Licence holder signature on catch certificates – Questions and Answers

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Questions for first buyers

1. Why does the buyer have to sign catch certificates on behalf of licence holders?
2. What can I do if a licence holder refuses to complete the authorization process to allow me to add their vessel to my grouping?
3. What if I use a vessel based buyer/agent grouping for fish purchased from another company, who should the signatory be?

Questions for licence holders

4. Is the licence holder signature or the signature of their duly authorized representative required on catch certificates? And if so, why?
5. Why do I need to authorize a catch certification representative?
6. What would happen if I do not authorize a buyer to sign catch certificates on my behalf?
7. If I refuse to authorize a buyer, is there any other way for my catches to be certified?
8. Why is the catch certification authorization done through my NOLS account?
9. Who can be my catch certificate representative?
10. I already have a designated NOLS representative, do I still need to designate a catch certificate representative?
11. Can my existing NOLS representative complete the process of designating a duly authorized representative for catch certification on my behalf?
12. Can I have multiple catch certificate representatives?
13. Can my newly set up duly authorized representative sign for any other documents for me, besides catch certificates?
14. What if I no longer wish to have a buyer represent me?
15. Why does my representative have to be the buyer of my catches or the Applicant Manager for their company?
16. Is there a guide or other material I can refer to for more information?
17. What if my buyer is not registered in FCS?
18. Which account should I use to make this request—my organization account or my personal fisher account?
19. What if the licence is linked to an estate account?

Questions for first buyers

1. Why does the buyer have to sign catch certificates on behalf of licence holders?

   The first buyer in the supply chain is responsible for creating a catch certificate application which includes all of the information related to the harvest of the product. As the first buyer, they will have received this information directly from the licence holders and/or vessel operators. Their signature next to each vessel entry will serve to confirm that the catch information that is reported is accurate and aligns with what the licence holder reported to them. Since the buyer (Applicant Manager) signature is already captured in FCS and appears on catch certificates in the exporter declaration section, having their signature appear next to all catch entries aligns with the current Canadian certification process and does not introduce significant additional burden to buyers or licence holders.

2. What can I do if a licence holder refuses to complete the authorization process to allow me to add their vessel to my grouping?

   To be eligible for export to the EU, catches must be accompanied by certificates that include all of the information that is mandatory under the EU IUU Regulation. This includes the signature of the licence holder or their representative. It is recommended that this be clearly communicated to licence holders so that they understand the reason for the authorization process and sharing of catch information.

   To assist with this, DFO has prepared several other documents, in addition to this Questions and Answers document, that may be shared with licence holders. These include:

   • Update regarding the European Union’s catch certification scheme – requirement for licence holder signature
   • Catch Certification Authorized Signatory instructions

3. What if I use a vessel based buyer/agent grouping for fish purchased from another company, who should the signatory be?

   If you certify fish that you purchased from another company using a vessel- based buyer/agent grouping, you will need to contact the buyer/agent and discuss the following options:

   • Option 1: If the buyer/agent is able to register in FCS, they must contact the harvesters they purchase from and advise them to submit a signatory request authorizing the Applicant Manager of their company to sign for their catch information.
   • Option 2: If the buyer/agent is not able to register in FCS, they must contact the harvesters they purchase from and advise them to submit a signatory request authorizing the Applicant Manager of your company (the company that will be applying to certify the fish) to sign for their catch information.

Questions for licence holders

4. Is the licence holder signature or the signature of their duly authorized representative required on catch certificates? And if so, why?

   Yes, the EU requires vessel masters or licence holders to sign each catch certificate after the catch information for each fishing trip has been reported. The purpose of this requirement is to confirm that the catch information recorded on the certificate accurately reflects what was actually harvested

5. Why do I need to authorize a catch certification representative?

   Given the challenge of having you sign every catch certificate directly, it will be acceptable on Canadian catch certificates to have a duly authorized representative sign catch certificates on behalf of the licence holder.

   To sign for you, your buyer must first be duly authorized as your representative. Once they are authorized, you will not be required to view and sign each catch certificate, or to use the Fisheries Certificate System to report catches for the export certification process.

6. What would happen if I do not authorize a buyer to sign catch certificates on my behalf?

   If you do not authorize a buyer to sign catch certificates on your behalf, your catches will not be eligible for export to the EU. To be eligible for export to the EU market, fish and seafood products must be accompanied by a catch certificate which includes mandatory information related to the catch, as well as the signatures of all licence holders or their duly authorized representative(s).

7. If I refuse to authorize a buyer, is there any other way for my catches to be certified?

   If you refuse to authorize a buyer, the only way to certify your catches would be to create your own account in the Fisheries Certificate System and apply for your own catch certificates. You will need to enter your catch information for each trip in a catch certificate application and forward this to your buyer. This must be done for all sales transactions, so typically one certificate application per fishing trip.

8. Why is the catch certification authorization done through my NOLS account?

   When logging into your NOLS account, you are cyber authenticated through the GC Key secure key login process. Through this process, we can confirm that you are the licence holder who is the holder of the NOLS account being used to designate the representative. Using this process helps to alleviate the need for an exchange of documents including wet signatures, which would otherwise be needed to duly authorize your representative.

9. Who can be my catch certificate representative?

   Your duly authorized representative for catch certificate applications is the company that creates catch certificates for your product, for example, your fish buyer. This company will be registered to use the Fisheries Certificate System and will be completing applications for certificates which include all of the required information that you provide them about your catches. This enables them to sign certificates on your behalf, knowing that the information they have entered into FCS reflects what you have harvested and sold to them.

10. I already have a designated NOLS representative, do I still need to designate a catch certificate representative?

    Yes, you still need to designate a catch certificate representative. The NOLS representative is authorized to conduct business in NOLS on your behalf, whereas a catch certificate representative is authorized to apply for catch certificates and provide information about your catches within the Fisheries Certificate System on your behalf.

11. Can my existing NOLS representative complete the process of designating a duly authorized representative for catch certification on my behalf?

    Yes, your NOLS representative can designate a duly authorized representative for catch certification on your behalf, since you have given them the authority to conduct business on your behalf in NOLS.

12. Can I have multiple catch certificate representatives?

    Yes, you can have multiple different catch certificate representatives.

13. Can my newly set up duly authorized representative sign for any other documents for me, besides catch certificates?

    No, the duly authorized representative for catch certificates is only able to sign for the catches on catch certificate applications because you are providing them with all of the required information to complete the application. They are not authorized to represent you for any business outside of business being conducted for the Catch Certification Program, or for reporting in the FCS.

14. What if I no longer wish to have a buyer represent me?

    When submitting a request in NOLS using the “Catch Certificate Signatory Request” request type, two options for sub-request type will exist. One of these will include the option to terminate the authorization of a representative. Once DFO has received this request, it will be actioned by Catch Certification Program (CCP) staff, and the representative will no longer be able to sign for your catches.

15. Why does my representative have to be the buyer of my catches or the Applicant Manager for their company?

    The first buyer in the supply chain is responsible for creating a catch certificate application which includes all of the information related to the harvest of the product. As the first buyer, they will have received this information directly from the licence holders and/or vessel operators. Their signature next to each vessel entry will serve to confirm that the catch information that is reported is accurate and aligns with what the licence holder reported to them. Since the buyer (Applicant Manager) signature is already captured in FCS and appears on catch certificates in the exporter declaration section, having their signature appear next to all catch entries aligns with the current Canadian certification process and does not introduce significant additional burden to buyers or licence holders.

16. Is there a guide or other material I can refer to for more information?

    Please refer to the instruction document called “Catch Certification Authorized Signatory Instructions” which is a step by step guide to submitting a request in NOLS for more information.

17. What if my buyer is not registered in FCS?

    If your buyer is not registered within FCS, then you should contact your buyer and ask them to provide you with the name of the company that they are selling your catch to and the name of the FCS Applicant Manager for that company. The Applicant Manager is the company manager whose signature appears on catch certificates.

18. Which account should I use to make this request—my organization account or my personal fisher account?

    You would use the account that your licence is linked to. For example, if the licence is held by your business, you would make this request through your organization account. If the licence is held by you as an individual, you would make this request in your personal fisher account.

19. What if the licence is linked to an estate account?

    You would use the account that the licence is linked to. If the licence is held under an estate, you would make this request through the estate account.