Guidance

Sales notes – Completion and submission

Updated 2 July 2025

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. Responsibilities of the master of a UK vessel when catches are sold first sale outside of the UK

Please note: Countries outside of the United Kingdom are considered a ‘Third Country’, this includes European Union (EU) states.

2.1 Where catches are landed and sold first sale in a third country

As the master of a UK registered vessel landing into a third country and selling those catches of first sale fish to a non-UK merchant or market you or your representative must:

• Provide copies of sales notes for these catches to the relevant UK fishing authority. For English vessels, this would be the MMO.

• These must be submited within 48hrs of the first sale of the landed catch.

You will need ensure that any applicable requirements for the labelling, weighing and traceability of fish for the landing and destination countries are complied with.

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

For traceability, weighing and transporting requirements when landing in third countries, masters or representatives should familiarise themselves with the guidance from the relevant third country.

2.2 Where catches are landed in the UK and transported to a third country for first sale

As the master of a UK registered vessel landing within the UK and selling those catches of first sale fish to a non-UK merchant or market you, or your representative, are asked to submit, if possible:

• Copies of sales notes for these catches to the relevant UK fishing authority. For English vessels, this would be the MMO.

• These copies to be provided within 48hrs of the first sale of the landed catch if possible.

You will also need to ensure that any applicable requirements of the landing and destination countries for the labelling, weighing and traceability of fish are complied with prior to catch being loaded and transported for first sale of the catch.

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

For traceability, weighing and transporting requirements when landing in the UK and the first sale takes place in third countries, masters or representatives should check the relevant third countries’ guidance.

3.  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. The next sections detail what should be recorded in a sales note, as well as why the accuracy of the information provided is important.

3.1 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.

It is essential that data entered is accurate as recording  incorrect vessel details means traceability is lost at the first stage. It may also mean a vessel is incorrectly identified for non-compliance e.g. for failing to submit a catch record, which could result in enforcement action.

• The port of landing. This is the port where the vessel landed the catches and may not be the same as where you buy or sell the fish.  Providing the correct port of landing allows us to follow traceability of catches from landing to point of sale.

• The date of landing. This is the date the vessel landed and may not be the same as when you buy or sell the catch.

Where catches are from separate trips and landed on different days, you must record accurate, individual landing dates. For example:

Vessel VS123 undertakes 3 fishing trips and lands fish on 3 separate days.

1. Landing 1 - Friday 02/05/2025,
2. Landing 2 – Saturday 03/05/2025,
3. Landing 3 – Sunday 04/05/2025.

A separate sales notes should be submitted for each of these 3 landings, each correctly reflecting the date that catch was landed. These catches should not be grouped together on a sales note with a single date of landing declared.

Ensuring accurate date of landing information is captured allows vessels to correctly complete landing declarations for each trip and is crucial for exports and Catch Certificates.

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

3.2  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. The date of sale recorded should be the date the sale took place.

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

3.3  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.

Where there is a specific species code, that is what should be recorded rather than a generic code. For example, use RJC to record Thornback Ray not SRX or SKA (all ‘skate and rays’).  With the introduction of Fisheries Management Plans (FMPs), accurate recording of species which may have previously been recorded under a generic code is important. For instance, correct recording of the two different octopus species found in our waters.

• 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.

• 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. See our guidance on Processing, presentation and marketing information for fish - GOV.UK.

• 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.

4. 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.

4.1  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 £175,000 or more in first-sale fish then you must provide the information electronically.

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

4.2  Electronic sales notes

If you or your business has an annual turnover of £175,000 or more 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. salesnote.live@fishhub.net (You can use this to submit a file containing multiple sales notes).

Before using the ERS you must register, please see section 6. If you want to discuss the best method of electronic submission, then please contact your local MMO coastal office.

4.3 Sales Notes relating to first sale in a third country

Sales notes submitted in accordance with the guidance for when the first sale takes place in a third country (Section 2) must be submitted within 48hrs of first sale to the vessels fishing authority. In the case of English vessels this is the MMO.

These sales notes should be submitted, if possible, electronically, to the landing vessels registered admin port.

5.  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. When submitting sales notes for undersize fish on the electronic reporting system (ERS), you must state freshness as “SO” and then presentation “BMS”.

More information on the landing obligation can be found on the MMO website

6.  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
Lutra House
Dodd Way
Walton Summit
Preston
PR5 8BX

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

7.  Contact details

Email: registrationof.buyersandsellersrbs@defra.gov.uk

8. Relevant 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.

The Registration of Fish Buyers and Sellers and Designation of Fish Auction Sites Regulations 2005