A practical exporter-side walkthrough to compile a clean EU IUU catch certificate package for mixed lots, including Annex IV processing statements, optional re-export certificates, and the data checks your EU importer needs for CHED-P without rework.
If you’ve ever had an EU shipment stuck because the IUU documentation didn’t line up, you know the pain. We’ve been in that queue. A few years ago, one mixed-lot container of snapper fillets cost us two weeks while customs asked for “clarification.” We built a system after that. Since then, our mixed-vessel shipments for products like Grouper Fillet (IQF) and Yellowfin Saku (Sushi Grade) have cleared with zero rework.
This guide distills how we assemble EU IUU packages for mixed lots. It’s exporter-side. It’s practical. And it’s exactly what your EU importer needs to file a clean CHED-P.
The 3 pillars of a clean EU IUU package
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Evidence chain. Your package must tie each finished-product kilogram back to specific catch certificates. For mixed-vessel product, that means multiple EU IUU catch certificates and an Annex IV processing statement that aggregates them.
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Data alignment. Species scientific names, FAO areas, gear type, vessel IDs, and weights must match across documents. If you list “Epinephelus spp.” on a catch certificate, don’t switch to “mixed reef fish” on the Annex IV. Keep codes consistent.
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Quantity logic. The math has to work from raw to finished. The Annex IV should show input weights per catch certificate and finished weights per product SKU. If yields look unrealistic, expect questions.
Takeaway: If these three pillars hold, customs queries drop to near zero.
Weeks 1–2: Trace data gathering and validation (tools + templates)
Here’s what we set up before a single form is filled:
- Master intake log. Record per-lot raw material: species, vessel name/IMO, trip dates, FAO area, gear type, and weight. Map each lot to a factory batch ID.
- FAO area and gear code table. Use FAO area codes and FAO/standard gear terms (e.g., longline, gillnet). Align with what your authorities accept. Don’t invent synonyms.
- Vessel registry cross-check. Verify vessels are authorized and not on any IUU list on the catch dates. Nothing sinks a file faster than a flagged vessel.
- Yield matrix. Define typical yields by product form. For example, skinless fillet yield for snapper vs. loin vs. saku. This helps you reconcile raw to finished weight on the Annex IV.
What’s interesting is that 80% of rejections we see trace back to sloppy intake records. Get this right and the rest is a lot easier.
Weeks 3–6: Compile forms and pre-validate
The package flow for mixed lots looks like this:
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EU IUU catch certificates (per raw-material lot). Each certificate is issued and validated by the flag-state competent authority. If you sourced raw grouper from three Indonesian vessels, you’ll have three certificates.
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Annex IV processing statement. Your processing establishment completes this when the shipment includes processed product or mixed catches. It aggregates the catch certificates and shows how much of each went into the finished SKUs. It’s then validated by the competent authority where processing took place.
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Optional EU re-export certificate. Use this if your factory used imported raw material that already had its own EU catch certificate from another country and you further processed it before exporting to the EU. This certificate references the original catch certificates and your Annex IV.
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Health certificate and CHED-P. Different document, different purpose. The health certificate covers sanitary conditions. Your EU importer uses your IUU package to file CHED-P in TRACES NT. They will need document numbers, weights, species, and vessel details to match your IUU set.
Pre-validation checklist we run every time:
- Species and scientific names match everywhere.
- FAO area codes and gear types are identical across docs.
- Vessel identifiers (name/IMO/call sign) are consistent.
- Input vs. output weights make sense using your yield matrix.
- Batch IDs on packing lists link to catch certificates on the Annex IV.
Need a second set of eyes on a complex mixed-lot mapping? We’re happy to review a draft Annex IV and weight reconciliation. If that’s helpful, Contact us on whatsapp.
Weeks 7–12: Scale and optimize
Once your first few containers clear smoothly, lock in the process:
- Supplier SOPs. Provide your suppliers a one-page intake spec: what vessel data and documents must arrive with each lot.
- Digital document control. Keep a single source of truth for CC numbers, Annex IV versions, and batch mappings. Version control matters when customs asks for “the signed copy you shipped with.”
- Early validation. In our experience, competent authorities validate in 3–10 working days. Build that into your production plan and aim to have the complete IUU pack signed before loading.
- EU CATCH platform. Several EU member states have expanded use of the CATCH system in the last few months. Your importer may ask you to supply structured data or upload PDFs in advance. Agree the workflow before you book space.
Takeaway: The more you systematize, the less you firefight.
The 5 biggest mistakes that kill mixed-lot IUU files
- Mismatched weights. Annex IV finished weights exceed raw material from the listed catch certificates, or yields are unrealistic. Avoid this with a yield matrix and a simple spreadsheet that rolls up input vs. output.
- Missing or inconsistent FAO areas or gear. If your catch is Lethrinus spp. from FAO 57 with longline gear, say that consistently on all forms.
- Combining species incorrectly. Don’t use one catch certificate to cover multiple species. Each species must be clearly identified and traceable.
- Using the wrong signatory. Only the competent authority can validate the catch certificate and Annex IV. Factory managers can sign the operator section, but you still need the CA validation.
- Re-export confusion. If you processed imported raw material, you can’t skip the EU re-export certificate. Customs notices.
Takeaway: Build one pre-shipment audit to catch these five points.
Practical Q&A from buyers and importers
Do I need one EU catch certificate per container or per raw-material lot?
Per raw-material lot. The catch certificate belongs to the catch event and flag state, not your container. A single container can carry product covered by multiple certificates. Your Annex IV links them to the finished goods in that container.
Who completes and signs the Annex IV processing statement for mixed-vessel product?
Your processing establishment completes it with lot-level inputs and finished outputs. The competent authority in the country of processing then validates it. In Indonesia, we coordinate this as part of our export file so the signed Annex IV accompanies the shipment.
Can I combine multiple vessels under one shipment, and how do I show quantities from each?
Yes. List each catch certificate on the Annex IV with the input weight used from that certificate. Then show the resulting finished weights by SKU/batch. Example: A 19,800 kg shipment of Grouper Fillet (IQF) might use 8,000 kg from CC-001, 7,000 kg from CC-002, and 6,000 kg from CC-003 (raw equivalent), yielding 19,800 kg finished after trimming and glazing. The math must reconcile.
When do I need an EU re-export certificate for processed seafood?
When your factory processed raw material that was originally caught under another country’s flag and already had an EU catch certificate from that country. The re-export certificate references those original certificates and your Annex IV. If all raw material was caught by Indonesian vessels and processed in Indonesia, you won’t need a re-export certificate for the EU.
How do I link factory batch numbers to specific catch certificates so customs can trace them?
Use a batch mapping sheet that sits behind the Annex IV. For each finished batch code on your packing list, list the contributing catch certificate numbers and the exact weight taken from each. Many importers will request this mapping to support their CHED-P and internal audits. We attach it as an appendix to the Annex IV.
How should gear type and FAO area be listed when the shipment contains multiple sources?
List them per catch certificate. Don’t try to “average” or generalize on the Annex IV. If one certificate is FAO 57 longline and another is FAO 71 handline, they are presented separately with their correct gear and area. Your product labels don’t need to show this, but your IUU docs must.
What are the most common reasons EU catch certificates get rejected?
We see three: input-output weight mismatches, incorrect or missing vessel identifiers, and species inconsistency between certificates and Annex IV. A close fourth is using scans that are illegible or unsigned. Send clear, signed PDFs and keep the originals accessible.
Where this advice applies (and where it doesn’t)
This walkthrough is for EU IUU documentation under Regulation 1005/2008 for wild-caught seafood. It covers mixed-lot shipments and processing scenarios where you need the Annex IV and occasionally a re-export certificate. It doesn’t cover U.S. SIMP, eco-label claims, or your sanitary health certificate. Different rules, different paperwork.
Resources and next steps
If you’re building a program around high-spec products like Pinjalo Fillet (IQF) or Swordfish Steak (IQF), get your IUU package flow right from day one. Agree templates with your importer, test your yield matrix on a pilot batch, and pre-validate with your competent authority before you scale. Questions about a live file or CHED-P data alignment? Contact us on email. If you need product specifications aligned with EU documentation from the start, you can also View our products.
What’s the real secret? Keep it boring. When your EU IUU package looks the same every time, customs moves your containers faster. And that’s the goal, right?