Indicator 1.4.5: Restrictions on Selling Treated Crustaceans and Antimicrobial Products as ASC Certified

Overview of Indicator 1.4.5

Indicator 1.4.5 of the ASC Farm Standard Interpretation Manual establishes clear restrictions on which aquaculture products may be marketed and sold as ASC certified. The indicator sets two distinct prohibitions that apply at the point of sale or dispatch:

1. Crustaceans treated with antibiotics at the Unit of Certification (UoC) cannot be sold or dispatched as ASC certified.
2. Any product treated with antimicrobials listed as Critically Important Antimicrobials for Human Medicine by the World Health Organisation (WHO) cannot be sold or dispatched as ASC certified, regardless of the species or when the treatment occurred in the product's lifecycle.

These restrictions operate as a form of market labelling control, ensuring that consumers and buyers receive accurate certification status and that treated products do not enter certified supply chains under false representation.

Two Separate Prohibitions

Crustacean-Specific Antibiotic Restriction

The first restriction targets crustaceans (such as shrimp, prawns, crabs, and lobsters) that have been treated with antibiotics during the production phase at the UoC. This prohibition applies only to crustaceans and only to treatments applied at the farm itself. A crustacean that received antibiotic treatment upstream in the supply chain—for example, at a hatchery or earlier production facility—would still fall under the second, broader restriction if those antimicrobials are on the WHO Critically Important list.

WHO Critically Important Antimicrobials Restriction

The second restriction is broader in scope and applies to any aquaculture product—fish, crustaceans, bivalves, or abalone—that has been treated with antimicrobials classified by the WHO as Critically Important for Human Medicine. This restriction does not limit itself to treatments applied at the UoC; it captures treatments at any stage in the product's lifecycle, including prior to the farm receiving the stock. This means a farm must track whether incoming larvae, juveniles, or stock have been treated with such antimicrobials before arrival.

Practical Implementation: Record-Keeping and Process Controls

The Interpretation Manual guidance for Indicator 1.4.5 clarifies that farms must maintain detailed records of antibiotic treatments to ensure compliance. Specifically, the UoC should:

• Maintain detailed records of any antibiotic treatments applied prior to the UoC, including treatments at hatcheries or other upstream supply chain points.
• Implement a process to ensure that products falling under either restriction (1.4.5(a) or 1.4.5(b)) are not sold or dispatched as ASC certified.

This dual-layer approach—both documentation and process control—creates accountability. A farm cannot simply claim to be unaware of prior treatments; it must have systems in place to capture this information and prevent misclassification at the point of sale.

Connection to Supply Chain Requirements

Indicator 1.4.5 operates within the broader framework of traceability and supply chain requirements set out in Criterion 1.4 and Criterion 1.5. Under Indicator 1.4.2, all batches of ASC certified and non-certified product must be identifiable and segregated at all sites and at all times. Indicator 1.4.5 adds a specific filter: even if a batch meets all other ASC requirements, it cannot be labelled as ASC certified if it contains treated crustaceans or WHO-listed antimicrobials.

The ASC Stock Status Record, required under Indicator 1.5.2, must include information on treatments applied at any stage in the lifecycle. This record flows through the supply chain and provides the documentary evidence that farms rely on to determine whether incoming stock or product can legitimately be processed or sold as ASC certified.

What Auditors Examine

When auditing compliance with Indicator 1.4.5, auditors will:

• Review records of all antibiotic and antimicrobial treatments applied at the UoC, including the specific antimicrobials used and the species treated.
• Cross-reference ASC Stock Status Records for incoming stock to confirm whether prior treatments are documented.
• Verify that the UoC has a documented process to prevent products subject to the restriction from being sold or dispatched as ASC certified.
• Examine sales, dispatch, and labelling documentation to confirm that restricted products have not entered the certified product stream.
• Interview staff responsible for product classification and shipping to understand how they identify and segregate treated product.

Auditors will also confirm that the UoC has access to and correctly identifies the WHO list of Critically Important Antimicrobials for Human Medicine, as this is the authoritative source for the second restriction.

Distinction from Other Antimicrobial Requirements

Indicator 1.4.5 differs from other antimicrobial-related requirements in the standard. It is not a prohibition on the use of antimicrobials in therapy or treatment; rather, it is a prohibition on marketing as ASC certified any product that contains residues or history of such treatments. Other criteria, such as Criterion 4.4 (Veterinary therapeutants) and Criterion 4.5 (Parasite Management), govern when and how antimicrobials may be used. Indicator 1.4.5 is the market-facing control: it determines which treated products qualify for certification labelling.

Documentation Evidence

Farms must maintain the following evidence to demonstrate compliance:

• Records of all antibiotic treatments applied at the UoC, including dates, species, antimicrobials used, and batch/lot identification.
• Completed ASC Stock Status Records for all incoming stock, documenting prior treatments.
• A written process or procedure describing how the UoC identifies and segregates treated product and prevents it from being sold as ASC certified.
• Sales and dispatch documentation clearly identifying product as ASC certified or non-certified, with supporting batch records.

This article summarises ASC-INT-001-ASC-Farm-Standard-Interpretation-Manual-V1.0.1-September-2025.pdf. Refer to the original document for the authoritative text and full requirements.