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Empowering Consumers for the Green Transition Directive: How Does ASC Meet the Requirements?
ASC welcomes the Empowering Consumers for the Green Transition Directive (‘EmpCo’ or ECT) and all initiatives to promote credible transparency aimed at combatting greenwashing towards consumers and stakeholders.
We are an ISEAL Alliance member, and verifiably compliant with the ISEAL Code of Good Practice for Sustainability Systems – a globally recognised framework that defines best practices for credible sustainability systems and claims.
ASC is the only aquaculture assurance programme that simultaneously meets best practice requirements set by the UN Food and Agriculture Organisation (FAO) Code of Conduct for Responsible Fisheries (as recognised under the Global Sustainable Seafood Initiative – GSSI) and is independently evaluated as complying to ISEAL’s Code of Good Practice. ISEAL Code compliance is also being recognised under the EU Corporate Sustainability Reporting Directive (CSRD)’s Environmental Sustainability Reporting Standard (ESRS) for Biodiversity (ESRS, E-4. Article 17.e “conforms to the ISEAL Code of Good Practice”).
The ASC certification scheme is based on third-party verification, adheres to internationally recognised standards and Conventions, such as the UN Guiding Principles on Business and Human Rights, the Ten Principles of UN Global Compact and International Labour Organisation (ILO) Conventions; it is open under transparent and non-discriminatory terms to all traders that respect the EU law.
Furthermore, ASC provides unrivalled transparency (defined as proactive public disclosure) in the realm of aquaculture certification.
How does ASC specifically meet EmpCo requirements?
The ASC welcomes the EmpCo and all initiatives to promote credible transparency aimed at combating greenwashing towards consumers and stakeholders. We are an ISEAL Alliance member, also verifiably compliant with the ISEAL Code of Good Practice for Sustainability Systems – a globally recognised framework that defines best practices for credible sustainability systems and claims. ISEAL Code compliance is also being recognised under the current EU Corporate Sustainability Reporting Directive (CSRD)’s Environmental Sustainability Reporting Standard (ESRS) for Biodiversity (ESRS, E-4. Article 17.e “conforms to the ISEAL Code of Good Practice”).
Based on the requirements set out in Article 1 (q) and (r) of the EmpCo Directive, we are confident without prejudice that the ASC is in alignment with the EmpCo requirements for a recognised “sustainability label” and “certification scheme”.
EmpCo Requirement: Voluntary “Sustainability Label” [Art. 1 (q)]
“sustainability label” means any voluntary trust mark, quality mark or equivalent, either public or private, that aims to set apart and promote a product, a process or a business by reference to its environmental or social characteristics, or both, and excludes any mandatory label required under Union or national law;”
How does ASC comply?
The ASC label is a voluntary trust mark or equivalent that aims to set apart and promote a product by reference to its environmental or social characteristics, and which excludes any mandatory label required under Union or national law.
EmpCo Requirement: Third-Party Transparent Certification Scheme [Art. 1 (r)]
“certification scheme” means a third-party verification scheme that certifies that a product, process or business complies with certain requirements, that allows for the use of a corresponding sustainability label, and the terms of which, including its requirements, are publicly available and meet the following criteria […]”
How does ASC comply?
ASC certification is a third-party certification scheme that operates through a voluntary and independent auditing system. Audits and certification are carried out by accredited certification bodies, independent from ASC and themselves supervised and audited by ASI (Assurance Services International); while the public/stakeholders can access publicly available complaints mechanisms.
EmpCo Requirement: Transparency, Fair and Non-Discriminatory [Art. 1 (r) i]
“…. […] the scheme is open under transparent, fair, and non-discriminatory terms to all traders willing and able to comply with the scheme’s requirements;”
How does ASC comply?
ASC meets the EmpCo requirements for a transparent, fair and non-discriminatory certification scheme to all traders willing and verifiably able to comply with the scheme’s requirements. Being ISEAL Code compliant, ASC is also able to demonstrate standard-requirements and thought leadership on cross-cutting areas such as data and stakeholder engagement, due diligence, remediation, and gender/non-discriminatory issues.
Transparency – and more specifically proactive public disclosures and accountability – are core to ASC and our requirements towards certified operations are unrivalled in the realm of aquaculture certification:
- All ASC standards are available on our website: Our standards – ASC International.
- All certification procedures are transparent and available here: Get ASC Certified: Producers and Get ASC Certified: Feed Mills.
- Programme and standard development undergo several phases of public consultation, with stakeholder feedback and responses being made public.
- All audit reports of ASC-certified farms and feed manufacturers are proactively made public here: Find an ASC-certified Farm and Find an ASC-certified Feed Mill.
- Audits are announced publicly weeks ahead to make stakeholders aware and make their intention to be consulted/engaged known to the certifier.
- There are mandatory public comment periods and stakeholder engagement/consultation opportunities before certification is awarded and complaints mechanisms are available.
- Audits are conducted annually, and a minimum of 10% of audits are unannounced.
- There is a public and searchable certification-status database which beyond display of valid certificates (and associated audit reports) includes information regarding incomplete initial certification, failed audits, certification not awarded, withdrawn, suspended, cancelled or expired.
- Exact (GPS polygon) geolocation verified and displayed in a multi-layered GSI.
- Timely proactive public disclosures are required regarding various events and non-conformances.
- Audit procedures, as well as suspensions or withdrawals, are available here: ASC Farm and Feed Certification and Accreditation.
- There are various complaint mechanisms available to concern stakeholders at various levels of the certification process.
- ASC publishes Monitoring and Evaluation (‘Impact’) reports annually demonstrating the positive impacts of certification on people, farmed animals, and the environment: Annual Report ASC.
- As a UK-registered Charity and NGO, ASC publishes its accounts annually.
EmpCo Requirement: Multi-Stakeholder Development of ASC Scheme [Art. 1 (r) ii]
“[…] the scheme’s requirements are developed by the scheme owner in consultation with relevant experts and stakeholders;”
How does ASC comply?
ASC is the only aquaculture certification scheme that meets the strict requirements of ISEAL regarding multi-stakeholder engagement for standard development and revision; inclusive of all relevant (aquaculture companies, environmental and social NGOs and civil society, local communities, Chain of Custody certificate holders) stakeholders and industry/academic experts.
The development and revisions (every 3 to 5 years) of ASC standards follow a defined and precise procedure available here: ASC Programme Development and Revision Procedure.
It includes:
- Working groups composed of international experts: NGOs, academics, scientists, producers, processors, retailers, etc. The composition of the working groups is available here: Governance.
- Public consultations on the criteria developed by the working groups. A full history of public consultations can be found here: Completed projects.
- Science-based criteria supported by measurable performance indicators (available in audit reports).
EmpCo Requirement: Dealing with Non-Compliance, Withdrawals & Suspension [Art. 1 (r) iii]
“[…] the scheme sets out procedures for dealing with non-compliance with the scheme’s requirements and provides for the withdrawal or suspension of the use of the sustainability label by the trader in case of non-compliance with the scheme’s requirements;”
How does ASC comply?
ASC has various and rigorous mechanisms in place to assess and address/correct any non-compliance to all of its requirements (i.e. all non-compliances have to be addressed to gain/retain certification; this is not always the case amongst aquaculture certifiers).
Cancellation, suspension and withdrawal of accreditation and certification are also specifically addressed and enabled under conditions outlined in the document titled “ASC Farm and Feed Certification and Accreditation Requirements” (known as the ‘CAR Farm & Feed v1.0’) Section 4 & 13 (“Conditions for Suspensions and Withdrawals of Accreditation”… “Cancellation, Suspension and Withdrawal of Certification”).
Only licensed ASC certificate holders may use and apply the ASC label.
EmpCo Requirement: Independent 3rd Party Audited Compliance to Scheme Requirements [Art. 1 (r) iv]
“[…] the monitoring of a trader’s compliance with the scheme’s requirements is subject to an objective procedure and is carried out by a third party whose competence and independence from both the scheme owner and the trader are based on international, Union or national standards and procedures;”
How does ASC comply?
ASC certification is based on independent third-party audits conducted by Conformity Assessment Bodies (CABs) accredited by Assurance Services International GmBH (ASI). ASI is an independent organisation which oversees more than 85 CABs across 150+ countries, ensuring consistent performance. CABs comply with international standards, including the ISO 17065 standard as set out in the EmpCo.
Regarding its independence and integrity for certification and auditing: ASC doesn’t have any financial ties with the farms or feed mill operations being certified; and use of the label (for which there is a ‘Licensing Agreement’) is voluntary.
Date: Information above is deemed accurate as of 28 November 2025.