A practical, action-first guide for Indonesian processors re-exporting to the EU using imported raw materials. What a Processing Statement is, when you need it, who signs it in Indonesia, how to verify foreign Catch Certificates, map weights/yields, complete the form, avoid rejections, and move on time in 2026.
Why this matters in 2026
If you process imported fish in Indonesia and re-export to the EU, you won’t ship far without a clean EU IUU Processing Statement. We’ve seen brilliant product get stuck at EU border control over simple gaps in weight mapping or a missing transshipment declaration. Here’s the thing. EU authorities have tightened document scrutiny and the CATCH IT platform rollout keeps raising the bar on data consistency. The upside is predictable. When your paperwork aligns with your factory reality, clearance is smooth and repeatable.
Let’s anchor one core distinction up front. A Catch Certificate proves legal harvest for fish exported directly from the flag state of capture. A Processing Statement covers product that was legally caught elsewhere, then imported into Indonesia, processed, and re-exported to the EU. If your raw material was caught by Indonesian vessels and exported from Indonesia to the EU, you’re in Catch Certificate territory. If it was caught by, say, a Taiwanese or Vietnamese vessel and you turned it into portions, loins, or saku here, you need the Processing Statement.
The 3 pillars of a clean Processing Statement file
In our experience, approvals come down to three things.
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Verified foreign Catch Certificates. Don’t assume upstream paperwork is correct. Check vessel flag and name spelling, RFMO authorizations if relevant (ICCAT, IOTC, WCPFC), gear type, FAO areas, dates, species, and net weights. If there was transshipment, you’ll usually need the carrier details and declarations attached. Red flags include mismatched FAO areas versus species distribution, impossible landings timelines, or inconsistent net/gross weights.
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Traceable weight and yield mapping. You must show how much of each CC lot entered your process and how that volume transformed into your HS-coded export SKU. Split-lot production is fine. You just need a transparent logic that ties batch intake to finished goods and unavoidable losses (skin, bone, trim, glazing). The weight trail has to reconcile.
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Correct form completion and HS code alignment. Use the EU Processing Statement form with all CC numbers listed, lot weights consumed, finished product HS/CN description, processing dates, and plant identifiers that match your labels and invoices. Align CN codes with your EU importer and broker. Small mismatches often trigger holds.
Practical takeaway. Build an internal “PS dossier” template once. Reuse and adapt it per shipment. Your future self will thank you.
Week 1–2: Pre-verify before you cut
When the imported raw material lands in Indonesia:
- Validate each foreign Catch Certificate against the checks above. We’ve found that catching issues here saves 90% of headaches later.
- File and index supporting docs: landing/port clearances, transshipment declarations, factory intake weigh notes, and supplier declarations where relevant.
- Assign a unique intake lot ID per CC. If you receive mixed-origin pallets, deconsolidate on paper before production starts. Don’t try to fix it after freezing.
Need a quick sense-check on a complicated file or a multi-vessel mix? We’re happy to review a redacted set and flag risks. If that helps your timeline, Contact us on whatsapp.
Week 3–6: Production and traceability you can defend
During cutting, trim, glazing, and packing:
- Record gross intake, thaw drip (if any), skin/bone removal, and finished net weights per batch. Keep this by lot and shift. A simple matrix sheet works.
- If you blend multiple CC lots into one SKU, use either an actual usage method or a documented pro‑rata allocation. Stick to one method per SKU family.
- Match labels, inner packs, and pallets back to the production batch IDs. The Processing Statement will lift from these records.
For example, if you’re producing Yellowfin Saku (Sushi Grade) and Yellowfin Steak from the same thaw, your mapping should show how each CC lot flowed into each cut with respective yields.
Week 7–12: Compile, validate, and ship
This is where teams either glide or grind.
- Compile the EU Processing Statement form with all CC numbers, weights, processing dates, and final HS description. Attach your weight/yield sheet and intake-to-finished reconciliation table.
- Submit to Indonesia’s Competent Authority for validation. In 2026, the designated CA is the Ministry of Marine Affairs and Fisheries (KKP) through the Directorate General of Capture Fisheries (DJPT). Validation is performed by DJPT at central or designated provincial offices authorized to sign.
- Typical lead time is 3–7 working days after a complete file. If the CA needs to verify a foreign CC with the flag state, add 5–10 days. We plan 2 weeks for multi-CC or tuna-heavy files, just to be safe.
Coordinate with your EU importer on whether their port accepts originals at clearance or allows pre-clearance with good scans and originals to follow. CATCH platform use is growing, but paper remains common in many EU entry points.
Common questions we get
What is an EU Processing Statement and when do Indonesian processors need it?
It’s the EU IUU document that proves legally caught fish from another country was processed in Indonesia and is now being re-exported. You need it whenever your export to the EU contains marine fish that were not originally caught under the Indonesian flag.
Which authority in Indonesia signs the Processing Statement?
The Competent Authority is KKP via the Directorate General of Capture Fisheries (DJPT). Applications are lodged through their designated offices. Your local DJPT contact can confirm where your plant should submit.
Can I mix raw materials from multiple countries or vessels?
Yes. List every Catch Certificate used, with exact weights allocated. Your mapping and finished totals must reconcile. If species or FAO areas differ, ensure your label and HS description still make sense for the final SKU.
What documents must accompany the Processing Statement for EU export?
- Copies of all upstream Catch Certificates used
- Any transshipment or landing declarations cited in those certificates
- Your weight/yield mapping and production records
- Commercial invoice and packing list referencing the same plant codes and HS description Some Member States also ask for the bill of lading and health certificate at clearance. Align with your importer.
Do EU authorities accept scanned Processing Statements from Indonesia?
Often for pre-notification, yes. For final clearance, many ports still expect originals unless the file is processed through the EU CATCH system or a port-specific e-document arrangement. Confirm with your importer before sailing.
How to calculate and show yield mapping
Here’s a simple, defensible approach.
Scenario. You use two CC lots of yellowfin to produce IQF steaks and saku blocks.
- CC A: 5,000 kg WR frozen
- CC B: 4,000 kg WR frozen
- Thaw drip: 4% average. Skinned, trimmed loin yield: 56% from WR equivalent. Finished yields: 75% of loin to saku. 20% of loin to steak. 5% to trim.
Mapping logic.
- WR equivalent intake to loin: (A 5,000 + B 4,000) × 0.96 × 0.56 = 4,838 kg loin
- Finished saku: 4,838 × 0.75 = 3,628.5 kg
- Finished steak: 4,838 × 0.20 = 967.6 kg
- Trim: 4,838 × 0.05 = 241.9 kg
Allocation by lot (pro‑rata by WR intake):
- Lot share A = 5,000/9,000 = 55.56%. Lot share B = 44.44%.
- Saku from A: 3,628.5 × 55.56% ≈ 2,016 kg. From B: ≈ 1,612 kg.
- Steak from A: 967.6 × 55.56% ≈ 538 kg. From B: ≈ 430 kg.
Document these numbers in your mapping sheet, cite assumptions, and attach supporting batch reports. For reef fish products, we do the same. For instance, Grouper Fillet (IQF) or Red Snapper Portion (WGGS / Fillet) runs get lot-by-lot allocations and glazing statements so the net-for-duty aligns with the CN declaration.
Pro tip. EU officers like seeing conversion steps and losses explained in plain language. If your yields depart from your own historical norm, add a one-line reason. Different size grade or higher trim spec is enough.
Why applications get rejected (and how to fix them fast)
We track the same handful of issues again and again.
- Mismatch between CC species/FAO area and finished product description. Fix by aligning product naming and HS code to the dominant species actually used.
- Weight totals don’t reconcile. Your intake minus losses must equal finished goods plus byproducts. Rebuild the mapping sheet and show each step.
- Missing transshipment or landing proof referenced in the CC. Ask the supplier for the specific annexes and keep them in the PS dossier.
- Plant IDs differ across labels, invoices, and the form. Standardize your identifiers and update your internal template.
- Illegible scans or incomplete fields on the form. Re-scan cleanly and fill every field. If it doesn’t apply, mark N/A rather than leaving blanks.
Most rejections we’ve fixed within 48–72 hours once all attachments are in hand.
HS/CN code alignment without the headaches
We always confirm CN codes with the EU importer’s broker before the application goes in. The Processing Statement should reference the finished goods description consistent with the CN declared at import. For tuna loins or steaks, for example, agree the CN description upfront so your PS, invoice, and CHED-P data don’t fight each other. Avoid copying Indonesian HS codes directly into EU paperwork without checking.
When to ask for help
Two cases justify an outside review. First, multi-flag or multi-CC blended products where traceability is dense. Second, tuna with RFMO touches and transshipments. A 30‑minute pre-check can shave weeks off. If you want a redacted sample PDF of a properly completed Processing Statement, or a quick review of your yield logic, Contact us on whatsapp.
If you also need product specs that pair cleanly with EU paperwork, our lines like Yellowfin Saku (Sushi Grade), Grouper Bites (Portion Cut), and Mahi Mahi Fillet are built with batch-level trace files ready for PS compilation. You can browse full options here: View our products.
Quick recap you can act on today
- Decide early if you’re in Catch Certificate or Processing Statement scope.
- Pre‑verify foreign CCs within 48 hours of raw material arrival.
- Map weights from intake to finished goods with a single, consistent method.
- Align the HS/CN description with your importer before you submit.
- Submit a complete dossier to DJPT and plan 3–7 working days for validation.
Do these five and your 2026 EU shipments will feel refreshingly… boring. And in logistics, boring is a win.