How the Rainforest Alliance Supports EUDR Compliance from Farm to Retailer

Coffee and cocoa farm certificate holders can select specific criteria that align with EUDR requirements on the RACP and upload their geodata. Companies are encouraged to actively engage with their farm supplier base, asking farm Certificate Holders to ensure data collection and submission happens at pace. The Rainforest Alliance is also providing support on the ground toward this purpose.  

Companies are legally responsible for implementing the EUDR throughout their supply chain. And, while there is much alignment between the requirements of the Rainforest Alliance’s 2020 Sustainable Agriculture Standard and those of the EUDR, there are some small yet crucial differences between the two. Therefore, Rainforest Alliance Certified cocoa and coffee cannot be automatically considered to be EUDR-compliant. However, our certification program is equipped with a range of tools that can provide companies with the additional information needed for compliance (at no extra cost to our certified supply chain partners).

The Rainforest Alliance is communicating with farm Certificate Holders about what to expect with the self-selected EUDR criteria and has developed targeted training to that end. We are also working with our Associate Trainers Network (ATNs) and Certification Bodies to ensure they support farm Certificate Holders in implementation and auditing against the self-selected criteria.  

The Rainforest Alliance 2020 Sustainable Agriculture Standard (see Annex Chapter 6: Environment) currently makes allowance for “minor conversion” of land to agriculture use in two specific instances:  

1. Minor conversion that has already occurred after January 1, 2014. This must be limited to 1% of the total farm area (and for farm groups, the total land area of the entire group) or 10 hectares, whichever is smaller. In such instances, the farm Certificate Holder must put in place a restoration/compensation plan.  
2. Planned minor conversion for infrastructure essential for farm or processing operations. This must be limited to 1% of the total certified land area and must be pre-approved by the Rainforest Alliance.  

However, farm Certificate Holders selecting the EUDR criteria on RACP may no longer make use of the minor conversion allowed under point one above in cases where the conversion has taken place after December 31, 2020. 

We encourage companies to have a conversation with their suppliers as soon as possible to understand their ability to implement an Identity Preserved or Mixed Identity Preserved system, as the volumes of Rainforest Alliance Certified cocoa available for sourcing through these traceability levels is dependent on each company’s suppliers. All Rainforest Alliance Certified cocoa is purchased from farm Certificate Holders as Identity Preserved and then each actor in the supply chain chooses how to sell that cocoa forward.   

The Rainforest Alliance Certification Program uses a combination of satellite mapping technology and field-based, third-party audits to assess risks and instances of deforestation.  
 
Farm Certificate Holders provide geodata during the certification registration process that is used as the input for a deforestation risk assessment. The results of this assessment are shared with the farm Certificate Holder and the Certification Body that will perform the audit. When auditing a farm group, the auditor must create a sample of farm members to visit based on the deforestation risk assessment. The auditor then visits the farms (including those that have been identified as “high-risk”) to identify any instances of deforestation after January 1, 2014. You can read more about this process and our tools to promote deforestation-free supply chains.   

The Rainforest Alliance has proprietary forest-layer data sets for Peru, Brazil, Ghana, Côte d’Ivoire and Indonesia, and uses Copernicus forest layers for other countries, mapped against Global Forest Watch maps for tree cover loss. We use proprietary AI remote sensing forest data alongside other publicly available and government data sources to map deforestation risks. The combination of traceability, proprietary AI forest mapping, and auditing offers a unique solution to coffee and cocoa companies.

All farm Certificate Holders are required to use the deforestation risk assessment during the certification process.  

In the Rainforest Alliance certification process it is the responsibility of farm Certificate Holders to collect and submit their geodata. However, this does not mean it is necessarily the sole responsibility of farmers to pay for this data collection. The Rainforest Alliance strongly encourages companies buying from coffee and cocoa certificate holders to support this geodata collection, financially or otherwise—especially considering that EUDR compliance is the responsibility of companies placing goods on the market in the EU or exporting from the EU. 

For our supply chain partners, there will be no additional charge from the Rainforest Alliance for companies who choose to access this EUDR offering through certification.  

The deforestation and encroachment risk assessments are based on satellite imagery. They are intended to provide an assessment of deforestation and deforestation risk, rather than definitive evidence of deforestation or non-deforestation. For Rainforest Alliance Certified cocoa, further investigation through the assurance process allows for context to be taken into consideration. As part of the Rainforest Alliance process, farm Certificate Holders have the option of removing high-risk farms from their certification scope or visiting high-risk farms to collect the necessary proof that there was no deforestation on these farms. This is part of the internal management process for farm group certification.  
 
The Rainforest Alliance will continue to refine risk assessment results through improvements, such as the progressive requirement on polygon mapping, and continually updating the maps used for risk assessments as new information becomes available. We will also continue to improve assurance measures for our certification program. These improvements should result in fewer false positives and fewer farmers unable to access certification.  

Companies will be able to access data related to their supply chain in line with what is provided in MultiTrace. If retailers would like to take advantage of this offering, they will need to go through the Rainforest Alliance supply chain certification process and participate in traceability in MultiTrace. 

Retailers should work with their suppliers to identify the farm Certificate Holders that are in their supply chains.  

The EUDR requires products to be produced in accordance with local laws, including not only applicable deforestation laws, but also human rights, labor rights laws, and other relevant legislation.  

The legal and legitimate right to use the land is included in the Rainforest Alliance’s 2020 Sustainable Agriculture Standard requirements (See Chapter 5: Social, requirements 5.8.1 and 5.8.2). Although auditors are required to check official or legal documents, in many countries, there is no documentation that can be considered proof. Hence, the Auditor Verification Protocol (a guidance for auditors on how to check compliance for each requirement) provides the possibility to check “the absence of disputes” over the land. 

As established in the Rainforest Alliance 2020 Sustainable Agriculture Standard, all farm Certificate Holders must comply with applicable laws and collective bargaining agreements (CBA) within the scope of the standard. In the case that an applicable law or CBA is stricter than a requirement in the standard, such law or CBA will prevail unless such law has become obsolete. In the case that an applicable law or CBA is less strict than a requirement in the standard, the requirement in the standard will prevail, unless the requirement explicitly allows for such law or CBA to apply (See Chapter 1: Management). 

All Certification Bodies (CBs) that conduct audits for the Rainforest Alliance in specific countries must undertake an Applicable Law Assessment for each of these countries, to identify applicable laws corresponding to each requirement of the standard. The Applicable Law Assessment is updated annually by the CB and sent to the Rainforest Alliance. The CB has to make this Applicable Law Assessment accessible to their auditors so that they can verify the conformity of Certificate Holders with these laws. 

The self-selected criteria will require farm Certificate Holders to collect geolocation data for all   cocoa and coffee farm plots, with polygons for plots above 4 hectares. All geodata will need to include 6 decimal digits, rather than the 4 currently required by Rainforest Alliance certification.

This data is collected through the Rainforest Alliance certification process and is owned by the certified producers. Supply chain Certificate Holders will agree to limit the use of this data for EUDR purposes only.  

When geodata aligned with the EUDR self-selected criteria is submitted through the certification process, the Rainforest Alliance will check the quality of the data. After that, the self-selected criteria will be included in the third-party farm certification and surveillance audits conducted by Certification Bodies, meaning that the auditor will check a sample of farms to assure the data submitted by the farm Certificate Holder is complete.  

The Rainforest Alliance provides the platform and access to key data for our market partners to fulfil their obligations under the EUDR. The Rainforest Alliance is not enabled to issue due diligence statements.