Introduction

The 60-day public consultation for Version 3 of the MarinTrust Factory Standard has been closed since 3rd July 2023.

All feedback received went through review with the relevant MarinTrust governance body. A summary of all consultation feedback, not attributable to individuals or organisations, is now available. A summary of the decision taken related to each comment received in consultation is reported in the annexe. 

Version 3 public consultation summary

Public consultation ran from 4th May to 3rd July 2023. This consultation came towards the end of a rigorous development process, including pilot assessments across the world and feedback from auditors, certified companies, and other key marine ingredient stakeholders to enhance the consistency and efficiency of audits.

The whole process has been closely overseen by MarinTrust’s multi-stakeholder Governing Body Committee, and this consultation will provide an important final step to engage the wider community, ensuring that Version 3 will meet expectations of all those that will use it.

We would like to thank everyone for their participation in the public consultation survey. 

Below is a summary of the Standard, including the differences from the previous version.


Contents


Objectives of Version 3

  • To continue to meet the objectives set in the development of Version 2.0 of the MarinTrust standard
  • To enhance and strengthen the MarinTrust Fisheries Approval Criteria for raw materials (whole fish and by-products) used for the production of compliant marine ingredients to promote more robust responsible fishery management.
  • To enhance the traceability criteria to provide assurance to the traceability and integrity of the compliant marine ingredient.
  • To enhance the MarinTrust Good Manufacturing Practices Criteria by taking into consideration good manufacturing practices for production that is intended for human consumption to ensure that marine ingredients are produced utilising relevant and robust practices for food safety.
  • To promote more efficient marine ingredients production practices to reduce the environmental impact of the marine ingredients manufacturing process.
  • To promote and create improved social and welfare benefits for all workers employed within the marine ingredients manufacturing sector.
  • To evaluate extending the scope to include human rights criteria for vessels supplying whole fish to the marine ingredients manufacturing sector.
  • To ensure that MarinTrust Version 3 remains relevant, robust and fit for purpose.

Timeline

timeline

Key differences in Version 3 (compared with Version 2)

Differences

Version 3 summary of main sections

Explore the main sections of the draft Version 3 Standard. Simply click on the icons to open and click again to close.

sourcing

Includes the requirements for raw materials including whole fish and by-products. As a pre-requisite these raw materials must be assessed, and assurance in place regarding the legality of sourcing.

Improvements:

- Streamlined and simplified the pre-requisite section

Covers the wide scope of the facility quality management system, including policies, procedures and other requirements.

Improvements:

- Consolidated policies into one clause​

- Introduced the need to provide metrics each year

- Greater emphasis on due diligence​

- Strengthened checks of suppliers and subcontractors as a foundation of due diligence; traceability, legal, social etc. ​

- Duplications removed

- Improved clarity around the use of logo and Improver Programme claims

Details the specific information and requirements to ensure the raw materials which are sourced, can be verified as to their origin, including fishery, supplier, farm. Includes the key information required for each type of raw material.

Improvements:

- Strengthened the  traceability requirements relevant to the  raw materials Introduced applicable Key Data Elements (KDEs) from GDST​ Clarified types of by-products and sources​ 

Details the specifics for traceability of MarinTrust compliant raw materials, including requirements for segregation from non-approved sources. How MarinTrust compliant raw materials should be able to be traced through the production process, from source to sale to customer. Requirement for mass balance to verify input and outputs.

Improvements

- Aligned to Chain of Custody V2 to facilitate linkage between standards

- Introduced Key Data Elements (KDEs) from GDST

- Linked to raw material requirements in Section 3 to specify traceability requirements for each batch/delivery of raw materials

- Traceability requirements have been strengthened at all stages of production 

 
manufacturing

Focuses on the key requirements for a facility to ensure good manufacturing practices are in place, across all the key areas of the facility.

Covers numerous specific requirements including hazard analysis, risk management, and operational details. 

Improvements:

- Section has been streamlined and is clearer and more logical​

- Duplications have been removed and all GMP requirements are now in this section​

- Strengthened requirements as required to align with good practice​ Aligned to latest versions of Codex Alimentarius

- General principles of Food Hygiene (2020), ISO 22000 (2018), GMP+ (2022), FEMAS (2019).​

- In line with HACCP requirements and terminology​

- New requirements for TACCP / VACCP (only for plants producing human consumption) improves product integrity​

Ensures that staff have the required skills to understand and deliver across all areas of the MarinTrust standard.

Improvements:

- Staff training is clearer and ensures building knowledge of MT ​ 

- Requirement for procedures provides flexibility for plants

Ensures effective staff safety, welfare and working conditions.

Improvements:

- Social accountability has been brought up to date and in line with the International Labour Organization (ILO) / latest practice​ 

- Clearer requirements to demonstrate social performance and balanced against what is possible​

Ensures effective environmental management and that the facility is in line with permits and managing environmental performance.

Improvements:

Environmental accountability has been streamlined but remains largely the same 

Additional information on raw material sourcing

By-productsTo demonstrate responsible sourcing, a MarinTrust certified facility can only use raw material (whole fish and by-product) that is MarinTrust approved, which means it has passed an assessment undertaken by a third-party Certification Body. For MarinTrust approved whole fish and by-products, MarinTrust sets the criteria to assess these raw materials.

Alongside the development of V3, MarinTrust began further development of the by-product and whole fish fishery assessment criteria. Following a comprehensive development process, including pilot assessments and feedback from certificate holders and fisheries experts. The process has been overseen by MarinTrust’s multi-stakeholder MarinTrust Fisheries Development Oversight Committee and Governing Body Committee.

By-product assessment:

The focus of the assessment has changed. V3 now focuses on the legality of the by-product sourced within the supply chain, this is done by using an IUU risk-based assessment of the source country (flag state). Retained checks to ensure the species is not endangered (CITES appendices & IUCN Red List for threatened species).

The species categorisation and assessment criteria for whole fish (Categories A, B, C and D) remain unchanged.

For whole fish fishery assessment:

The key requirements remain the same as the current version. The Management and Ecosystem Impacts criteria have been improved by restructuring the clauses and introducing sub-clauses. Sub-clauses come from information already used to assess the fishery and formalise the information previously situated in the assessment guidance.