
added to the regulatory realm of food safety-related traceability, such as requirements relating to
property; or permits for the use of the production areas; license registers; and environmental and
labour conditions that are becoming market access issues in aquaculture production. Therefore, the
responsible authorities must be able to access the information that allows them to verify compliance.
In general terms, the traceability requirements for aquaculture have been driven by market access
conditions for those intending to export their products. Traditionally, this was the realm of the national
CA which provides verification against applicable standards (which include specific requirements
normally referring to infrastructure, hygiene conditions, HACCP, operations, traceability, labelling, etc.).
However, the utility of good traceability has expanded to other regulatory (and private) requirements
working in parallel with these food safety aspects.
4.2 FEED PRODUCTION AND DISTRIBUTORS
Feed and fertilizer play an important role in the successful production of fish and other aquatic food for
human consumption. They are often a significant cost in aquaculture operations.
In 2010, FAO published comprehensive and practical guidelines to assist producers and stakeholders
along the production and distribution chain to comply with the regulatory framework which has or will
come into force in response to the Codex Alimentarius Code of Practice on Good Animal Feeding.
Traceability/product tracing of feed and feed ingredients, including additives, should be enabled by
proper record keeping for timely and effective withdrawal or recall of products if known or probable
adverse effects on consumers’ health are identified (FAO and IFIF, 2010).
An increasing number of countries have specific regulatory requirements for animal feed and raw
materials used in the production of aquafeed. These requirements are usually met by the registration
of the feed formula with the relevant CAs which constitute a positive list of feed authorized to be used.
Feed producers are registered and licensed as per their compliance with official controls.
Animal feed and raw materials for the production of aquafeed must meet the minimum requirements
in the applicable regulations (e.g. maximum residues of contaminants, microbiological criteria, etc.)
32
4. Critical tracking events and key data elements in aquaculture
before products are traded. Therefore, traceable management of conformity assessments is critical, in
particular when imported products are used. Hence, importers and their imports should have unique
operator identifiers and unique materials identifiers and thus keep records of origin, storage and
destination of each imported batch.
Table 7 identifies the main supply chain stops, CTEs and KDEs identified for feed production and
distribution. The table is designed to suit the production of commercial feed but farms manufacturing
their own feed could also use it. In this case, farms have to comply with the national requirements in
term of licensing for feed production, when applicable.
► TABLE 7
Main supply chain stops, CTEs and KDEs identified for feed production and distribution
Feed production and distribution
Supply chain stage CTEs Main KDEs Data source Comments
Feed production Feed Name and details of feed Unique indicator generated by A licensing and/or authorization
producer manufacturer including the authorities in the country system of feed producers should
details in-house sources using a of operation that gives the be implemented
unique operator identifier licence to operate
GDST KDE A05
Location (at least country) Aquaculture business Location must be linked with
of operation, Location ID, public register, maps, GPS the operation licence, since
address coordinates the place must be approved for
GDST KDE A07, A08, A09 installing the facility
Processing Production date, feed expiry Production records Based on implementation of

info date Labelling information good manufacturing practices
GDST KDE A19 and internal minimum
traceability system

Unique seafood material Unique identifier for item/ Identifier of food material to
identifier for feed type SKU/UPC/GTIN distinguish it within a particular
produced, brand, pellet size Lot/batch facility, company, or globally
GDST KDE A01 Production records, labelling
information
Main ingredients (source of Commercial feed formula Operators should establish

protein) Seafood species Feed ingredients list/ and maintain effective record
name (if applicable) certificate of origin/sales keeping about the source of
GDST KDE A14, A04 order/delivery order ingredients and raw materials
used in the production of
aquafeed
Batch volume, weight, Production records This allows the ingredients’

quantity of units Lot tracing/product reports/ mass–balance, especially for
GDST KDE A03 inventory processing orders fishmeal and fishery-derived
ingredients
Batch number, serial Production records The feed products traded should
number, or container Lot tracing/product reports/ be identified per traceable unit
number inventory processing orders (either batch of feed sold in bulk
GDST KDE A02 or feed bag).
Selling units, number of Invoices, inventory records,

units delivery bill
Feed Sale info Selling date Invoices, inventory records,

commercialization packing list
Name and details of first Unique indicator generated by

buyer using a unique the authorities in the country
operator identifier of operation that gives the
licence to operate
33
(Cont.)
Feed production and distribution
Batch number, serial Invoice, transport documents, This allows every batch of feed
number, or container packing list to be traced to and from the
number farm
GDST KDE A01, A02
Batch volume, weight, Invoice, transport documents,

quantity of units packing list
GDST KDE A03
4.3 HATCHERY/NURSERY/SEED GROWING
Aquaculture has been made possible through the use of hatchery-bred seed. The supply of seed of
common aquaculture species has been key to the growth and intensification of the aquaculture sector.
A licensing and/or authorization system of hatcheries/nurseries, with a clear identification of
their location, is the basis of most regulatory frameworks for the sector. Hatcheries/nurseries should
establish and maintain effective record keeping from the receiving of the broodstock and/or seeds
and subsequently cultivating them into seedlings or fish fry on the basis of the internal minimum
traceability system.
Hatcheries/nurseries should maintain records internally for all laboratory results certifying the
health of the broodstock and seed. Movement of seed may be controlled through movement documents
between the hatchery and the growing farm(s) and health certificates.
Hatchery and nursery operations, and in particular the feeding, feed management and the sanitary
treatments, should be recorded.
Once harvested, the harvesting record, commercial documents, transport documents and
documents of origin should be issued and accompany the seed to the farms/grow out areas. When there
are no hatcheries and seed comes from the wild – as in the case of some bivalves and finfish – or in the
case of ranching, or for nursery operations receiving seeds from hatcheries, it is necessary to record
the collector, permit/licences, species, area, movement, means of transportation, date of collection,
date of stocking, amounts, etc. CAs should ensure that the collecting areas have been approved for
extraction and a unique code must be assigned to each operator, which allows for identification of the
legal origin of the seed.
Table 8 identifies the main supply chain stops, CTEs and KDEs identified for hatchery/nursery/
seed growing.
34
► TABLE 8
Main supply chain stops, CTEs and KDEs identified for hatchery/seed growing
Hatchery/nursery/seed growing
Hatching area/ Hatchery Name and details of Unique indicator generated by Identifier of operator to
nursery/ identity and hatchery using a unique the authorities in the country distinguish it from others
Seed growing details operator identifier of operation that gives the A licensing and/or authorization
GDST KDE A06 licence to operate system of hatcheries should be
implemented
Broodstock Unique identifier for Unique identifier for item/SKU Identifier of broodstock to
info broodstock /UPC/GTIN distinguish it within a particular
GDST KDE A01, A02 lot/batch/tank facility, company, or globally
High-value species may have
unique codes, otherwise code is
attached to batch or tank
Considerations with exotic
species, yet these fall under
biosecurity rather than
traceability per se
Broodstock reception date, Detailed invoices, transport Broodstock are either produced
origin, seller documents, origin certificates domestically, sourced from the
GDST KDE A11 Buy or catch records of wild, or imported from another
broodstock, invoices, country. If imported, then the
production records import documents can be used
Pre-customs clearance as data source also
documents In any case, the movement of
the animals has to be traceable
Species name ASFIS list of species Species have to be clearly

GDST KDE A04 Sampling records, history of identified for commercial
strain development documents aquaculture
(when available) History of strain development
documents may be added to
support the identification of the
species
Non-authorized species should
not be farmed under biosecurity
requirements and therefore
should not appear in the
traceability system
Sanitary and/or epizootic Registers, health certificate, Proof of animal health status
status laboratory reports Health certificate issued for
Production records/farm book the CA, or a CA-authorized
for sanitary treatments laboratory
Record of treatments,
contaminants, supplements,
additives
Seed source Unique fish material Unique identifier for item/ Identifier of seed material to
(for nurseries) identifier for seed SKU/UPC/GTIN distinguish it within a particular
GDST KDE A01, A02, A03, Lot/batch/tank facility, company, or globally
A06 along with its components
For input of seed from
elsewhere – other hatchery or
from the wild Means of verifying
origin if from the wild, e.g.
proof/document of legal origin;
import documents or legal
status of catch area; link with
requirements on the source of
broodstock
Location Location (at least country) Aquaculture business Location must be linked with
of operation, location ID, public register, maps, GPS the operation licence, since
address coordinates the place must be approved for
35
(Cont.)
Hatching area/ Feed info Name of feed manufacturer Detailed invoices, delivery bills Identifier of supplier to
nursery/ Unique identifier of seller distinguish it from others
Seed growing GDST KDE A05 Hatcheries/nurseries must keep
information about their feed
suppliers, e.g. distributors and
feed producers. Feed labels are
often kept as records
For imported feed passing
through a local distributor,
information on the feed
producer, such as its unique
identifier, may not be available.
The minimum information to be
recorded should be visible on
the feed packaging (bag) and/
or labels
Feed brand, type, pellet size Detailed invoices, production When fresh food, such mussels,
GDST KDE A01, A03, A04 records clams, squids, etc, is used as
feed for broodstock, information
about the source, species,
treatments/contaminants,
volume and sanitary status of
live, fresh or frozen food must be
recorded and kept accordingly
Feed batch number, feed Feed invoices, certificates, Identifier associated with the
expiry date lot tracing/feeding records, physical product marking a
GDST KDE 02 feed labels particular instance of seafood
material. Relevant information
for traceability
Volume purchased Feeding records/inventory Numerically quantifiable amount

GDST KDE 03 records of feed with a standard unit of
measure
Usually number of bags of
commercial feed
Sanitary Veterinary drugs and Name of veterinary drugs Approved list of authorized
treatments chemicals used and chemicals used. Active veterinary drugs and chemicals
principle, time, date and should be available
dosage (withdrawal period) Information required for market
access
When controlled substances
are used, tests to determine
the residue level should
be performed according
to national/international
regulations and standards
before processing and selling
the harvested product
Harvest info Harvesting date Harvest records Date on which fingerlings were
GDST KDE A10 transferred to the grow out
farm/pond/tank/pen/cage
Harvested volume/weight/ Harvest record Numerically quantifiable amount

quantity/age/size or life of seafood with a standard unit
stage of measure
GDST KDE A03 In the case of partial harvest,
this needs to be mentioned

GDST KDE A04 Species, scientific name/FAO identified since there are
3-Alpha code (e.g. YFT) some endangered species
Harvest record non-authorized for commercial
aquaculture.
36
(Cont.)
Hatching area/ Harvest info Unique fish material Unique identifier for item/ Identifier of seed material to
nursery/ identifier for seed SKU/UPC/GTIN distinguish it within a particular
Seed growing GDST KDE A01, A02, A06 lot/batch/tank facility, company, or globally
Harvest records, detailed along with its components
invoice, transport documents, Records should record splitting
documents of origin or combining of lots or sources,
etc.

GDST KDE A04 Species, scientific name/FAO identified since there are
3-Alpha code (e.g. YFT) some endangered species
Harvest record non-authorized for commercial
aquaculture.
Unique fish material Unique identifier for item/ Identifier of seed material to
identifier for seed SKU/UPC/GTIN distinguish it within a particular
GDST KDE A01, A02, A06 lot/batch/tank facility, company, or globally along
Harvest records, detailed with its components
invoice, transport documents, Records should record splitting or
documents of origin combining of lots or sources, etc.
Name and details of buying Harvest records, detailed The unique indicator generated
farm for grow-out using a invoice, transport documents, by the authorities is ideal for
unique operator identifier documents of origin the harvest records. When it
is unknown to the seller, as
much information as possible is
required for traceability
Sanitary and/or epizootic Registers, health certificate, Proof of animal health status
status laboratory reports Health certificate issued for
the CA, or a CA-authorized
laboratory
Record of treatments,
contaminants, supplements,
additives
Results of controls made in
relation to the sanitary and/or
epizootic status made by the
CAs should be recorded
When applicable, a copy of the
health certificate required by
the processing or market state
should be kept
4.4 FARMS/GROWING AREAS
Operators involved in farms and growing areas are required to maintain and demonstrate a minimum
set of requirements for their traceability systems, such as:
registration/licensing system that includes mapping of productions units, such as ponds, marine
cages and growing areas, which, along with supporting registration and licensing information,
form the basis for traceability, in addition to approval of farming operations that reinforce the
identification system;
conformity assessment against national regulations and international standards;
seafood safety, epizootics and animal welfare requirements;
the origin, safety and quality of the farm inputs, i.e. seeds, feed and chemicals are to be recorded
so that they can be potentially traced in case of non-conformity along the chain; and
sanitary status of culture areas.
37
Farms should establish and maintain effective record keeping from the receiving of the seed, to the
harvest of the aquaculture products. A traceable unit should be the quantity of products harvested
from one production unit with identical production conditions: at the farm, it is usually the harvest
from one production unit.
Minimum farming input and parameters should be recorded for each identified unit:
origin of the seeds, fish seedlings or fish fry;

feed used and quantities;
record of any drugs and chemicals; and
harvest date, quantity and client information.
Movement of aquaculture products may be controlled through movement documents between the
growing farm(s) and the collectors and/or processors. This is usually where aquaculture products are
split and/or mixed.
Table 9 identifies the main supply chain stops, CTEs and KDEs identified for farms/growing areas.
► TABLE 9
Main supply chain stops, CTEs and KDEs identified for farms/growing areas
Farms/growing areas for bivalves
Farm/growing Growing area/ Name and details of growing Unique indicator generated by Identifier associated with the
area farm identity area/farm using a unique the authorities in the country operator for the duration of its
and details operator identifier of operation that gives the existence to distinguish it from
GDST KDE A15 licence to operate others
Location, GPS coordinates, A licensing and/or authorization
business licence, identifiers system of farms and growing
for ponds, tanks and pens/ areas should be implemented
cages Information about location
must be declared in the official
documents to guarantee the
origin of the product in the
traceability system
Consideration should be given to
identification of small producers
Location (at least the Aquaculture business Location must be linked with the
country) of operation, public register, maps, GPS operation licence because the
location ID, address coordinates location must be approved for
Stocking Species name ASFIS list of species Species have to be clearly

information GDST KDE 04 Species, scientific name/FAO identified for commercial
3-Alpha code (e.g. YFT) aquaculture
Sampling records

Name of supplier (hatchery Unique identifier of the If the official unique identifier
that supplied the fry/ hatchery is unknown, a list of hatcheries/
fingerlings to farm for grow nurseries supplying the farms
out, including in-house should be recorded
sourced)
GDST KDE A06
Unique fish material Unique identifier for item/ Identifier of seafood material to
identifier for stocking SKU/UPC/GTIN distinguish it within a particular
animals (from hatchery/ Lot/batch/tank facility, company, or globally
nursery)
GDST KDE 01, 02
38
(Cont.)
Farm/growing Stocking Stocking date Detailed invoices, delivery Harvest date of the seeds is
area information GDST KDE A10 documents (from hatcheries/ important to record as well
nurseries), production records Age/size/life stage of seeds can
be also recorded here
The age of the post larvae/seeds
can be calculated from the
stocking and harvest date at the
hatchery
Pond/cage/tank/pen ID (at Unique identifier for pond/ Information detailing farm layout
the farm) cage/tank/pen or growing area or company
information that allows the
identification of the pond/cage/
tank/pen where the animals are
grown in a specific time frame
Stocking quantity Detailed invoices, delivery Verifiable number of animals

documents (from hatcheries/ stocked in the production unit
nurseries), production records Mortality should be taken into
consideration because quantity
stocked and quantity harvested
at the hatchery/nursery may not
match
Feeding Name of feed manufacturer Detailed invoices, delivery bills Identifier of supplier to
information including in-house sources distinguish it from others.
GDST KDE A05 Farms must keep information
about their feed suppliers, e.g.
distributors and feed producers.
Feed labels are often kept as
records
Feed brand, type, pellet size Detailed invoices, production Complete information about
GDST KDE A01 records feed used for every batch of
animals has to be recorded for
traceability
Feed batch number, feed Feed invoices, certificates, Identifier associated with
expiry date lot tracing/feeding records, physical product marking a
GDST KDE A02 feed labels particular instance of seafood
material. Relevant information
for traceability
Volume of feed purchased Farm production records, Numerically quantifiable amount

GDST KDE A03 inventory records of seafood with a standard unit
of measure
Additives used Name of additives used. Approved list of authorized

Active principle, time and additives should be available
dosage Information required for market
access
Sanitary Veterinary drugs and Name of veterinary drugs Approved list of authorized
treatments chemicals used and chemicals used. Active chemicals should be available
Name and details of client principle, time, date and Information required for market
(distributor or processing dosage access
plant) using a unique Production records/farm book When controlled substances
operator identifier are used, tests to determine
Aggregator name and ID the residue levels must be
GDST KDE A21, A22 performed before processing
and selling the harvested
product
Harvest Harvesting date Harvest records Calendar date on which the

information GDST KDE A16, A10 seafood was harvested from the
farm/cultivation area
Harvested volume/weight/ Harvest records, detailed

quantity, batch number, invoice, transport documents,
seafood material identifier documents of origin
GDST KDE A03, A02, A01
39
(Cont.)
Farm/growing Harvest Harvesting date Harvest records Calendar date on which the
area information GDST KDE A16, A10 seafood was harvested from the
farm/cultivation area
Harvested volume/weight/ Harvest records, detailed

quantity, batch number, invoice, transport documents,
seafood material identifier documents of origin
Name and details of client Harvest records, detailed The unique indicator generated
(distributor or processing invoices, transport by the authorities is ideal for
plant) using a unique documents, movement the harvest records. When it
operator identifier documents is unknown to the seller, as
Aggregator name and ID much information as possible
GDST KDE A21, A22 is required for traceability and
market access
Farming method Farming and harvest records A combination of type of culture,

GDST KDE A17 unit, level of intensity, culture
species and scale or size of
exploitation as defined by FAO
4.5 COLLECTOR/DISTRIBUTOR/TRADERS/AGGREGATORS
In many countries, there are intermediaries in between harvest and processing who may be independent,
associated with producer organizations, or associated with processors. They can also be a part of the
processing plants. For clarity, in this document this role will be called “distributors”. The GDST qualifies
these intermediaries as “aggregators”.
The distributors may be involved with the farm operators during the harvesting process and can
split harvest volumes or mix them with products of other farms prior to delivery to the processors.
Therefore, it is critical that they are under the structure of the traceability schemes associated with
the regulatory requirements in place.
A registration system for distributors needs be in place based on the criteria for unique operator
identifiers.
Ideally, the distributors should maintain the granularity of the minimum set of KDEs associated with
those of the farms for each lot received and further distributed. However, this is not always practical or
possible (e.g. from small-scale farmers or from extensive farmers) and in such cases, the distributors
shall record information about what was mixed and how the new mixed lot is now identified.
Distributors’ operations normally include the transport of harvested aquaculture products, but can
also extend to grading, cleaning and forwarding. Therefore, they should keep records that allow for the
unique identification of products and volumes in regard to sources and destinations.
Distributors may receive products from several suppliers, or from the same supplier but in different
batches, which they may want to mix. They may also split batches due to size grading. Ideally, in such
cases records of what is mixed – and at which step – should be kept and a unique identifier should be
given to the new mix.
An alternative solution would be for the distributors to record the names/identifiers of the
suppliers delivering aquaculture products over a day or a shorter specific period of time in a day (e.g. a
working shift). At the processing stage, daily reception of aquaculture products and distributor names
40
are recoded. If a trace-back is required, the farms that delivered aquaculture products on a given date
can be contacted and the relevant information could be requested and investigated. A traceable unit
should be the quantity of products graded and mixed in a lot, with links to the farm(s) of origin.
4.6 PROCESSING
While in most instances farming and processing occur in the same state, the practice of sending raw
materials to countries with lower processing costs for value adding is becoming more common in
aquaculture (following a similar trend to that seen in fisheries). Therefore, a system needs to cover
the entire chain of events by means of a national traceability system that traces product from landing,
or importation at ports of arrival, through ownership changes and processing exportation or re-
exportation. What is needed is for traceability systems to cover events between entry and exit “gates”
(into and out of the country) so that regulatory controls can establish where anomalies occur and
identify those responsible. These controls must cover:
Registration and licensing of storage and processing premises to identify value chain operators.
In most countries, the storage and processing premises of aquaculture products must be
licensed and controlled by authorities, which amounts to a traceability and record keeping
system that can support traceability.
Distribution and transfers among operators’ premises. Registration of internal movements of
declared species and volumes makes them traceable; these require strict adherence to the main
KDEs identified for the operator’s unique identity and unique seafood material identifiers in
Section 3.2.
Assurance that raw materials/products are coming from farms and distributors identified in the
traceability scheme, and that they comply with the minimum traceability requirements.
The recording of products leaving operators’ premises, regardless of destinations. Regular
verification by CAs of pre-dispatch checks and consignment loading records will ensure the
effectiveness of traceability systems at the level of individual operators.
At the processing stage, combining and splitting batches and production codes depending on the
type of products and specific customer requirements must follow the standard practices for these
transactions to preserve traceability.9
The information provided on the product and content of sales documents (e.g. invoices and health
certificates) may contain additional information about the history of the product if required by the
buyer or by law. If needed, this information can be used to begin a trace-back or a product recall.
Table 10 identifies the main supply chain stops, CTEs and KDEs identified for the processing of
aquaculture products.
9
All co-mingling or mixing, aggregation, and disaggregation or splitting of batches or units must be tracked and all KDEs
associated with new units and previous units must be tracked. In addition, changes of legal ownership or physical possession (e.g. a
transportation subcontractor) must be tracked. These events are not included in every table, as this could happen throughout supply
chains, and even several times under the oversight of one “owner” or during one “event”. The GDST Core Normative Standard addresses
this topic in more detail.
41
► TABLE 10
Main supply chain stops, CTEs and KDEs identified for processing of aquaculture products
Distribution and processing plants
Distribution Distribution Name and details of Unique indicator generated by Identifier associated with the
events distributor using a unique the authorities in the country operator for the duration of its
Product splits operator identifier of operation that gives the existence to distinguish it from
(initial and GDST KDE A21 licence to operate others
later)
Movement date Harvest records, detailed Date of transportation from

invoice, transport documents, the farm or delivery at the
documents of origin distributor facilities
Transport vehicle identifier Transport documents Transport vehicle identifier

For example, registration Consideration should be given to
plate of vehicle or any other small-scale producers
means of identification
e.g. accreditation number
of vehicle with CA, type of
vehicle.
Product Unique seafood material Unique identifier for item/ Identifier of seafood material to
information identifier SKU/UPC/GTIN distinguish it within a particular
GDST KDE 01 Lot/batch/tank/pen/cage facility, company, or globally
Species name ASFIS list of species

GDST KDE A04
Species, scientific name/FAO
Sampling records
Verified net volume/weight/ Harvest records, transport

quantity, form, batch documents, invoices,
number movement documents
GDST KDE A03, A02
Product form Harvest records, detailed Commercial short-hand

GDST KDE A18 invoice, transport documents, reference of the degree of
documents of origin transformation of seafood from
its original living form
Processing Processing/ Name and details of Unique indicator generated by Identifier associated with the
transformation client (distributor or the authorities in the country operator for the duration of its
processing plant) using a of operation that gives the existence to distinguish it from
unique operator identifier license to operate others.
registration/ approval
number (Food and Drug
Administration of the
United States of America,
European Union, etc.)
Processing plant details,
product origin
GDST KDE A01, A06, A07,
A21, A20
Reception date Harvest records, detailed Date of reception at the

invoice, transport documents, processing plant should be
documents of origin as soon as possible after the
harvest

GDST KDE A04 Species, scientific name/FAO identified because there are
3-Alpha code (e.g. YFT) some endangered species not
Sampling records authorized for commercial
aquaculture
Verified net volume/weight, Reception records, detailed

forms and species entering invoices, certificates, packing
processing, batch number, lists, delivery bill
production date
42
(Cont.)
Distribution and processing plants
Processing Processing/ Verified net volume/weight, Processing records

transformation species for rendering/
fishmeal, batch number
Product form Harvest records, transport Commercial short-hand

GDST KDE A18 documents, invoices reference of the degree of
transformation of seafood from
its original living form
Domestic Unique identifier of buyer Business operators are to

distribution be registered for existing
of finished regulatory frameworks under
products health and food safety, tax,
etc.
Verified net volume, forms Processing records, detailed

and species received, batch invoices, certificates, packing
number lists
Exportation Name and details of client Business operators are to

or re- (buyer/consignee or be registered for existing
exportation processing plant) using a regulatory frameworks under
of semi- unique operator identifier health and food safety, tax,
finished/ etc.
finished
products Delivery date Processing records, detailed
invoices, certificates, packing
lists
Verified net volume/weight, Processing records, harvest

form and species sold, records, detailed invoices,
batch number certificates, packing lists,
GDST KDE A02, A03, A04, A18 delivery bill, product label,
purchase order
Unique identifier of first Last business operator is

buyers and distributor’s to be registered for existing
name regulatory frameworks under
health and food safety, tax,
etc.
4.7 SPECIAL CONSIDERATIONS FOR BIVALVES
Unlike fish and crustaceans, bivalves are filter feeders that could accumulate certain contaminants
present in the culture water and require special attention in terms of sanitary controls. The authorities
of the countries in which bivalves are grown, processed and commercialized should pay special
attention to traceability aspects related to the growing areas, and incorporate data on water monitoring
to control the presence of pathogenic microorganisms, environmental contaminants and biotoxins.
Table 11 identifies the particular chain stops, CTEs and KDEs identified for bivalve aquaculture and
wild capture products. While some KDEs in the table align with GDST KDEs, the GDST materials do not
identify special considerations for bivalves. Following the processing step in Table 11, the KDEs would
be the same as those in Table 10 for distribution and processing.
43
► TABLE 11
Particular supply chain stops, CTEs and KDEs identified for bivalve aquaculture products
Bivalve
Hatching area/ Name and details of Production area: Production area maps Location should be
seed growing hatchery using a unique GPS coordinates of the established by the CA identified because
operator identifier/ collecting area that water quality has to
location supplied the seed be monitored. If seed
GDST KDE A06, A07, A08, Unique indicator comes from the wild,
A09 generated by the then operator should
authorities in the country have an ID and licence
of operation that gives the number, and seed
licence to operate should be collected
from authorized areas;
information has to be
traceable
Growing area Production area GPS coordinates of the Production area maps Areas should be officially
Source of stock collecting area that established by the CA, monitored for identified
GDST KDE A10, A11 supplied the seed laboratory monitoring risks so as to maintain
Unique indicator tests results its open status
generated by the
authorities in the country
of operation that gives
the licence to operate/
classification of the water
area
Harvest Date of harvest Calendar date on Harvest records

GDST KDE A16 which the seafood was
harvested from the farm/
cultivation area
Processing Depuration/clearing/ Sanitary status of product Monitoring reports

treatments lot/batch
Note: These apply in addition to previous tables for hatchery, growout and processing and apply to entities involved in shellfish production and
handling.
In most major markets, importers and distributors help to ensure that only products compliant
with local legislation are placed on the market. As they are the intermediaries between producers and
retailers, they must have comprehensive knowledge of the legal requirements and make sure that the
products they distribute or import meet them. Importers must check that products fulfil all safety,
health and environmental protection requirements before placing them on the market. Distributors
must handle the product carefully and must not affect the integrity of the packaging so as to avoid
contamination, respect the temperature control indications, etc.
The identified KDEs and CTEs for end-market states are the same for wild capture fishery products
in Table 6. Generally, the distinction in origin (wild/farmed) is not captured once fish products enter
international trade, though some countries do make the distinction in their trade data and are
encouraged to do so.
44
5. DISCUSSION
The many and varied advantages that effective traceability systems provide were summarized by Lewis
and Boyle:
In the last decade, a range of drivers within the seafood sector have incentivized the application of traceability
to issues beyond food safety and inventory management. Some of the issues motivating the expanded use of
traceability within the global seafood sector include: increased media attention on the legal and social risks
within some seafood supply chains, governmental traceability requirements, private‐sector sustainability
commitments, and others.
(Lewis and Boyle, 2017)
The aim of this guidance document is to support countries by providing technical advice on the
CTEs and KDEs required for robust traceability along the seafood value chain, and the identification
of supporting verification mechanisms for official assurance. The guidance document also introduces
leading private sector-led initiatives across the seafood value chain as the substrate over which
electronic traceability-type solutions can work.
There are many intrinsic and extrinsic challenges in implementing successful and cost-effective
traceability. These challenges have created some issues for the operators and the CAs in control of food
safety, particularly when engaging in transnational trade.
The GDST initiative correctly identified the opportunities that new digital technologies present for
making traceability more possible and affordable than ever, but effective and widespread traceability
has faced two major obstacles:
i. Inconsistent demands and formats for information coming from regulators, private
certifications, and even retailers or other downstream companies. This has led to confusion,
higher compliance costs and lower motivation among producers.
ii. Incompatible digital information management systems resulting from the large number
of uncoordinated CTEs/KDEs, standards, traceability solutions and solution vendors. This
impedes information flow while causing rigidity in business relations and raising barriers to
onboarding new suppliers and customers.
By compiling and analysing the CTEs and KDEs from the regulatory realm and incorporating the
applicable ones from the non-regulatory realm, this document hopes to facilitate the development of
traceability systems that extend over the whole value chain.
The best-case scenario would be that many of the same CTEs and KDEs would be adopted globally
for seafood supply chains. If this could be accomplished, many of the challenges relating to traceability –
such as inconsistent data formats and interoperability challenges – would be reduced and the resources
of companies and governments could be redirected toward verifying the information in the systems and
other improvements.
45
Nevertheless, the authors are very aware that no “one size fits all” solution is possible, and that the
views, CTEs and KDEs presented here constitute guidance only, and may not be applicable in their
entirety for some products, or even for the same product in different jurisdictions.
Yet, two issues have been identified not only in this guidance document, but also in prior ones
(Blaha, Borit and Thompson, 2015) and these remain a non-technical challenge:
Different authorities
Even if traceability systems are well designed and generally well implemented, they can fail with a lack
of implementation at a single step. Therefore, it is vital to ensure coordination between the different
operators in the production chain and in the control of traceability systems by the CAs involved.
For example, the understanding that IUU happens “at sea” is the one CTE where most of the relevant
fishing data (KDEs) are recorded. Besides this being the easiest point to perform this activity, it is
possible that this situation is due to the traditional view that MCS (including traceability as a tool for
MCS) is something that only happens at the vessel and wharf level, and does not concern processing
and the risks of laundering illegal fish. While at the same time the sanitary CA (which requires many
of the same KDEs) does not extend its oversight to the vessels and wharfs, nor integrates and cross-
checks acquired data with the fisheries authorities.
National (in country) and across-countries traceability

A further topic of importance is the integration of cross-countries (between countries) and national
(inside the country) traceability, particularly in the light of many countries with excess processing
capacity and low labour costs that import fish and fishery products for further processing and re-
export (e.g. China, Viet Nam and Thailand).
National traceability is organized by national administrations and governed by national laws.

While many countries require traceability, especially requirements associated with exports to an
international market, it is often enforced with varied degrees of effectiveness. Few to no countries
provide standardized CTEs and KDEs and electronic traceability systems where specific types of
products are electronically traced through the entire national supply chain from point of landing/
import to point of export/re-export.
The cross-countries traceability (in between countries) stops at the point of entry into a country
and restarts at the point of exit. If a product does not re-emerge as an export following landing or
import, it is deemed to have gone into domestic consumption.
This understanding is to be incorporated into the traceability system’s design so as to accommodate
the reality that in many countries, the largest importers of fish raw materials are not processors but
diversified import–export companies. These companies are sometimes servicing a variety of food-
related sectors, and often supply to and distribute fish on behalf of, large, and probably small, re-
processors. Although this service comes at a price, it may offer essential flexibility in the dynamic
channelling of raw material to a network of factories as market conditions change. Although this
situation is perfectly legal, the fact that fish may change hands one or more times while in the country
has implications for traceability systems.
Finally, interoperability will be always be a challenge to implementing new technology because of the
lack of traceability standardization in seafood value chains – both from a technical perspective, where
existing traceability systems may not be able to talk to each other, and also from the perspective that
there is a need for standardized KDEs to be recorded and shared. This document hopes to contribute
to this last point.
46
6. RECOMMENDATIONS
As demonstrated in this document, establishing a consistent and widely adopted set of KDEs and
CTEs is an essential part of functional and integrated traceability systems – both for companies and
national CAs.
While technology has enabled many examples of successful implementation and is constantly
evolving, implementing advanced technology is secondary to having well-developed traceability along
the value chain, not only with accurate and well-defined KDEs and CTEs, but with standards that
facilitate integration, management and transmission of data. Hence, prior to deciding which technology
is to be used, it is critical to define what data are to be acquired, and to determine the sources and
jurisdictions involved at each type of state or entity of the traceability system to be built.
All types of states, entities and operators have essential roles to play in the implementation of
traceability mechanisms. Some responsibilities and duties are directly related to the implementation of
rigorous traceability mechanisms, whereas others are only loosely related – but together they provide
the conditions in which traceability functions can be enforced.
The overall recommendation of this document for countries is to: 1) identify and define standardized
KDEs and CTEs for commercial and regulatory traceability; and 2) follow strict due diligence (using a
holistic and integrated approach) involving all stakeholders at legal, commercial and operational level
prior to commitment.
In order to achieve the two recommendations above, critical forethought needs to be given to the
following (not exhaustive) list of considerations:
Use of defined and flexible standards

Once the identification and definition of the CTEs and KDEs is completed, stakeholders across
the supply chain should consider adopting industry-wide use of the standards using globally
unique identification of units as a significant step forward for electronic and interoperable
seafood traceability.
An example of such standard is the GDST Standards and Guidelines for Interoperable Seafood
Traceability Systems, Version 1.0. These industry-developed standards are designed to improve
the reliability of seafood information, reduce the cost of traceability and contribute to supply
chain risk reduction and to securing the long-term social and environmental sustainability of
the sector.
Traceability and value chain considerations for due diligence

An exhaustive understanding of all possible is needed - as distinct from desirable - supply-chain
events and scenarios under consideration.
Consideration should be given to small-scale producers supplying domestic markets and
potential gaps in national traceability systems where information is challenging to capture.
47
Clear identification and definition of the CTEs and KDEs are needed in the value chain under
consideration.
For regulatory purposes, the segments of analysis need to consider the administrative, logistic
and legal aspects associated with the types of states, entities and operators that have custody of
fishery and aquaculture products as they move through national and international supply chains,
from harvesting and processing to the consumer end market.
A clear understanding of the current operational and logistical advantages and limitations of the
traceability system in existence (if any) is needed.
48
7. REFERENCES
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2016. Project to develop an interoperable seafood traceability technology architecture: Issues brief.
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Blaha. Independent fisheries Advisor. Cited 22 September 2022. http://www.franciscoblaha.info/
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Blaha, F. & Katafono, K. 2020. Blockchain application in seafood value chains. FAO Fisheries and
Aquaculture Circular No. 1207. Rome, FAO. https://doi.org/10.4060/ca8751en
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of 10 country cases. Rome, FAO.
Borit, M. & Olsen, P. 2012. Evaluation framework for regulatory requirements related to data recording
and traceability designed to prevent illegal, unreported and unregulated fishing. Marine Policy,
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norms. FAO Fisheries and Aquaculture Circular No. 1123. Rome, FAO. www.fao.org/3/a-i5944e.pdf
Borit, M. & Olsen, P. 2020. Beyond regulatory compliance – Seafood traceability benefits and success cases.
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BSI (British Standards Institution). 2017. PAS 1550: 2017. Exercising due diligence in establishing the
legal origin of seafood products and marine ingredients – Importing and processing – Code of
practice. London. https://pages.bsigroup.com/l/35972/2021-03-08/2t7y9nf/35972/1615212433S
Wdm63mn/PAS_1550.pdf
Corsin, F., Funge-Smith, S. & Clausen, J, 2007. A qualitative assessment of standards and certification
schemes applicable to aquaculture in the Asia-Pacific region. FAO RAP Publication 2007/25.
Bangkok, FAO. www.fao.org/3/a-ai388e.pdf
De Silva, D. 2011. Value chain of fish and fishery products: origin, functions and application in developed
and developing country markets. Rome, FAO. www.fao.org/fileadmin/user_upload/fisheries/
docs/De_Silva_report_with_summary_.doc
EC (European Commission). 2023. Establishment Lists. In: IMSOC–TRACESNT. Brussels. Cited 3 April
2023. https://webgate.ec.europa.eu/tracesnt/directory/publication/establishment/index#!/
search?classificationSectionId=FISHERY_PRODUCTS&sort=country.translation
EJF (Environmental Justice Foundation), OCEANA, The Nature Conservancy, The Pew Charitable
Trusts and WWF. 2020. A comparative study of key data elements in import control schemes aimed
at tackling illegal, unreported and unregulated fishing in the top three seafood markets: the European
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CDS-Study-WEB.pdf
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FAO. 1995. Code of Conduct for Responsible Fisheries. Rome. https://www.fao.org/3/v9878e/V9878E.pdf

FAO. 2013. Best practice guidelines on traceability. Sub-Committee on Fish Trade. Fourteenth session.
Bergen, Norway, 24_28 February 2014. Rome. www.fao.org/cofi/29510-0d3ea0e690044579673deb
e9c27579459.pdf
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Rome, FAO. www.fao.org/3/I9540EN/i9540en.pdf
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proceure: 8 April to 8 May 2022. Plenary sessions: 7, 8, 9 and 20 June 2022. In: FAO. Rome. Cited
22 September 2022. www.fao.org/about/meetings/cofi-sub-committee-on-fish-trade/session18-
documents/en
FAO. 2022b. Report of the regional consultations on advancing end-to-end traceability in fish value
chains – Virtual meetings, September 2021 to January 2022. FAO Fisheries and Aquaculture Report
No. 1378. Rome. https://doi.org/10.4060/cc0307en
FAO and IFIF (International Feed Industry Federation). 2010. Good practices for the feed industry
– Implementing the Codex Alimentarius Code of Practice on Good Animal Feeding. FAO Animal
Production and Health Manual No. 9. Rome. www.fao.org/3/i1379e/i1379e00.htm
FishWise. 2017. Key data elements for seafood: A compilation of resources. Santa Cruz, United States,
FishWise. https://fishwise.org/wp-content/uploads/2018/03/2017.05.25_KDEs-for-Seafood-
Compilation-of-Resources_Final_-1-1.pdf
FishWise. 2018. Advancing traceability in the seafood industry: Assessing challenges and opportunities.
Santa Cruz, United States, FishWise. www.fishwise.org/wp-content/uploads/2018/04/2018.02.22_
Trace-WP_February-2018-Update-1.pdf
GDST (Global Dialogue on Seafood Traceability). 2022. GDST standards and materials. In: GDST. Cited
18 September 2022. https://traceability-dialogue.org/core-documents/gdst-1-0-materials
GS1. 2019. Foundation for fish, seafood and aquaculture traceability guideline. Implementing traceability
in fish, seafood and aquaculture supply chains using the GS1 standards for identification, data
capturing and data sharing. GSI. https://www.gs1.org/sites/default/files/docs/traceability/GS1_
Foundation_for_Fish_Seafood_Aquaculture_Traceability_Guideline.pdf
GS1. 2023. GS1. Brussels. Cited 3 April 2023. www.gs1.org/home
GSSI (Global Sustainable Seafood Initiative). 2023. GSSI. Haarlem. Cited 3 April 2023. www.ourgssi.
org/contact-us/
Hosch, G. & Blaha, F. 2017. Seafood traceability for fisheries compliance: country-level support for catch
documentation schemes. FAO Fisheries and Aquaculture Technical Paper No. 619. Rome, FAO. 110 pp.
www.fao.org/3/a-i8183e.pdf
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debut. In: IFT. Chicago, United States. Cited 22 September 2022. https://www.ift.org/news-and-
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their-debut
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iso.org/obp/ui/#iso:std:iso:9000:ed-4:v1:en
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recorded in captured finfish distribution. In: ISO. Geneva. Cited 22 September 2022. https://www.
iso.org/standard/52084.html
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SALT (Seafood Alliance for Legality & Traceability). 2021. Comprehensive electronic catch
documentation and traceability (eCDT) principles. https://media.salttraceability.org/wp-content/
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51
GUIDANCE DOCUMENT:
CRITICAL TRACKING EVENTS AND KEY DATA ELEMENTS
ALONG CAPTURE FISHERIES AND AQUACULTURE VALUE CHAINS
Traceability systems, including their associated elements of transparency,

represent a crucial concerted effort towards transparent and responsible
value chains. They allow a product to be followed from its origin to the end
market, informing about compliance with many fisheries regulations. Given
the interconnectivity of fisheries and aquaculture value chains, collaboration
at all stages is crucial for robust end-to-end traceability. Most current systems
are fragmented and internal to individual companies; this creates information
gaps throughout the supply chain and loss of operational efficiency. This
guidance document provides elements to address these challenges and enable
supply chain actors to have a common understanding and language in order to
increase interoperability and data sharing for efficient traceability systems at
the governmental and private levels.
Fisheries and Aquaculture Division –

Natural Resources and Sustainable Production
[email protected]
fao.org/fisheries
Food and Agriculture Organization of the United Nations

Rome, Italy
ISBN 978-92-5-137835-9
9 789251 378359
CC5484EN/1/04.23

FAO Guidance Advanced End To End Traceability

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GUIDANCE DOCUMENT:

ADVANCING END-TO-END TRACEABILITY

FOOD AND AGRICULTURE ORGANIZATION OF THE UNITED NATIONS

Cover illustration: © FAO/Zoe Brandizzi

Preparation of this document iii

2. TRACEABILITY IN CAPTURE FISHERIES AND AQUACULTURE VALUE CHAINS 3

3. CRITICAL TRACKING EVENTS AND KEY DATA ELEMENTS 13

4. CRITICAL TRACKING EVENTS AND KEY DATA ELEMENTS IN AQUACULTURE 32

AIS automatic identification system

1.1 SCOPE AND DEVELOPMENT PROCESS

2.1 THE APPLICATION OF TRACEABILITY

2.2 THE REGULATORY REALM (OFFICIAL GUARANTEES)

 Within an organization: internal traceability, specific to a company or enterprise, is used to meet

2.2.1 CAPTURE FISHERIES

2.3 THE NON-REGULATORY REALM

2.4 TRACEABILITY STANDARDS AND TECHNOLOGY

3.2 FUNDAMENTALS FOR OPERATORS

CTEs Main KDEs Data source Comments

Linking KDE Weight ticket, production Individual facility/supply chain

Product source – seller and Invoices, weight ticket,

Product destination – buyer and Invoices, weight ticket,

Species name Aquatic Sciences and Fisheries

Volume/weight/quantity Weight ticket, invoices, Codes for units of measure used

Expiry/production date Calendar date associated with a

Production method Categorization on the spectrum

Product origin Country where seafood

Source: Authors’ own elaboration.

3.3 FUNDAMENTALS OF FLAG STATE RESPONSIBILITY

Supply chain CTEs Main KDEs Data source Comments

Supply chain stop CTEs Main KDEs Data source Comments

Fishing gear(s) type Fishing gear/s used aligned Normally described in the

Supply chain stop CTEs Main KDEs Data source Comments

Start and end dates of Reporting/logbook Can be validated by VMS/AIS to

End of fishing Unloading/port entry Reporting/logbook Flag state best practice is

Species name Vessel’s logbook/harvest

Estimated volume/weight / Vessel’s logbook/harvest Numerically quantifiable amount

Product form Vessel’s logbook/harvest Commercial short-hand

Supply chain stop CTEs Main KDEs Data source Comments

Transshipment location Rendezvous area GPS Can be validated by VMS to some

Dates of transshipment Fishing vessel captain/ Can be validated by VMS to some

Transshipment location Port name and country/ Port name or rendezvous

Fishing vessel captain/

Landing Location Unloading vessel (fishing Port name and country/

Dates of landing (start and Reporting/logbook

First buyer Flag state best practices This is similar to identifying

Source: Authors’ own elaboration.

3.4 COASTAL STATES

Supply chain stop CTEs Main KDEs Data source Comments

Supply chain stop CTEs Main KDEs Data source Comments

Start and end dates of Reporting/logbook Can be validated by VMS/AIS to

End of fishing Species name ASFIS list of species

Product form Vessel’s logbook/harvest Commercial short-hand

Supply chain stop CTEs Main KDEs Data source Comments

Source: Authors’ own elaboration.

3.5 PORT STATES

 deny port access to vessels registered in other states;

Supply chain stop CTEs Main KDEs Data source Comments

Harvesting End of fishing End of fishing/port entry Port entry notice

Within an organization: internal traceability, specific to a company or enterprise, is used to meet

deny port access to vessels registered in other states;

origin of the seeds, fish seedlings or fish fry;