Central to the effectiveness of the EU IUU regulation is the Catch Certificate (CC), a document not easy to handle, so here I will try to “reverse engineer” the ways each section is being handled by the different countries and the CA in the MS that receive them, to clarify its use
The Regulation (EU) 2023/2842 that underpins the use of CATCH, proposed changes in the content of the CC, and processing statement to
To address loopholes in key data elements relevant for traceability in the old CC
Incorporate key data related to fishing and to tracing trade flows
To ensure consistency of data collected
To ensure the same traceability data requirements for the same commodities in all cases.
While the changes are effective from 10 January 2026, “old” catch certificates and documents (those created and validated before 10 January 2026) will be admissible for an additional 24 months from the date of application (if submitted through CATCH).
The changes in each section of the Catch Certificate
There is no "standard understanding" of the interpretation of the CCS contents, and DG MARE does not interfere with the interpretation by EU MS.
This blog is based on my experience with the “old” certificate and the information currently available on the “new” certificate.
This part of the guide aims to facilitate the understanding of the different sections of the CC by analysing them individually,
The “new” information requirements and changes are in light blue type, and new areas in the certificate have a light blue background, while the “old” ones without change maintain the white background.
Section 1
This requires the details of the authority entrusted for this job (usually the fisheries authority) of the flag state. The authority must be “notified” by DG MARE, and it is assumed that under the new system, those authorities in exporting countries may access these “notification requirements” by becoming registered users of CATCH.
However, there is a “catch 22” type situation (pun intended) between the requirements from the EU Catch Certification (CCS) and the Health Certification since some Flag States, while having a fisheries body, lack the EU DG SANTE's authorisation from a sanitary perspective to export. Without this, raw products sourced from such vessels will remain ineligible and, as such, are not part of DG SANTE’s TRACES system (in which CATCH is based).
So, only the countries approved from a sanitary perspective will be “notified”, even if they comply with all the “fisheries elements” of the CCS. This issue will become evident in the analysis of Section 7
The “new” Section 1 differs from the old in naming itself the European Union Catch Certificate to avoid confusion.
Regarding the details above, it is assumed that the CA of the vessel flag State is in charge of managing a unique consecutive numbering system for each cert. The country decides the complexity and structure of this system.
While not listed, it is sensible for the CA of the vessel Flag State to have a dedicated e-mail contact.
Section 2
The new elements in this section aim to increase the details of the vessel's identification and add the gear used for harvesting the fish in the consignment.
The fishing gear code should be under FAO’s international Standard statistical classification of Fishing Gear (ISSCFG)[1]
However, the changes do not address the old system's issues.
Many vessels and landings in one consignment
The CC is based on the volumes in the consignment exported, and the consignment could consist of various landings of various vessels; hence, there could be 20+ vessels in one consignment in the paper system; there was no chance to put more than 2-3 vessels in this section.
FFA members “invented” Annex B to add more vessels; hence, we assume that the new system may allow the addition of as many vessels as necessary for the consignment.
No role for coastal States
The fishing licence # and validity in the certificate seem to refer to the flag state license and not to the coastal state where the vessels may be operating. Yet the legality of the catch is associated with the conditions imposed by the coastal state and not only by the flag state. Furthermore, the validity may differ (yearly for the flag state and monthly for the coastal state), so it gets complicated, and the CCS remains silent on this. Based on this, the numbering of the licence and validity of the vessel by the flag state may not have any inference with the legality of the catch.
Charter vessels
As discussed, the issuing and validating of the catch certificate is done by the flag state fisheries authority. Yet, a significant part of the fishing world works on principles of “charter”; hence, vessels flagged in country “A” are based and operate in country “B” under its legislation and controls. Chances are that flag state “A” may not have seen that vessel in years and may not even know where it is, but under flag state responsibility is the flag state (A) that had to validate the catch certificates of the vessels that operate in country B.
So, in an ideal world, country “A” would establish an MoU with the Coastal States where the vessels operate and/or with the Port State where the fish is landed/transhipment and/or with the processing state where the fish is processed (note that all this can happen in one country or different ones). Once these MoUs are in place, a robust information-sharing system can be established, enabling the flag state to provide the required “official assurances” during validations.
In the real world, most of the countries utilising charter vessels are not particularly responsible in terms of fishing compliance. Hence, they don’t give much attention to these issues (in fact, very few such MoUs are in place).
While initially, this was designed as a “Catch certificate” (hence certified the fish caught at the time of landing), it has always been used as an “export certificate” only for the fish being exported to the EU, in many cases not from processors based in the flag state of the harvesting vessel.
So this becomes a problem for the processors and exporters in the countries that process the fish being exported to the EU, as they depend on the willingness and efficiency of the flag state authority, even more so if the flag state CA does not use CATCH.
Sections 3 and 4
The changes in these sections aim to increase the available catch area and date information and clarify the issues of the weights to be presented in the CC, which was a matter of much confusion in the old one.
The catch area FAO area(s) refers to FAO’s statistical catch areas[2]; furthermore, the information should include the identification of the exclusive economic zone(s) and/or high seas and where the catches took place.
The changes do not address fully some of the old system's issues and remain somewhat mixed and complicated.
Section 4 relates more to Section 2 in the function of the conditions under which the vessel operates and catches fish; hence, it is analysed first.
It refers to the applicable Conservation and Management Measures (CMMs) applicable to the vessels and area of catches; this has been a confusing aspect, as an example; a vessel from a WCPFC member fishing in the area may be under the obligations of over dozens of CMMs[3] that are incorporated into the fag state legislation (high seas permits, conditions related to leaving the flag state EEZ, observers, FADs, and all other CMMs applicable to the WCPFC in which that vessel operates) and/or the measures imposed by the coastal state (permit # and conditions, etc) which as discussed above seems absent.
In any case, it only relates to the relevant RFMO convention area(s), so one assumes that naming the WCPFC is sufficient.
Section 3.
Product Description: The product is described by using the species name, and the product code is the customs code used in the nomenclature implemented by the third country (however in reality, it is the one that the client requested) in the sections below. However, some countries ask for the product's generic name to be listed (i.e. Tuna loins).
Catch dates and areas: Dates of catch can be interpreted as the actual dates of fishing. However, a vessel may not catch every day, so certainty is required regarding whether this constitutes each active fishing date, the time between the 1st fishing operation (i.e. trawl, set, hook in the water, etc.) and the last one. This could also be from port departure to return or from empty hold to full hold, depending on how the vessel operates.
This is not defined; hence it is potentially in the hands of the operators that complete this section to choose what they want, or it may also be subject to a directive from the fisheries authority defining what is required.
Weights: The clarifications for this section, as explained in DG MARE’s FAQ of May 2024[4], are very welcomed since the ones in the older system were complex and somewhat confusing. Question 48 of that document states
“Estimated weight to be landed in kg” - this box will be used in direct landings of fishery products in the EU. It will contain data based on the fishing logbook.
“Net catch weight in kg” - this box will be used in case of landings in third countries. It will contain data after completion of landing relevant for the products intended to be exported to the EU.
“Verified weight landed (net catch weight in kg)” - this box will be used in case of landings having taken place under the supervision of an authority.
What often used to happen is that when fish from a vessel flagged in country “A” was unloaded in country “B” for processing, the whole volume of fish landed can be quoted in the “estimated” box. So now it is advised that this volume only applies to fish landed in the EU.
The one that seems applicable to landing in 3rd countries is the “Net Weight”, the note does not go into details. Still, it would be great to assume this for the full landing. Then, the processing statement provides the details of the processed volume out of the landed, and the CATCH system keeps track of this for each landing of each vessel in the CC and incorporates some standard conversion factors/yields to keep subtracting the volumes processed of the volume landed until the full net volume is exhausted.
No details are provided regarding the verified weight landed, yet one is to assume that this could apply to the port State authority if fish is landed in a country other than the flag state.
While the present understanding is a step forward from the old one, DG MARE will need to clarify some aspects further.
Section 5
The changes here add the option of a licensee holder since masters were usually unavailable to sign.
While is ideal to make the master responsible for the fish caught, the certificate is often raised when the product is ready to be exported, which usually means processed (not for the product caught).
This may happen in a different country and months after the vessel lands, and therefore, the master will not be able to sign the document.
In theory, the fisheries authorities should validate this. Yet, most operators have scans of the skipper’s signatures available or add the concept of “authorised company representative” or something similar to the paper certificates.
Section 6
Transhipments at sea are heavily regulated worldwide and good reasons exist for this.
Transhipments are permitted in various fisheries and under the fishing rules of the flag state and/or RFMO, and/or coastal state.
Nevertheless, it is the Flag state’s responsibility to attest to the legality of transhipment at sea. Hence, the flag states should have processes and instruments to ensure the operations are legal and no underreporting occurs.
Some difficulties apply here in addition to the other elements of the CC. The paperwork may be completed soon after the event and handled by the processors rather than the fishers. So, in this case, how does the flag state know and validate the identity (and signature) of both masters?
While there is no definition of “transhipment at sea” it is almost obvious that it happens outside any port region, and many states have not defined the “format” in which the transhipment information is to be supplied.
Examples have been cited where the CC declares two dates and positions (start and finish of the transhipment). This may suggest that there were two transhipments instead of one.
Indeed, there could also be two consecutive transhipments by the same vessels separated by a few days.
Thus, it is important that the validation authority clearly states how they require the information to be presented.
Section 7
The changes here address a substantial failure of the old system, the lack of a section for landings and an absence of Ports State Measures in the CCS.
Furthermore, the EU is a party to PSMA and actively participates in the FAO Technical Consultation, which elaborated the 2022 Guidelines for Transshipment and agreed to the definition of transhipment and landing.
The new form correctly identifies the ports the dates of transhipment or landing and the details of the vessels receiving transport in case of transhipments.
In any case, the changes do not address some of the old system's issues and remain complex and somewhat confusing.
While not clearly explained in the regulations or manuals, this is the only part of the CC that requires the signature from the Port State instead of the Flag State.
When vessels flagged in Country “A” tranship or land at a port in Country “B”. Country “A” is responsible for the validation of the CC, but Country “B “is responsible for authorizing the transhipment or landing under PSM.
The transhipment or landing can occur before the CC certificates are raised and validated (in many cases, there is still no firm buyer for the fish) or because the fish has not been landed or processed at its destination, which may or may not be the Flag State.
This a difficulty for the Port State as under the paper system, if they were to sign Section 7 at the time of the transhipment or landing, they'll sign an empty CC, unless the flag state is really “onto it” an able to provide a validated CC based on reliable estimates prior the transhipment (there is no evidence of this ever being the case).
Alternatively, they need to keep the records of the transhipment authorization on file until the processors of the fish that was transhipped/landed request the CC from the Flag State, who can then issue and validate the CC, which can then go to the Port State for section 7 signature.
As it is now, the operational side of section 7 requires either jeopardy from the Flag State or from the Port State.
It's only hope that under CATCH, the communication between the flag state and port state may be working over the same CC initiated by the flag State.
As discussed before, CATCH can incorporate countries that are not authorised from the sanitary perspective, something it cannot presently do on TRACES.
Section 8
There are no changes to this section, that is normally completed by the processor that fills Section 5, as the CC is prepared by the processors (which, as already discussed defeats the purpose of a catch certification), so in general terms there are no issues with this section.
Section 9
This section, which refers to the authority in charge of Section 1, has not been changed. However, a name and position are required.
Initially, it was believed that the details should be communicated to DG MARE. Yet the CC is evaluated by the CA of the EU MS, and there is no centralized system to verify (or not) the details of the CC. It is, therefore, up to the EU member state to decide whether to inform DG MARE.
Section 10
There are no changes to this section which is a rather illogic part of the certificate which could just be the appendix (transport details) or simply not referred to.
The “new” transport details appendix does, however, incorporate changes that refer to the documentation details, such as the CMR (Contract for the International Carriage of Goods by Road), the inclusion of a port of destination, and the instruction that in the case of use of multiple modes of transport or multiple shipments, the information related to the transport has to be provided for each mode of transport used for each.
The appendix collects the information related to the transport details of the fishery products from the third country, having validated the catch certificate to the next destination, an EU Member State in case of direct importation or an intermediate country in case of indirect importation to the EU.
Yet, as has been seen under part 7, if a transhipment in port happens in between vessels where the Port State is the Flag State, then this can also be construed as having the carrier as the de facto transport vessel. In this case, the carrier's details will be entered in this section.
There are also instances where the transhipment details being recorded in section 7 are the same details of the carrier being repeated in this section of transport details.
Acceptance of this practice may be one of those issues that is dependent of the practices of the authorities of importing EU MS at the time the consignment enters the country.
Processing Statement
The processing statement, as required by Annex IV of the IUU Regulation, has gone through a full change of understanding.
While it used to be only required for fish processed under a foreign catch certificate in a 3rd country, it will now be required even in cases where the processing of the product takes place in the same country where the flag of the fishing vessel.
From now on, processing statements will be required for ALL processed fishery products imported in the EU, regardless of where the processing has taken place (in the flag State or in another non-EU country).
This means that processing statements should also be endorsed in cases where the flag State of the fishing vessels that caught the fish and the country where the processing operation occurred are the same.
In addition, the template laid down in Annex IV will include the obligation to apply a unique number provided by the authorities endorsing the statement (in case of direct use of CATCH, the system can generate such a unique number directly).
Importantly, the processing statement should refer to the related catch certificates, including the quantity of fish used as raw material to produce the processed products to be exported to the EU. As discussed before, hopefully, this is checked in terms of the standard yields for the type of processing.
There are no significant issues regarding this document. From the practical and management point of view, it is important for the CA of the processing state that validates this document to maintain a register of processing statements signed with a description of species, volumes and destiny.
A Non-Manipulation Statement?
The legislation did not stipulate a “non-manipulation statement”, but it stated that:
In order to import fishery products constituting one single consignment, transported in the same form to the EU from a 3rd country other than the flag State, the importer shall submit to the authorities of the Member States of importation:
the catch certificate(s) validated by the flag State; and
documented evidence that the fishery products did not undergo operations other than unloading, reloading or any operation designed to preserve them in good and genuine condition, and remained under the surveillance of the competent authorities in that third country.
Documented evidence shall be provided by means of:
where appropriate, the single transport document
A document issued by the competent authorities of that third country:
giving an exact description of the fishery products, the dates of unloading and reloading of the products and, where applicable, the names of the ships or the other means of transport used and
an indication of the conditions under which the fishery products remained in that third country.
Hence, some FFA members developed a ‘Non-Processing Statement” to cover all these issues and assist with their “fish accountancy”. An example follows:
Under the new system, there would be an official template for this document (not yet published)
Annex B or attachment to Catch Certificate
This form was not published in the original legislation; hence, it is not a compulsory form. In a note published by the EU on their website in July 2010, the EU welcomed the use of it for domestic products (i.e. products caught by the flag state vessels in this case). They do not standardise the contents. Hence, countries can adapt it to reflect their systems and the outcome based on traceability.
The EU noted: "Discussions are presently carried out with other third countries to provide similar information regarding domestic processing activities. The Commission welcomes the support received from third countries and their positive approach to implement the IUU Regulation". Hence, the third countries should use this to their advantage.
The certificate itself is still filled as usual, but then sections 2 and 3 will refer to the attachment or Annex B.
This form is handy when the consignment is made from various landings of various vessels (as is common in canneries), as the form can replace otherwise 30 “individual” certificates.
It is easier to set up the information in a readable way, including the volumes landed, the volumes processed, and the volumes exported. The Container number where that product is stored for dispatch, hence the whole traceability of the product is “visible” in one document; an example is presented below:
As discussed for Section 2 of the CC, it will depend on the facilities under the new CATCH system to add many vessels if applicable.
So yeah… one big thing is the processing statements change,… something that could have been done 14 years ago already. However, I see the capabilities of CATCH to do “fish accountancy” and check when a vessel landing is exhausted even with high yield margins during processing, and then see how much of the fish flows into the EU diminish… that is the ultimate test of the effectiveness wich so far hasn’t shown much in terms of impact in trade.
[1] https://www.fao.org/fishery/en/knowledgebase/139
[2] https://fish-commercial-names.ec.europa.eu/fish-names/fishing-areas_en
[4] https://oceans-and-fisheries.ec.europa.eu/document/download/4b92c8f5-9f96-46ec-babc-3bc880ff4ad3_en?filename=FAQ-amendment-IUU-Regulation_en.pdf&prefLang=fr