This Q&A has been developed to provide guidance to certificate holders and certification bodies with regards to the Measures to Strengthen the Cocoa Sector.
This Q&A makes reference to requirements in the Policy For Farm And Chain Of Custody Certification In Cocoa In West Africa published in April 2020.
More information on the Audit Allocation system can be found here.
For questions about the use of the new Rainforest Alliance certification seal on cocoa products, please visit FAQ: New Rainforest Alliance Certification Seal.
Pause on new groups joining Rainforest Alliance and UTZ certification programs
Why has the pause been continued in Côte d’Ivoire and Ghana?
We have seen improvements following the first phase of the Cocoa Assurance Plan. GPS data quality and coverage are improving, and we have seen a clear decrease in the number of certified groups where producers were identified in protected areas in Côte d’Ivoire.
However, we need further data, including verification of available GPS and polygon information, improved first mile traceability and improvements in Certification Body (CB) quality to maintain and strengthen transparency in our certified supply chains. For this reason, we believe that we need to extend the pause through this year’s harvest to focus on the quality of implementation with existing certified groups, after which we will assess progress and make a decision on the lift of the pause.
And why was it extended to Nigeria and Cameroon?
Many of the risks to certified cocoa supply chains are not confined to Côte d’Ivoire and Ghana alone. For this reason, we are extending the coverage of certain aspects of our Cocoa Assurance Plan to include Cameroon and Nigeria, to strengthen and improve the assurance of our program across West and Central Africa. This includes a pause on new groups joining the program. It also includes the requirement for certified groups to increase the coverage of GPS points (to 50% for those with no or little coverage and to 100% for those who already have more than 50% coverage). CB monitoring will also be strengthened in Nigeria and Cameroon.
When will the pause in Nigeria and Cameroon come into effect?
The pause in Nigeria and Cameroon came into effect as of February 1st, 2020 (date at which the Measures to Strengthen the Cocoa Sector were published on the Rainforest Alliance website). Only groups which (1) signed a contract with a CB prior to 1 February 2020, (2) scheduled an audit date prior to 1 February 2020, and (3) have complied with the GPS requirements, may conduct their audit as planned to join the certification program in 2020. Please be aware, however, that the Audit Exception Policy For COVID 19 also applies which clearly states that no new groups can be certified without an in-person audit.
When will the pause be lifted?
The decision to lift the pause on new groups will be taken by Rainforest Alliance based on an assessment of the progress made in achieving the objectives of these enhanced measures. For this reason, it is not possible for Rainforest Alliance to say when the pause will be lifted. Progress will be regularly reviewed to determine when a decision to lift the pause can be taken. All stakeholders will then be informed accordingly.
For new groups which already have 100% GPS requirements and for which Group Management has already signed contracts with the producers, can they join the certification program?
For Côte d’Ivoire and Ghana, new groups cannot join either of the two certification programs, even if the GPS requirements are met and contracts have been signed because the pause on new groups has been in effect since April 2019.
For Nigeria and Cameroon, only groups which met the GPS requirements and signed the contract for the certification audit before 1 February 2020, when the pause became effective in these two countries, can be certified.
Can groups which were certified in the past but that did not have an active certificate for some time (because they chose not to renew it or were non-certified or suspended) join the certification program again?
Groups which were certified in the past and whose latest active license expired before January 1st, 2019 (time extensions excluded) cannot join again either of the two certification programs.
Groups whose latest active certificate expired after January 1st, 2019 (time extensions excluded) are allowed to rejoin the same certification program. UTZ groups eligible to rejoin the program can choose whether to start their certification for the April or October 2020 certification year, as per the Protocol audit timeframe.
However, if the group did not have an active certificate because of a negative certification decision, the group must wait one full harvest period before they can be recertified, in conformity with the rules set out in the Policy for Cocoa Certification in West Africa.
Time extensions for the conduct of in-person audits and additional volumes granted under the COVID Policy only apply to groups with an existing active license/certificate.
Can we allow groups that are currently certified to restructure into new certified groups under the pause?
Existing certified groups are allowed to split into several groups to facilitate their management or comply with national governmental laws. Nonetheless, the 10% limit on the increase in group size (see below) still applies. The total number of group members of all the separate groups resulting from the division cannot be more than 10% higher than the total number of group members of the original group which was split up.
E.g.: Group A has a total of 1000 group members and wants to split to have three groups (Group B, Group C and Group D). The sum of the number of group members in groups B, C and D combined cannot exceed 1100, i.e. 10% more than the original size of Group A (1000)
What is the justification for the Rainforest Alliance to limit the growth of existing certified producer groups, allowing only 10% growth for Côte d'Ivoire and Ghana?
Rainforest Alliance is aware that in some cases, attempts have been made to avoid the restriction on new groups joining the UTZ and Rainforest Alliance programs by adding large numbers of new producers to existing groups. Unrestrained growth in group size makes it difficult for group management to collect all the required data for all group members, put in place adequate internal management systems, and ensure that new producers receive the appropriate training to be able to meet the necessary level of compliance against the requirements of the standards. Rainforest Alliance has therefore placed a limitation on the growth of groups, which takes account of the fact that membership of groups is dynamic, but prevents levels of growth that can undermine a group’s compliance with certification requirements and improvements in sustainability performance.
Why does the ban of growth in group size not apply in Cameroon and Nigeria?
Rainforest Alliance made the decision to extend the limited set of strengthened assurance measures in Cameroon and Nigeria in 2020 to give certificate holders in these countries time to first comply with the core set of measures. This is the same approach that was taken in Côte d’Ivoire and Ghana in 2019.
What does 10% growth limit in the number of group members entail and when will it be made applicable?
The 10% growth limit in the number of group members means that a group can only add a maximum of 10% additional members in total over the whole certification year (during the certification audit and/or the extension audit) compared to the total number of certified producers in the previous certification year.
This means if a group has 100 members in the 2019-20 certification year, it can have a maximum of 110 members in the 2020-2021 certification year. If a group has excluded members between their 2019 audit and their 2020 audit, the equivalent number of group members can be replaced and an additional 10% can also be added. E.g.: If a group with 1000 group members in 2019 excluded 200 members, in 2020 the group can replace those 200 producers and add an additional 100 members (10%). The 300 new producers added to the group must nonetheless comply with the 100% GPS requirement and comply with the same compliance year (UTZ certification) or performance level (Rainforest Alliance certification) as the existing group members.
If a group already added 10% of new members during the annual 2020 recertification or surveillance audit, the group is not allowed to add any more producers throughout the period covered by the certificate.
The limitation on 10% growth in group size is applicable to all UTZ groups whose upcoming certificate starts on June 1st, 2020 and beyond (time extensions excluded), and to all Rainforest Alliance groups whose re-certification or surveillance audit take place on June 1st, 2019 and beyond. This measure only affects cocoa producing groups in Côte d’Ivoire and Ghana.
This measure will be verified by Rainforest Alliance during the audit application process of the group and confirmed by the CB during the audit.
If a group had excluded group members two years ago and now wishes to allow them to rejoin the group, are these producers considered new members?
Any group members who were not included in the total number of certified producers in the previous certification year are considered to be new members. Therefore, the group can only allow former members to rejoin the group as part of the permitted 10% increase in the total number of group members.
For a group with producers in different villages, can they increase by 10% in each village?
Yes. This is possible provided that the overall membership of the group does not increase by more than 10% in total. If a group increases the number of producers in village A by10% compared to the number in that village the previous year, and also increases the number of producers in village B by 10% compared to the numbers in that village the previous year, the total increase in the number of producers in villages A and B would still be 10%. Therefore, it is allowed.
Can new group members have a lower level of compliance against the standard than members who have been in the group for some time?
No, all new group members must comply with the same compliance year or performance level as other existing group members. This means that if a group is in year 3 in the UTZ Code of Conduct, new members of the group must also be in compliance with control points for year 3. For Rainforest Alliance, if the group is implementing continuous improvement criteria in a specific area at performance level B, new group members must also be compliant against performance level B requirements.
Ban on Dual Certification
Why is Rainforest Alliance banning groups from holding both Rainforest Alliance and UTZ certification before the new Standard comes into effect in 2021?
Where groups hold both certifications, it is difficult for Rainforest Alliance to accurately track transactions of certified volumes sold under the different labels by the same group. To eliminate the risk that the same volumes could potentially be counted twice Rainforest Alliance will no longer accept groups holding both Rainforest Alliance and UTZ certification.
How will the ban on dual certification work for groups?
Groups which are currently dual certified Rainforest Alliance and UTZ must chose only one of these certifications and cancel the other. Certificate Holders must inform the Rainforest Alliance by 1 June 2020 which certification program they wish to be certified against. Once the group selects a preferred certification, the other certificate will be cancelled.
Groups may still hold additional certification such as Fairtrade if they wish.
The Rainforest Alliance encourages dual certified groups with certificates from either program expiring before June 2020 to decide which program they want to continue with before renewing their certificate to avoid unnecessary audit costs.
Can a group divide into separate smaller groups to keep both UTZ and Rainforest Alliance certification?
Yes, it is possible for one group that is dual Rainforest Alliance and UTZ certified to split into two groups – one which is UTZ certified and one which is Rainforest Alliance certified. However, the membership of each group must be separate. No group members may belong to both groups. Each group must also have a functional internal management system and comply with all the requirements of the relevant standard and all the requirements of the Cocoa Policy.
Is it possible for producers that have selected either UTZ or Rainforest Alliance certification to still sell product as certified under either program until 2021?
No, this is not possible. Producer groups certified against the Rainforest Alliance standard may only sell volumes as Rainforest Alliance certified in 2020 and those certified against the UTZ standard may only sell volumes as UTZ certified in 2020. Nonetheless, first buyers still have the option to be dual certified Rainforest Alliance and UTZ, and can get mutual recognition for their audits, giving them the possibility to buy both UTZ and Rainforest Alliance certified cocoa.
For groups that are currently certified UTZ, is it possible to switch to become Rainforest Alliance certified instead? (and vice-versa)
No, it is not possible for a group currently certified with UTZ to decide to be certified with Rainforest Alliance or vice versa, as this would effectively constitute a new group entering the newly chosen certification system which is not allowed. From 2021 UTZ and Rainforest Alliance groups will all have to apply the new common Rainforest Alliance standard so the distinction between UTZ certification and Rainforest Alliance certification will no longer apply.
100% of GPS points
What is the process for certificate holders to submit all their up-to-date group member registries (with 100% of the GPS coordinates) to RA?
Certificate Holders need to submit all their group members’ GPS coordinates to Rainforest Alliance before their audit for the 2020-2021 certification year. Guidance on how and by when to submit this data will be provided in the coming weeks.
In addition, Certificate holders will have to provide this data to their allocated CB before the audit is conducted.
Are there any groups that are exempted from the GPS requirements?
No, all groups and all group members have to comply with this measure in Côte d’Ivoire and Ghana.
Is the 100 % GPS point requirement applicable for all the plots of each group member, or only for one plot per member?
Currently, the Rainforest Alliance is asking for only one GPS point per certified group member, regardless of how many plots (also called “farm units” – the piece(s) of continuous land composing a farm or situated within a farm) they have. For new group members, this GPS point must be taken in the center of the largest farm unit of the farm. This is to align with requirements of the 2020 Sustainable Agriculture Standard. Guidance on how to take GPS points will be provided in the upcoming weeks.
Are group members allowed to be located in enclaves of Protected Areas in Côte d’Ivoire?
Yes, according to the Ivorian Ministry of Water and Forests (MINEF), production of cocoa is permitted within the agricultural enclaves of Protected Areas defined in the maps officially shared in December 2019. Those maps have already been shared with CBs.
Will Rainforest Alliance allow certified cocoa producers to operate in accordance with the new categorization of Classified Forests in 2020?
The categories of Classified Forests are not yet operational in Côte d’Ivoire. Certified producers are not currently allowed in any of those Classified Forest categories as per Arrêté 444.
How is Rainforest Alliance supporting groups and CBs to detect deforestation?
In the coming weeks, Rainforest Alliance will share a deforestation risk assessment at farm level per Certificate Holder. These risk assessments will also be shared with the CB prior to audit.
Can Rainforest Alliance share the maps of the protected areas in Côte d’Ivoire, Ghana, Nigeria and Cameroon?
Rainforest Alliance can share the maps of Protected Areas for Côte d’Ivoire and Ghana. If you would like to receive them, please send an email to email@example.com to request them. The maps for Cameroon and Nigeria will be available soon and we will inform CBs and groups when they are available.
Is Rainforest Alliance asking groups to submit polygons for all of the group members?
At the moment, Rainforest Alliance is not requiring groups to submit polygons. This will be a requirement in the new standard from June 2021. However, groups will be given time to collect polygon information once this becomes mandatory, and will not be obliged to submit this in the first year of certification under the new standard. Groups are encouraged to submit polygon information where this is already available.
The Cocoa Policy includes the requirement that first buyers (traders) will share with Rainforest Alliance available polygon data of their supplier groups. Rainforest Alliance is not asking traders nor producer groups to collect new polygons for the time being.
Will the submission of the polygons be made to the Rainforest Alliance or to the CB through the audit?
The submission of the polygons will be made directly to the Rainforest Alliance. Instructions will be shared in the upcoming weeks.
Which specific governmental ID is being requested in the Group Member Registry?
For groups in Ghana, we are requiring the membership number of the NHIS (National Health Insurance Scheme) Card.
For groups in Côte d’Ivoire, we are requiring the “numéro d’immatriculation” which can be found either on the voter’s card (Carte d’électeur) or on the national Identity card (Carte Nationale d’Identité). For non-Ivorian producers, we are requesting the number indicated on their residency card (Carte consulaire).
Each group in Côte d’Ivoire and in Ghana is asked to provide this information for as many producers as possible. The auditors will check the accuracy of the information given in the member registry during the audit and will raise a non-conformity if any discrepancy is found between what is indicated in the member registry and what is cross-checked at producer level.
CAP 2 and Assurance Related Questions
Will there be enough availability of cocoa to meet demand in this new assurance system?
We are focused on the quality of assurance in the field and the supply chain, which could have a temporary effect on availability. However, please note that not all cocoa that is produced as certified is currently sold as certified. For UTZ 70% of certified cocoa was sold as certified in 2019, and for RA 40%. These numbers have historically been between 60% and 80% for UTZ and around 40% for RA. Additionally, we are still allowing groups in Côte d’Ivoire and Ghana that are already certified to grow by 10%, we are not limiting the growth of groups in Cameroon or Nigeria, and we do not have a pause on expansion outside of these four countries, potentially adding more new volume to the market as well. This means there could potentially still be a considerable supply of certified cocoa available to meet any extra demand. Please let your account manager know if your company is unable to source the certified cocoa needed, and our teams will provide support.
How much will the sustainability differential be and who will pay it?
The first buyer will pay a sustainability differential to a certified group. The group will then pay a sustainability differential to individual farmers. There will be no minimum sustainability differential amount set this harvest season (2020/2021). We will publish more guidance on the sustainability differential soon.
How will retailers be able to contribute to the payment of the Sustainability Differential when they are not part of the traceability system?
Retailers will be included in the traceability system in the future, which will give them more direct access to traceability information for their supply chain and increased access to impact data. We are finalizing the exact details of how retailers will be included.
Are we sure that for the other commodities the rules around seal usage remain as communicated.
The accelerated new seal requirements currently only apply to cocoa. We continue to work with the rules previously communicated for other commodities. We do not foresee changes in those timelines but keep open the possibility that these will be revisited as required by unexpected or changing circumstances. Please see our website for more details: https://www.rainforest-alliance.org/business/marketing-sustainability/new-rainforest-alliance-seal-available-for-companies-in-april-may/
When will the current traceability systems, GIP and Marketplace, be migrated to Multitrace for cocoa?
We will have a traceability system that supports the proposed interventions in current UTZ and RA cocoa by October 2020. This includes allowing for regional mass balance, seal use and approvals, shared responsibility and other elements of the 2020 cocoa strategy. The exact timelines for migration are still to be finalized but do not impact our capacity to implement these interventions.
Do country origin matching mass balance rules apply to both beans and products?
Yes, country origin matching for mass balance applies to both beans and derivatives (products). The percentage of origin matching required differs between beans and products, so companies should refer to the forthcoming guidelines for more details.
In case of products, what about the origins of Nigeria and Cameroon?
Origin matching for Mass Balance will apply for all countries globally, including Nigeria and Cameroon. UTZ mass balance credits currently in the market do not include origin information and can be used to cover those volumes or any other origin volumes for the time being. In case there is insufficient supply available from a specific origin please contact your account manager, so that we can explore ways to address this.
Any UTZ credits that enter the supply chain (at first buyer level) on or after October 1, 2020 will have the origin linked to that credit and will require origin matching.