In relation to its consultation document Registration of Sellers and Buyers of First Sale Fish, why a registration system is necessary; wha…

EU legislation (Council Regulation 2847/93) envisages that auction centres or other bodies or persons responsible for the first marketing of fishery products and therefore, the submission of sales notes to the control authorities shall be authorised by member states. The proposed system of designated auction centres and registered sellers currently under consultation with industry has been designed to allow the UK to comply with that provision with little or no change to current practice. The registration of buyers of first sale fish is not yet a requirement of EU legislation, although Regulation 2847/93 places responsibility for submission of the sales note on the buyer in circumstances where first marketing takes place other than through an authorised auction centre or other seller. The registration of buyers of fish is also proposed as part of the review of the CFP. It seems sensible, therefore, to propose also the registration of buyers, in anticipation of possible EC requirements; to ensure buyers of fish who may be responsible for submission of sales notes can be identified, and as a logical extension of traceability and control arrangements.The Fisheries Departments view the registration processes as simple and straightforward and unlikely to result in any additional costs to industry. Consultation and discussions continue with industry on detailed implementation arrangements, on which decisions remain to be taken.