European Union Certification Requirements

Certification Requirements

The NOAA Seafood Inspection Program is the competent authority within the U.S. Government for issuance of certain certificates required for export of fish and fishery products to the European Union (EU).  The program offers three documents required for export to the EU.  They are:

• EU export health certificate;
• EU illegal, unreported, and unregulated (IUU) fishing catch document for fisheries products harvested in the US, to prevent, deter, and eliminate IUU fishing; and,
• EU Annex IV documents for EU import when wild-caught seafood is either processed outside the EU (requiring a Processing Statement, Annex IV 14.2) or stored, transshipped, split, or consolidated in a non-EU country without processing (requiring a Non-Manipulation Document, Annex IV 14.1), with valid underlying catch certificates to maintain traceability.

EU Export Health Certificates

The EU export health certificate is required by the EU Directorate-General for Health and Consumer Protection and attests to the safety of fish and fishery - both wild and aquaculture - products shipped to the EU.   

General requirements applicable to all requesters:

• All U.S. fishery products must be produced and stored in establishments approved by the EU.
• Facilities must appear on the EU Approved Establishments List. Link here.
• If the product is foreign-sourced, all foreign-sourced materials must originate from manufacturing facilities listed on the EU Approved Establishments List at the link above. 

Catch Certificate Guidance for U.S. Exporters

(Reported CATCH, Processing Statement [Annex IV 14.2 Processing Statement], Non-manipulation Statement [Annex IV 14.1 Non-Manipulation Document])

U.S. Requirements to Support EU CATCH System Submissions

This guidance explains what U.S. exporters must do in U.S. Government systems to complete the Reported CATCH and Annex IV documents required under the EU IUU Fishing Regulation when exporting wild-caught seafood products to the EU.

This guidance represents NOAA Seafood Inspection Program’s current understanding of the requirements based on available European Commission (EC) regulations and will be updated as needed.  

Definitions

Definitions

For the purposes of this guidance, the following definitions apply:

Annex IV Documents: Standardized documents established under the EU IUU Fishing Regulation to ensure traceability of fishery products. Annex IV includes the Processing Statement (Annex IV 14.2 Processing Statement) and the Non-Manipulation Document (Annex IV 14.1 Non-Manipulation Document).

Catch Certificate (EU Catch Certificate): The official EU import control document required under Council Regulation (EC) No 1005/2008 to certify that fishery products imported into the EU originate from legal and reported catches. The EU Catch Certificate is created and managed in TRACES NT using information from the underlying catch documentation.

CATCH Platform (EU CATCH): The electronic catch certification system within TRACES NT used by EU authorities, importers, and operators to submit, manage, and validate catch certificates and related Annex IV documents.

Illegal, Unreported, and Unregulated (IUU) Fishing Regulation: Council Regulation (EC) No 1005/2008 and its subsequent amendments, including Regulation (EU) 2023/2842, establishing an EU system to prevent, deter, and eliminate IUU fishing through catch certification and traceability requirements.

Non-Manipulation Document (Annex IV 14.1): A mandatory traceability document certifying that fishery products transiting through or stored in a non-EU country have not been processed, altered, or substituted and that traceability to the original Catch Certificate has been maintained.

Processing: Under EU regulations, any operation that alters the presentation of fishery products, including but not limited to cutting, filleting, freezing, packing, canning, smoking, salting, cooking, drying, pickling, or preparing fish for market. Processing does not include simple storage, holding, or transport.  Note that for the purposes of the CATCH reporting requirement, a processing statement is not required when the activity is limited to freezing and/or packing only.

Processing Statement (Annex IV 14.2): A mandatory document required for fishery products that have been processed outside the EU prior to import. The Processing Statement links processed products to one or more underlying Catch Certificates and documents all processing operations performed.

Reported CATCH (U.S. Catch Documentation): The U.S.-issued catch documentation created, reviewed, and approved through the Seafood Inspection Services Portal (SISP). Reported CATCH serves as the authoritative U.S. government record confirming that fishery products were legally harvested under U.S. law and is the primary source document supporting EU Catch Certificates and Annex IV documents.

Seafood Inspection Services Portal (SISP): The U.S. government electronic system operated by the NOAA Seafood Inspection Program through which exporters request, manage, and receive Reported CATCH documents and, where applicable, Processing Statements.

TRACES NT (Trade Control and Expert System – New Technology): The EC’s integrated digital platform for sanitary, phytosanitary, and fisheries control documentation, including the EU CATCH module used for Catch Certificates, Processing Statements, and Non-Manipulation Documents.

Traceability: The ability to track fishery products through stages of harvest, processing, storage, transport, and distribution, linking finished products to their original legally harvested catch.

U.S. Exporter: Any U.S. individual or entity responsible for exporting fish or fishery products from the U.S. to the EU and for ensuring compliance with applicable U.S. and EU IUU documentation requirements.

Wild-Caught Seafood: Fish or fishery products harvested from the natural environment, excluding aquaculture products.

EU Legislative and Regulatory Changes

The EU has updated its IUU fishing regulations, requiring most seafood imports to include additional supply chain data.  Importers and freight forwarders must enter this information into the EU’s CATCH platform before shipment. NOAA’s previous administrative arrangements with the EU have ended, making U.S. exports subject to the new reporting requirements. 

Catch Certificate (Reported CATCH) Guidance for U.S. Exporters

Overview: Interaction between the U.S. and EU Systems

For exports of U.S.-harvested wild-caught seafood to the EU:

• U.S. catch documentation (Reported CATCH) is created, reviewed, and issued in the U.S. government system (Seafood Inspection Services Portal - SISP).
• The EU CATCH Certificate is created and managed in TRACES NT (CATCH module).
  • Information from the U.S.-issued catch document is used by the EU importer to populate and validate the EU Catch Certificate.

NOAA SIP has no role in the TRACES NT CATCH module system nor do we have any control over its operation or the technical aspects of its use.

The U.S. catch document, Reported CATCH, remains the authoritative record of legal harvest, while the EU CATCH certificate is the import control document used by EU authorities.

The use of TRACES NT EU CATCH is mandatory for EU importers for the submission of the catch certificates and related documents for the import of fish or fishery products.

Step 1 — Determine Whether an EU Catch Certificate Is Required

Before starting any certification process, the exporter must confirm that:

• The product is wild-caught (not aquaculture).
• The product is not exempt under EU IUU fishing rules (please refer to the EU’s Council Regulation EC No 1005/2008 Annex 1 for the full list of exempt items).
• Only products classified under Harmonized System (HS) codes in Chapter 03 or Chapter 16 are required for U.S. Reported CATCH documentation for entrance into the EU (https://www.census.gov/foreign-trade/schedules/b/index.html)
• The product is intended, at some stage, for import into the EU, including shipments to EU Member States or EU military bases.

Step 2 — Create the Reported CATCH Document in the U.S. System

U.S. exporters must request and obtain catch documentation through the Seafood Inspection Services Portal.

Key Actions for Exporters:

• Review the Instructions for Completing the Reported Catch Certificate
• Create a Reported CATCH document request for the shipment
• Ensure the request reflects the actual harvest information, including, but not limited to:
  • Harvesting vessel(s)
  • Flag state
  • Species and product forms
  • Catch dates and areas
  • Quantities by species
• Ensure the shipment details (exporter, consignee, destination country) are accurate.

The U.S. system serves as the official record confirming the product was legally harvested under U.S. law.

Step 3 — Vessel and Harvest Confirmation (U.S. Side)

Depending on the fishery and product:

• Harvest information may be confirmed through existing U.S. monitoring, reporting, and permitting systems.
• Vessel identity and authorization must be consistent with U.S. records.

Exporters should ensure that:

• All vessels listed are correctly identified.
• The quantities requested do not exceed documented harvest.

Incomplete or inconsistent data can delay issuance of the Reported CATCH document and, in turn, delay EU CATCH completion.

Step 4 — Issuance of the Reported CATCH Document

Once reviewed and approved:

• SIP issues the Reported CATCH document.
• The document confirms the product meets U.S. legal harvest requirements.

This issued Reported CATCH document is the primary source document used to support the EU Catch Certificate.

Step 5 — Use the Reported CATCH Document to Complete EU CATCH (TRACES NT)

After the Reported CATCH document is issued:

• The exporter works with the EU importer (depending on arrangements) to ensure the importer enter corresponding data into TRACES NT – CATCH.
• Data entered in EU CATCH must be consistent with the U.S.-issued Reported CATCH document, including but not limited to:
  • Vessel names and identifiers
  • Catch dates and areas
  • Species and quantities

Discrepancies between the U.S. document and EU CATCH entries may result in EU import delays or rejections.

Step 6 — Transport and Shipment Details

U.S. exporters should note:

• Transport details (container numbers, seals, routing) are entered in EU CATCH, not on the Reported CATCH document.

Exporters should plan logistics carefully and coordinate with EU importers to ensure transport details are added correctly at the appropriate stage in TRACES NT.

Step 7 — Coordination with EU Importers

U.S. exporters are encouraged to:

• Share the final Reported CATCH document promptly with their EU importer.
• Confirm that the EU importer has access to TRACES NT and understands how to link the U.S. catch information to the EU Catch Certificate.
• Coordinate on any additional EU-required documents (e.g., processing statements for processed products).

Key Compliance Tips for U.S. Exporters

• Start early: EU CATCH is data-intensive; delays may occur when Reported CATCH documentation is requested too late.
• Be precise: Vessel grouping allowances or administrative flexibilities used in the past are no longer accepted under the updated EU system.
• Maintain records: Keep digital copies of issued Reported CATCH documents and any superseded versions as well as any supporting documentation necessary for traceability purposes.
• Communicate: Close coordination between exporters, brokers, and EU importers is essential.

This guidance reflects current alignment between U.S. catch documentation systems and the EU’s digital CATCH framework. 

Processing Statement Guidance for U.S. Exporters

U.S. Requirements to Support EU Processing Statement Submissions - Annex IV 14.2 Processing Statement

This guidance explains what U.S. exporters must do to support completion of the EU Processing Statement (Annex IV 14.2 Processing Statement) required under the EU IUU Fishing Regulation when exporting processed wild-caught seafood products to the EU.

The Processing Statement (Annex IV 14.2 Processing Statement) is a mandatory traceability document under the EU IUU Fishing Regulation. It certifies that fishery products imported into, or re-exported to, the EU after processing in a non-EU country come from legally harvested catches. The statement links the processed products to the original Catch Certificate and records all processing operations.

Under EC regulations, “processing” includes cutting, filleting, packing, canning, freezing, smoking, salting, cooking, pickling, drying, or any other method of preparing fish for market.  Processing does not include storing or holding. 

For purposes of the Annex IV 14.2 Processing Statement, “processing” includes cutting, filleting, packing, canning, freezing, smoking, salting, cooking, pickling, drying, or any other method of preparing fish for market. Processing does not include storing or holding. Note that for the purposes of the CATCH reporting requirement, a processing statement is not required when the activity is limited to freezing and/or packing only.

A Processing Statement is required for all processed fishery products entering the EU, including those processed in the fishing vessel’s flag State, ensuring traceability and consistency between reported catch and finished product.

Overview: Interaction Between the U.S. System and the EU Processing Statement

For exports of wild-caught seafood that are processed prior to EU import:

• Catch documentation (example: Reported CATCH if U.S.-caught) is created, reviewed, and issued by the country’s competent authority (example: NOAA Seafood Inspection Program if U.S.-caught).
• The Processing Statement (Annex IV 14.2 Processing Statement) is created, reviewed, and issued in the U.S. government system (Seafood Inspection Services Portal – SISP) from information from one or more CATCH documents.
• The TRACES NT Processing Statement is entered into TRACES NT.
• NOAA SIP has no role in TRACES NT and has no control over its operation or technical requirements.

Step 1 — Determine Whether a Processing Statement Is Required

Before preparing a Processing Statement, exporters must confirm that:

• The product is wild-caught (not aquaculture).
• The product is not exempt under EU IUU rules.
• The product has undergone processing outside the EU before import.
• The product is destined, at some stage, for import into the EU, including EU Member States or EU military bases.

If required, an EU Processing Statement cannot be completed without valid underlying catch certificates, such as U.S.-issued Reported CATCH documents or catch certificates issued by other foreign competent authorities for products harvested in their respective countries.

Step 2 — Obtain the Underlying Catch Documentation

U.S. exporters must ensure that all source raw material used in the processed product is supported by valid catch documentation.

Key actions for exporters:

• For U.S.-caught products, Request and obtain Reported CATCH documents through the Seafood Inspection Services Portal.
• For foreign-caught products, request and obtain catch documentation from the source country.
• Ensure each catch document accurately reflects all required information.
• Confirm that the catch documentation fully covers the quantities used in processing.

For U.S.-caught products, the U.S. system serves as the official record confirming that the seafood was legally harvested in accordance with U.S. law.

Step 3 — Verify Traceability through Processing

Before completing the Processing Statement, exporters and processors should ensure that:

• Incoming raw material quantities can be clearly linked to one or more valid catch certificates.
• Processing records demonstrate a clear mass balance between inputs (raw material) and outputs (processed product).
• No commingling occurs with material lacking valid catch documentation.

Incomplete traceability or unsupported quantities may result in rejection by EU authorities.

Step 4 — Complete the EU Processing Statement in TRACES NT

Using the information on the Annex IV 14.2 Processing Statement, the Processing Statement is completed in TRACES NT – CATCH module by the EU importer depending on contractual arrangements.

Information required includes, but is not limited to:

• Identification of the processing establishment
• Description of processing operations performed
• Product descriptions before and after processing
• Quantities used and produced
• References to all underlying catch certificates (e.g., Reported CATCH numbers)
• Country where processing took place

All data entered must be consistent with the underlying catch documentation.

Step 5 — Validation by the Processing Country Authority

Once completed:

• The Processing Statement must be validated by the competent authority of the country where processing occurred.
   
• Validation confirms that:
  • The processing took place as declared
  • The products originate from legally harvested catches
  • Traceability has been maintained throughout processing

An unvalidated Processing Statement is not acceptable for EU import purposes.

Step 6 — Link the Processing Statement to EU Import Documentation

After validation:

• The Processing Statement is linked within TRACES NT to the relevant EU Catch Certificate and import consignments.
• Transport and shipment details are managed within TRACES NT and are not part of the U.S. Reported CATCH document.

Exporters should coordinate closely with EU importers to ensure all references are correctly linked.

Step 7 — Coordination with EU Importers

U.S. exporters are encouraged to:

• Provide EU importers with copies of all underlying catch documents.
• Confirm that EU importers understand how to reference catch documentation within the Processing Statement.
• Coordinate on additional EU-required documentation, including health certificates and transport details.

Key Compliance Tips for U.S. Exporters

• Start early: Processing Statements depend on complete and accurate catch documentation.
• Be precise: Quantities, species, and vessel information must align across all documents.
• Maintain records: Retain processing records, mass-balance documentation, and digital copies of all issued and superseded catch documents.
• Communicate: Close coordination between U.S. exporters, foreign processors, and EU importers is essential to avoid delays.

This guidance reflects current requirements under Regulation (EU) 2023/2842 and its implementation within the EU’s digital TRACES NT CATCH framework.

Non-manipulation Statement Guidance for U.S. Exporters

U.S. Requirements to Support EU Processing Statement Submissions - Annex IV 14.1 Non-Manipulation Document

This guidance explains what U.S. exporters must do to support completion of the EU Non-Manipulation Document required under the EU IUU Fishing Regulation when exporting wild-caught seafood products that transit through, or are stored in, a non-EU country without processing prior to import into the EU.

The Non-Manipulation Document is a mandatory traceability document under the EU IUU Fishing Regulation. It certifies that fishery products, including live products, exported to the EU have not been altered, substituted, or processed while outside the EU and that traceability and integrity of the consignment have been maintained throughout storage or transshipment.

Under Regulation (EU) 2023/2842, the Non-Manipulation Document is required when products are stored, split, consolidated, or transshipped in a third country, provided no processing occurs. The document supports continuity between the original Catch Certificate and the product presented for EU import.

Overview: Interaction between the U.S. System and the EU Non-Manipulation Document

For exports of wild-caught seafood that transit or are stored in a non-EU country without processing prior to EU import:

• Catch documentation is created, reviewed, and issued by the competent authorities
• The Non-Manipulation Document (Annex IV 14.1 Non-Manipulation Document) is created, reviewed, and issued by the competent authority of the country where storage or transshipment occurred.
• The Non-Manipulation information is entered into TRACES NT by the EU importer or other responsible party.
• NOAA SIP has no role in TRACES NT and has no control over its operation or technical requirements.

If required, an EU Non-Manipulation Document cannot be completed without valid underlying catch certificates, such as catch certificates issued by other foreign competent authorities for products harvested in their respective countries.

Step 1 — Determine Whether an Annex IV 14.1 Non-Manipulation Document Is Required

Before export, exporters must confirm that:

• The product is wild-caught (not aquaculture).
• The product is not exempt under EU IUU rules.
• The product did not undergo processing outside the EU.
• The product was stored, transshipped, split, or consolidated in the U.S.
• The product is destined, at some stage, for import into the EU, including EU Member States or EU military bases.
   

Under Regulation (EU) 2023/2842, processing includes any operation that alters the presentation of the product, such as cutting, filleting, freezing, packing, canning, smoking, salting, cooking, drying, pickling, or otherwise preparing fish for market.

Simple storage, handling, reloading, or transport does not constitute processing.

Where no processing has occurred, a Processing Statement is not applicable, and a Non-Manipulation Document (Annex IV 14.1 Non-Manipulation Document) is required.

Step 2 — Obtain and Maintain Valid Catch Documentation

U.S. exporters must ensure that all products entering storage or transshipment are supported by valid catch documentation.

Key actions for exporters:

• For U.S.-caught products, request and obtain Reported CATCH documents through the Seafood Inspection Services Portal.
• For foreign-caught products, request and obtain catch documentation from the source country.
• Ensure that catch documents are accurate, complete, and valid.
• Confirm that quantities shipped match quantities covered by the catch documentation.
• Provide copies of catch documents to downstream operators, storage facilities, and EU importers as needed.

For U.S.-caught products, the U.S. system serves as the official record confirming that the seafood was legally harvested in accordance with U.S. law.

Step 3 — Maintain Product Integrity during Storage or Transshipment

During any non-EU storage or transit period, exporters and logistics partners must ensure that:

• Products remain sealed, identifiable, and traceable.
• No substitution, repackaging that alters identity, or processing occurs.
• Lot numbers, container numbers, and seals are maintained and documented.
• Quantities leaving the third country do not exceed quantities entering under valid catch documentation.

Failure to maintain integrity may result in EU rejection due to perceived gaps in traceability.

Step 4 — Completion of the Non-Manipulation Document (Annex IV 14.1 Non-Manipulation Document)

The Non-Manipulation Document is completed based on records maintained during storage or transshipment and includes, at a minimum:

• Identification of the storage or transshipment facility
• Description of operations performed (e.g., storage, unloading, reloading)
• Confirmation that no processing or alteration occurred
• Product description and quantities
• Container, seal, and transport references
• References to the underlying Catch Certificate(s) (e.g., Reported CATCH numbers)
• Dates and location of storage or transshipment

All information must be fully consistent with the underlying catch documentation.

Step 5 — Validation by the Third-Country Competent Authority

Once completed:

• The Non-Manipulation Document must be validated by the competent authority of the country where storage or transshipment occurred.

Validation confirms that:

• The products remained under official control
• No processing or manipulation occurred
• Traceability to the original Catch Certificate has been maintained

Step 6 — Link the Non-Manipulation Document in TRACES NT

After validation:

• The Non-Manipulation Document is entered and linked in TRACES NT to the relevant EU Catch Certificate and import consignment.
• Transport and shipment details are managed within TRACES NT, not within NOAA SIP systems.
• Exporters should ensure EU importers have all necessary references and supporting documents.

Step 7 — Coordination with EU Importers

U.S. exporters are encouraged to:

• Provide EU importers with copies of all underlying catch documents.
• Coordinate closely on shipment timing, container references, and supporting documentation to avoid delays.

Key Compliance Tips for U.S. Exporters

• Plan ahead: Non-Manipulation Documents depend on continuous, documented custody.
• Maintain integrity: Seals, quantities, and product identity must remain intact.
• Avoid scope creep: Any processing, even minimal, invalidates use of a Non-Manipulation Document.
• Keep records: Retain storage records, transport logs, seal information, and all catch documentation.
• Communicate: Clear coordination among exporters, logistics providers, third-country authorities, and EU importers is essential.

This guidance reflects current requirements under Regulation (EU) 2023/2842 and associated EU implementation guidance within the TRACES NT CATCH framework, including the EU Non-Manipulation Document model and instructions.

Additional resources on EU CATCH

• EU Control Regulation Website
  • The new EU Fisheries Control Regulation 2023/2842 was published in December 2023 and entered into force on 9 January 2024.
• EU fisheries control system
• EC IUU Fishing Website
• Regulation (EU) 2023/2842 amending Control Regulation (EC) 1224/2009
• Council Regulation (EC) No 1224/2009
  • Established the EU Fisheries Control System
• Council Regulation (EC) No 1005/2008
  • EU IUU Fishing Regulation
  • Chapter III Establishment of Catch Certification Scheme
• Annex 1 of the IUU Fishing Regulation for Excluded Products
• Commission Implementing Regulation (EU) 2025/1522 of 28 July 2025
  • Regulation implementing CATCH
• DG MARE FAQs (December 2025)
• DG MARE TRACES NT Documents
• Contact TRACES NT

Sample Certification Scheme Scenario