A zero-rejection, step-by-step guide for Indonesian processors on when and how to prepare a compliant processing statement for UK IUU imports. Practical tips on mixed lots, yield reconciliation, storage documents, and KKP validation.
If you export Indonesian seafood to the UK, the IUU processing statement is the one document that quietly makes or breaks your clearance. We have seen great products stuck at Port Health for days because a single line was missing, or a yield did not add up. This guide focuses on exactly when you need the processing statement, how to complete it without rejection, and how to handle mixed-lot and storage scenarios in 2026.
What the UK actually wants to see
The UK IUU regime mirrors the logic of the old EU system but is now administered by UK Port Health. Importers must show legal catch and clean traceability from vessel to border. That means:
- Catch Certificate(s) from the flag State of the fishing vessel.
- Processing Statement if processing occurred in a non-flag State. Indonesia counts here when we process imported or locally caught fish, unless the Indonesian flag catch certificate already covers straight landings and no further transformation took place.
- Storage Document if the product was only stored and not processed in a non-flag State before UK import.
In practice, Port Health wants a clear story. Which vessels caught the fish. Which factory processed it. What came in, what went out, and when. If the numbers tie together and the competent authorities sign off, you are through.
When do you need a processing statement?
We get this question every week, especially for IQF and re-packed SKUs.
- Required: Any transformation that changes the product. Filleting, skinning, trimming, loining, saku, portioning, canning, breading, mixed-lot production, or glazing to a different net weight profile. For example, our Grouper Fillet (IQF), Yellowfin Saku (Sushi Grade), or Red Snapper Portion (WGGS / Fillet) shipments require a processing statement when produced from raw fish covered by catch certificates.
- Not required: Genuine storage only. The fish stayed sealed and unchanged in a cold store, then exported. In that case, submit a Storage Document instead of a processing statement.
- Repacking only: If you simply re-label a sealed inner pack into a master carton without opening or mixing lots, many UK ports accept a Storage Document rather than a processing statement. If you open cartons, change net weights, or co-mingle, treat it as processing.
Takeaway. If the product identity changed at all, prepare the processing statement. If the pack stayed sealed and untouched, prepare the Storage Document.
Who signs and stamps in Indonesia?
Indonesia’s competent authority is KKP. In our experience, validation is handled through BKIPM offices. The processor prepares the processing statement with full lot-level evidence. BKIPM reviews and stamps it. Keep copies of supporting documents because Port Health sometimes asks for them.
Typical proof KKP expects:
- Vessel-to-factory traceability: purchase invoices, landing or transhipment docs, logbooks or catch data, and transport notes.
- Production records: intake weights, yields, lot codes, by-product and waste records.
- For transhipments via Bitung or Benoa: transhipment declaration, port clearance, and temperature records.
Can one shipment with multiple catch certificates use a single processing statement?
Yes, you can use a single processing statement for a production lot that blends multiple vessels or certificates. List all catch certificate numbers, vessels, FAO areas, and the incoming weights from each. Then show the total processed output and the allocation to each SKU in the shipment. We do this routinely for items like Pinjalo Snapper One Cut or Wahoo Portion (IQF / IVP / IWP) where production draws from multiple landings.
If your shipment contains multiple unrelated production lots, using separate processing statements per lot is cleaner. The rule of thumb. One processing statement per logical production lot. One shipment can include multiple statements.
Yield reconciliation that UK Port Health will accept
Here is where most rejections happen. Your incoming weights from the catch certificates must reconcile to your finished goods plus by-products and loss. Keep it plausible and consistent with your SOPs.
Useful ranges we see accepted for common Indonesian exports:
- Tuna loins or saku from whole round: 48–62 percent depending on grade, skin-on/off, and trim.
- Skinless snapper fillet from WGGS: 38–52 percent.
- Grouper skinless fillet from WGGS: 40–55 percent.
- Portion cuts from trimmed fillet: 90–97 percent of the fillet weight, depending on sizing and edge trim.
These are reference bands, not legal limits. If your yield sits outside, explain it on the statement. For example, heavy bloodline trim for sashimi spec on Yellowfin Saku (Sushi Grade) reduces yield but raises quality. We add a short note and attach trim records. That avoids questions later.
Practical tip. Reconcile by lot, not by the month. Port Health wants to see the math for the exact lot shipped.
What if the fish was stored before processing?
Two scenarios matter:
- Stored in a third-party cold store in Indonesia, then processed by your plant. You only need the processing statement as long as your traceability covers the storage period. Keep the storage in-and-out receipts on file.
- Stored in another country with no processing, then imported to the UK. You need a Storage Document from that storage operator. If any processing occurred there, you need a processing statement from that country too.
We have seen UK rejects when a Storage Document was missing for a prior third-country stop, even if the goods were untouched. Ask your logistics team to map all legs.
Will the UK accept scans or do they require originals?
Most UK Port Health authorities accept clear scanned copies for documentary checks and pre-arrival review. The original, wet-stamped processing statement must exist and be kept by the importer for audit. Some ports still request the original on arrival for high-risk profiles. We scan in color at 300 dpi and keep the couriered originals with the clearance file.
How long does KKP validation take, and when should you apply?
Our average in 2025 has been 5–7 working days from complete submission to stamped document. During peak seasons or if vessels are mixed, allow 10–15 working days. Apply as soon as production is complete and you can freeze the inputs and outputs numbers. We target two weeks before vessel ETD so Port Health can pre-check without delaying clearance.
If you need a fast review of your draft before submitting to BKIPM, reach out and we will sanity check yields and lot mapping. If you are up against a cut-off, Contact us on whatsapp.
How to complete the processing statement step by step
We keep a simple checklist that aligns with UK expectations.
- Processor details: company name, address, approval number, and plant code.
- Product identity: commercial name, scientific name, presentation (WGGS, fillet skinless, loin, portion), and HS code.
- Processing dates: start and finish of the transformation window.
- Inputs: for each catch certificate list vessel name, flag, FAO area, gear type, CC number, intake date, and net weight received into the lot.
- Outputs: finished products, pack sizes, and net weights. Show by-products if retained for food use and waste if not.
- Yield reconciliation: opening balance plus intake equals outputs plus waste and closing balance.
- Lot codes: link your internal lot IDs to the shipment cartons.
- Statement of no mixing with unverified fish: a one-line declaration KKP is comfortable with.
- Signature and competent authority validation: signed by the processor’s responsible person, then validated by BKIPM with stamp and date.
Working example. A mixed-lot of Goldband Snapper Fillet and Goldband Snapper Portion drawn from three vessels. We show three CC numbers with intake weights, one total fillet lot yield, and an allocation table to each SKU. By-products like heads routed to Goldband Snapper Head are recorded too.
Common UK rejection reasons and how to avoid them
We keep a running list from Port Health feedback.
- Missing CC-to-lot link. The processing statement lists vessels but not the specific CC numbers used in that lot. Always include the CC numbers.
- Implausible yields. Saku yield at 80 percent or fillet yield at 20 percent will trigger queries. Anchor your yields with specs.
- Product mismatch. The statement says skin-on fillet while the invoice shows skinless portions. Align descriptions across all docs.
- No storage document for a third-country stop. Even if goods were unopened, Port Health wants proof of storage-only.
- No BKIPM stamp or signature on the final page. UK will not accept draft or unsigned statements.
- Dates out of sequence. Processing dates before catch date or after shipment date. Check chronology carefully.
Before we book a container, we perform a 10-minute “IUU scrub” against those points. It saves days at the border.
Quick answers to questions we hear most
Do I need a processing statement if my plant only repacked frozen fish?
If you did not open inner packs or mix lots, use a Storage Document. If you opened and re-configured packs or co-mingled, submit a processing statement.
Who signs and stamps the processing statement in Indonesia, and what proof is required?
Your plant signs. BKIPM under KKP validates and stamps after checking vessel-to-factory traceability and production records.
Can one shipment with multiple catch certificates use a single processing statement?
Yes for one production lot that blends multiple CCs. List each CC and weight. Use separate statements for unrelated lots within the same shipment if it is cleaner.
How do I reconcile weight differences between the catch certificate and finished product weights?
Show inputs, outputs, by-products, and losses by lot. Keep yields within plausible ranges and explain any exceptions. Attach trim or thaw-loss records if needed.
If the fish was kept in a third-party cold store before processing, do I also need a storage document?
Not if storage was in the same country as processing and you submit the processing statement. You do need a Storage Document if there was third-country storage with no processing.
Will UK authorities accept a scanned processing statement or do they require the original?
They accept clear scans for checks. The original wet-stamped version must exist and be produced on request. Some ports may ask for the original at arrival for certain profiles.
How long does it take to get a KKP-validated processing statement, and when should I apply?
Plan 5–7 working days, up to 10–15 in peak periods. Apply as soon as production is complete and at least two weeks before ETD.
2026 trend to watch
UK Port Health teams are pushing for cleaner, digital-ready submissions. We have seen faster clearances when statements clearly list all CC numbers, lot IDs, and a one-line yield summary on the first page. Keep your PDF searchable. Use consistent product names across the statement, invoice, and packing list.
If you are planning new UK lines based on Indonesian species like Snapper WGGS (Red Snapper - Whole Gilled & Gutted) or Mahi Mahi Portion (IQF), we can pre-map the IUU paperwork so your first shipment clears smoothly. Questions about your project timetable or document flow. Call us.
Bottom line. A processing statement is not hard when you tie vessels to lots and lots to cartons with believable yields. That is what Port Health looks for. Get those right and your UK entries become predictable.