Questions and answers about the EU’s January 2026 Illegal, Unreported, and Unregulated (IUU) fishing regulation changes

1. The definition of ‘processing’ under the updated requirements is as follows: ‘Processing operations requiring a processing statement include cutting, filleting, canning, smoking, salting, cooking, pickling, drying or preparing fish for market in any other manner.’ The reference to ‘…preparing fish for market in any other manner’ is very vague. Has the UK received any clarification on which specific activities – besides cutting, filleting, canning, smoking, salting, cooking, pickling, and drying – could be classed as ‘processing’?

Anything other than freezing or packing constitutes grounds for a Processing Statement to be required under the updated rules. The EU’s list of activities that are classed as ‘processing’ is deliberately non-exhaustive to capture all activities, except for freezing and packing. The use of agents to prevent drip loss or black spot would require a processing statement (as it is neither freezing nor packing).

2. What should businesses do when required transport or logistics details (e.g., trailer number and seal number) are unknown until after dispatch?

The EU has confirmed that exporters may provide the transport details available at the time of certificate creation, even if these reflect pre-export movements happening in the UK rather than the final export leg. This approach was agreed following UK engagement with the EU to address industry concerns.

3. What is the position on the catch certificate number needing to appear on labels and packaging?

The catch certificate number must appear on labels at the lot level, not on individual units. A pallet-level or outer-lot label is sufficient. Digital labels are permitted but must be accessible to enforcement officials across the UK-EU border.

4. Who is responsible for enforcing these EU requirements?

EU member state authorities are responsible for enforcement upon importation into the EU. Within the UK – MMO, Defra, and devolved administrations are responsible for supporting exporters, providing guidance, and coordinating policy; however, they do not enforce EU import rules. 

5. Are transport registration numbers required on invoices or labels?

No. Transport registration numbers are not required on invoices or product labels. Some businesses had been under the impression that they were required on invoices or product labels because of the transport-detail requirements on catch certificates; however, those catch certificate requirements are separate from labelling obligations.

6. What is the rationale behind requiring detailed fishing gear type information?

The EU’s stated rationale is to improve traceability, support sustainability, and reduce the entry of IUU products into the EU market. Catch certificates now require detailed gear type information – for example, about forms of trap (e.g., pots) and forms of trawl (e.g., twin bottom otter trawl) – rather than the higher-level information required previously.

7. Do incorrect catch certificates lead to trucks being rejected at the EU border?

This depends on the nature of the error. EU member states use a digital database that enables real-time checks, allowing some errors to be corrected quickly. However, misalignments can still lead to delays or rejection. The UK is engaging with the EU to promote consistency across member states in their approach to enforcement.

8. Is a processing statement required when processing occurs on board a vessel?

No. A processing statement is required only for land-based processing. On-board processing does not require a processing statement.

9. Do the updated requirements affect commodity codes?

No. Commodity codes remain unchanged.

10. Are processing statements required for species that do not require a catch certificate?

No. Species exempt from the ‘fishery products’ definition are exempt from all three documents (catch certificate, processing statement, and storage document).

11. Can a single catch certificate cover multiple vessels and multiple landings?

Yes. A catch certificate can include up to 100 lines – covering multiple vessels, landing dates, and species. This is standard practice for mixed-origin processed batches.

12. Must the Export Health Certificate number be included on the processing statement?

Yes.

13. Must UK sellers (e.g., fish markets) provide all the information needed for the updated certificates without buyers requesting it?

Most required data is already mandatory under UK labelling law, but it does not always move through the supply chain effectively. Guidance and templates have been created to help with this, but buyers should actively request missing data from suppliers to ensure compliance.

14. How should exporters handle frozen stock landed before 10 January 2026 but exported after that date?

Frozen stock caught before 10 January 2026 but exported after that date must use the updated documentation template, unless a document was already created prior to 10 January 2026.

15. What happens if a catch certificate must be voided and reissued during transit after labels have been created?

If a catch certificate must be voided and reissued during transit, the importer should be informed immediately, as they are responsible for ensuring labelling compliance.

16. Can a pallet or lot label contain multiple catch certificate numbers?

Yes.

17. Must the updated documentation physically accompany the consignment?

This depends on the importing member state; practices vary in terms of whether digital submission is acceptable. Exporters are advised to confirm requirements with their importer and the relevant importing authority in the member state.