Sales notes – Completion and submission

Updated 28 December 2023

1. Responsibilities of a registered buyer or seller

As a registered buyer or seller of fish you must

  • Ensure fish is weighed prior to first sale and appropriate records maintained
  • Keep a record of each sale of fish for three years
  • Make records available for inspection at the notified location
  • Complete and submit a sales note for each transaction
  • Submit sales notes electronically (e-Sales) if required

You will also need to comply with requirements for the transport, weighing and traceability of fish.

See guidance on traceability, weighing and transporting for more information.

Your premises and records may be inspected by a Marine Enforcement Officer (MEO) or British Sea Fishery Officer (BSFO) to assess compliance with the regulations.

2. Information required on a sales note

As a registered buyer or seller you must submit information on each sale in the form of a sales note.

It is your responsibility as the buyer or seller to ensure the information is accurate.

2.1 Details of the vessel

You must record:

The name and port letters and numbers (PLN) of the vessel that has landed the fish. You can find details of licensed UK and foreign vessels on the vessel register.

The port and date of landing. This is port and date that the vessel landed and may not be the same as where/when you buy or sell the fish.

The name of the fishing vessel’s master or owner.

2.2 Details of the sale

You must record:

  • the name of the buyer and their registration number

You only need to record this if you are selling fish on an auction market. You can find details of all registered buyers and sellers in the UK on the buyers/sellers register.

  • the place and the date of the sale
  • Invoice or sales contract reference

You only need to provide this if you have a reference number and date of invoice or sales contract.

  • take over declaration and transport document details

If you buy or sell first sale fish that has previously been ‘taken over’ (held in storage prior to first sale for example), or has been transported from the place of landing to the place of sale, then you must include a reference to the take-over declaration or the transport document.

2.3 Details of the fish

You must record:

  • the three letter (FAO Alpha-3 code)species code(s)

A list of common species codes can be found on the MMO website.

You must use the species specific code not a generic code. For example, use RJC to record Thornback Ray not SRX (all ‘skate and rays’).

  • the area where the fish was caught

This is the relevant International Council for the Exploitation of the Seas (ICES) division or sub-division where the vessel caught the fish. A map of these areas can be found on the Europa website. A full list of the ICES areas around the UK is available.

  • the quantities of each species by presentation type and state

The weight of each species must be recorded in kilograms (kg). The only exception to this is when regulations require you to record the number of individual fish.

If you buy or sell quantities of fish in different forms, such as Cod fillets and whole Cod, you must record each presentation type and state separately. The presentation type is how the fish has been processed.

The presentation state is how the fish is treated, for example whether it is fresh, frozen or salted.

  • the marketing standards information

If you buy or sell fish that is subject to marketing standards, you must indicate how the fish has been sorted and graded according to size and freshness.

  • the price of each species sold, and where necessary, the price of the grade of that species

This should be the price in the currency of the transaction.

  • destination of withdrawn fish

If you are a producer organisation (PO) and you offer fish for first sale that is subsequently withdrawn from the market, you must state the storage destination.

  • quantities and destination of fish below the minimum conservation reference size

This must be recorded in kilograms (kg) net weight.

3. Submission of sales notes

You can submit a sales note either as a paper document (paper sales note) or electronically (eSales). The same information is required for both types of submission.

3.1 Paper sales notes

Paper sales notes must be submitted within 48 hours after the sale has taken place.

You should submit them to your local MMO coastal office.

Templates for buyers’ and sellers’ paper sales notes are available on the MMO website

If you or your business has an annual turnover of more than £175,000 in first-sale fish then you must provide the information electronically.

It is recommended that you submit sales notes electronically irrespective of your turnover.

3.2 Electronic sales notes

If you or your business has an annual turnover of more than £175,000 in first-sale fish then you must submit an electronic sales note within 24 hours of completion of the sale.

The UK Electronic Reporting System (ERS) allows you to submit sales notes electronically using one of the following methods:

  1. Direct data entry via the ERS website. (Suitable if you purchase small quantities of fish).
  2. Via Comma Separated Variable (CSV) file emailed to the ERS hub. (You can use this to submit a file containing multiple sales notes).
  3. Via an Application Programmable Interface (API) (This provides access to the ERS web service and enables you to download sales notes from your existing database.An API developer’s pack is available on the ERS website).
  4. Via a predefined template supplied by the UK Fisheries Authorities (‘Option 5’).(As a buyer you can use this spreadsheet template to submit a single sales note or multiple sales notes.

Before using the ERS you must register, please see section 5. If you want to discuss the best method of electronic submission then please contact your local MMO coastal office.

4. Fish subject to the Landing Obligation

The buyer or seller must provide a sales note for any sale or transfer of undersize fish regardless of the quantity involved. The sales note must include:

  • an accurate weight of the total amount of undersize fish by species
  • the catching vessel details

You can transport undersize fish unsorted by species if they’re separated from fish above minimum size. The electronic reporting system (ERS) for sales notes doesn’t allow records to be designated as ‘undersize’. You must use Fish State “Dried” when you submit sales notes for undersize fish. More information on the landing obligation can be found on the MMO website

5. Register for ERS

You can register to access the Electronic Reporting System (ERS) for the submission of electronic sale notes (eSales). You can either complete Section D of the RBS1 form when you first register as a buyer or seller or, if you are already a registered buyer/seller, sign up at any time using the form RBS5. Registration is free.

Send your completed application form to:

Registration of Buyers and Sellers
The Fish Quay
Sutton Harbour
United Kingdom

Once your application has been processed you will receive login details for the secure ERS site.

6. Contact details

Registration of Buyers and Sellers Scheme
Marine Management Organisation
Lancaster House
Hampshire Court

Telephone: 0300 123 1032


7. Further information

7.1 European Regulations

Control Regulation Council Regulation (EC) No. 1224/2009 establishing a Community control system for ensuring compliance with the rules of the common fisheries policy.

Control Implementing Regulation Commission Implementing Regulation (EU) No. 404/2011 laying down detailed rules for the implementation of Council Regulation (EC) 1224/2009.

Common Organisation of the Markets (CMO) Regulation Regulation (EU) No.1379/2013 of the European Parliament and of the Council on the common organisation of the markets in fishery and aquaculture products. Marketing Regulation Council Regulation (EC) No. 2406/96 laying down common marketing standards for certain fishery products.

7.2 UK Regulations

Registered Buyers and Sellers Regulation The Registration of Fish Buyers and Sellers and Designation of Fish Auction Sites Regulations 2005 (as amended).