Fish Importers- The introduction of the Catch Certificate Regime

21 December 2009

What could this mean for your business?

‘The Fight against Illegal and Unreported Fishing’ (IUU) has been of major importance in International Trade because of increasing IUU Trade. The European Union subsequently introduced EC Regulation No. 105/2008 as its response to IUU Trade.


The aim is to improve the traceability of all fishery products traded with the EC and to facilitate the control of their compliance with conservation and management rules in co-operation with third countries.

What does the scheme envisage?

Fishery products shall only be imported into the EC when accompanied by a catch certificate. The importers of fishery products will be required to submit a catch certificate to the authorities of the importing Member State, which has been validated by the competent authority of the flag State of the catching vessel. The general deadline for submission of these documents to the authorities of the importing Member State is fixed at three working days prior to the anticipated arrival of the consignment in that Member State. However, the deadline is different when the forms of transport are different (Airfreight and Rail: Four hours, Road: Two hours).

Approved Economic Operators and communication of validated catch certificates

By derogation to the general rule, Community importers benefitting from AEO status will not be obliged to submit the validated certificates to the competent authorities of the importing Member State prior to the anticipated arrival of the consignment concerned. However, they will have to inform these authorities of the arrival of the products in the same manner as other operators and to hold at their disposal the catch certificates and other relevant documents for the purpose of checks or verifications.

The Importer will be obliged however to keep the catch certificates and file them properly to ensure audit-traceability.

What action do importers need to take in light of the IUU Regulation?

The importer needs to ensure that the exporter is aware of the catch certification requirement and that the exporter has taken steps to make them available for each consignment of fish caught from 1 January 2010 onwards. In addition, it is advisable that importers carry out a risk-assessment of the supply chain to identify points at which IUU fish could enter the chain and map how notification will work in practice

Next Steps

For more details about the Catch Certification Scheme and about the requirements for Authorised Economic Operator Status call us on (01905) 619229 or alternatively email us at:

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