Marine Stewardship Council
MSC Variation Request Form - Agents
Version 1.1, 4 October 2016
Copyright notice
The Marine Stewardship Council “Variation Request Form - Agents” and its content is copyright of
“Marine Stewardship Council” - © “Marine Stewardship Council” 2016. All rights reserved.
Senior Policy Manager
Marine Stewardship Council
Marine House
1 Snow Hill
London EC1A 2DH
United Kingdom
Phone: + 44 (0) 20 7246 8900
Fax: + 44 (0) 20 7246 8901
Email: [email protected]
Document: MSC Variation Request Form - Agents v1.1
Date of issue: 4 October 2016
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© Marine Stewardship Council, 2016
Version Control
Amendments Issued
Version No.
Date
Description Of Amendment
1.0
1 September 2015
Date of application.
1.1
4 October 2016
Updated in line with MSC intent,
guidance and contact information.
This document is to be cited as:
MSC Variation Request Form - Agents v1.1
Document: MSC Variation Request Form - Agents v1.1
Date of issue: 4 October 2016
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© Marine Stewardship Council, 2016
Using the Variation Request Form for Agents
Agents are required to gain certification if they take legal ownership of products unless they purchase
product in consumer-ready-tamper-proof packaging (CRTTP) or are covered by a fishery certificate. However
in recognition of the range of different agent relationships, and relative range of risks, the MSC will consider
a review of how agents are covered by certification prior to the next Certification Requirements release.
This form details the information required from conformity assessment bodies (CABs) to enable the MSC to
consider variations to allow agents working on behalf of Chain of Custody (CoC) certificate holders (or
applicants) to be treated as subcontractors (see “Do agents need CoC?” MSC Interpretations).
Please complete all unshaded fields. Where instructions are included in italics, please delete and replace
with your specific information.
Once this variation form is completed, please delete pages i - iv of this document, save it as a PDF file and
send to [email protected].
On receipt, the MSC will consider your request and will usually respond within 14 days.
Document: MSC Variation Request Form - Agents v1.1
Date of issue: 4 October 2016
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© Marine Stewardship Council, 2016
Marine Stewardship Council - Variation Request and Response Form
v1.1
Agents working for the CoC holder purchasing from the fishery
Date submitted to MSC
Conformity Assessment Body
Agent name/s and contacts (or where
listed)
CoC certificate holder (agent acts on behalf
of)
Fishery/ supplier agent buys from (if
relevant)
Customer/s agent sells to (if relevant)
Lead Auditor/Programme Manager
Scheme requirement(s) to vary from
6.1.1.1
1. Proposed variation
To consider the agents above as subcontractors to the CoC holder above, rather than requiring them
to obtain separate CoC certification.
2. Rationale/Justification
It can be demonstrated that the agent
works on behalf of the CoC holder (for
example working exclusively for them, a
service agreement in place, order made
directly between CoC holder and
supplier/buyer)
The CoC holder has access to invoices
received by and sent from agents.
A traceability test has been carried through
the agent (sample of agents if all operating
in the same way e.g. at fishery) to the
ultimate buyer or supplier
If using the agent to sell products the
customer has access to traceability records
back to certified supplier
CoC holder’s controls ensure that the agent
meets all MSC requirements. Specifically:
 Purchase certified product only
from certified suppliers
 Correctly identify certified product
on sales documents (e.g. on invoice
line item)
Document: MSC Variation Request Form - Agents v1.1
Date of issue: 4 October 2016
Please detail how…..
Yes/ no
Yes/ no
Yes/ no (or n/a if procurement agent)
Please explain for each bullet…..
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© Marine Stewardship Council, 2016
Other relevant information on product
integrity risks relating to agent activity, and
systems/ controls in place to address these.
3. MSC decision to approval variation (name, role, date)
Yes/ No
Name/ role / date
4. Conditions of approval
The certifier includes these agents within the CoC holders certificate as subcontractors and lists them
on the MSC database (update list at each audit). If the agent is used to sell products, their name
must also be listed on the ‘marketing information’ section of the MSC database so that customers
can verify this within find a supplier.
The certifier shall apply all the requirements of the CR which relate to auditing subcontractor
activities (section 8).
The certifier will consider the CoC Standard 5.3.1 and 5.3.2 applicable, where ‘handling’ can be
replaced with the term ‘handling financial transactions relating to’
Document: MSC Variation Request Form - Agents v1.1
Date of issue: 4 October 2016
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© Marine Stewardship Council, 2016