11 Seafood tracing As originally drafted for the Draft Assessment Report, the Clause covered traceability and recall of unsafe seafood. One submission noted that the imposition of a written document places impost on businesses in situations where it might be difficult or impossible to contact sellers. Further, it was noted that it might be, for example in the case of fisherman, not possible for them to initiate recall. The submission made the recommendation to remove reference to ‘recall of unsafe or unsuitable seafood’. In subsequent discussions with the SDC and DFAT, it was noted that there are issues with the use of the term ‘traceability’, which has a distinct meaning in the international Codex arena. It was suggested to use alternatives terms to traceability in the drafting.
The Clause has been amended to limit it to seafood tracing and not recall. A seafood business will be required to maintain records to identify the immediate supplier and immediate recipient of seafood. The keeping of receipts will be adequate to satisfy the requirements for written records.