The Rainforest Alliance is proud of our assurance system – assurance is a fundamental strategy to maintain the rigour and credibility of any certification system. The conduct of regular third party audits is a key element of this system. For the Rainforest Alliance, the safety and security of our Certificate Holders and their communities and the auditors working for our partner Certification Bodies is our principle concern. From 7 March a policy is in place to govern exceptions arising from disruptions to audit activities due to corona virus or public health measures and travel restrictions related to it.
Currently, due to restrictions on travel and access to certain sites due to public health risks related to COVID-19 (Coronavirus), cases are arising in some localities where it is not possible to follow the planned schedule of audits in the annual audit cycle. The current Coronavirus pandemic is a situation of force majeure which affects the normal implementation of our certification program and we are implementing special measures to address this. The details of the policy can be found here: https://www.rainforest-alliance.org/business/resource-item/audit-exception-policy-for-covid-19/
The policy is valid until May 31, 2020. We will review the situation regularly and any further extension or modification of the policy will be communicated before the end of that period.
We request that all CHs and CBs respect the public health measures in place in each country. Travel advisories are available from the US and Dutch governments with links to country specific information. Advice on measures to combat corona virus are also available at World Health Organization and the CDC.
Questions and requests for further information should be sent to certification@ra.org.
General Questions
Do Certification Bodies need to apply to the Rainforest Alliance first for permission to do a remote audit for each case or is this a general permission?
As per the policy, Certification Bodies (CBs) need to inform the Rainforest Alliance via certification@ra.org when the policy is enacted for desk audits and certificate extensions. CBs do not need to ask for permission, but the Rainforest Alliance reserves the right to have an overview and ask for clarification or deny it accordingly. In case there is any doubt about the applicability of the policy, certification bodies are welcome to contact the Rainforest Alliance for final agreement/advice.
With regards to geographical applicability of the policy, can you clarify where information on yellow and red level of infections are taken from?
The Rainforest Alliance is using the Travel Advisories from the US and Dutch governments when country own policies do not exist. There are also constant updates by the World Health Organization and the CDC. If you are unsure of any destination or steps to take or cannot find information you are welcome to contact certification@ra.org.
Does the policy also cover national measures blocking external entry and national lockdowns?
Yes, these are considered public health advisories from the origin country.
Is the deadline for time extensions up to 30th August applicable only to farm or also to Chain of Custody?
The deadline for time extensions is applicable to all certificates/licenses
Under the COVID-19 exception policy, the current CB should request both a time and a volume extension. Which CB will conduct the extension audit: the current CB or can the member contract a new CB?
Under the COVID-19 exception policy the current CB will conduct the extension audit as it includes both time and volume. Extension requests to the Rainforest Alliance have to be processed by the current CB free of charge. The physical extension audit and related contracting thereafter will be done between the member and the CB, the Rainforest Alliance does not interfere with this.
If a certificate is valid till 2021 and if a surveillance audit was to be undertaken before March and it didn’t happen, the CB can reschedule the surveillance audit?
Yes, the surveillance audit can be rescheduled to a date outside of the surveillance audit window deadline. For these cases, CBs shall inform the Rainforest Alliance by using the provided template for exceptions (Exception type: Audit Rescheduled). The Rainforest Alliance will update the information in SalesForce accordingly.
For UTZ certificates that are already extended in the beginning of 2020, is there any possibility for giving them one more extension now?
It depends until when that extension is valid. If it is valid beyond the time frame of this policy, then that is not a problem. If it is expiring during this timeframe, then yes, we would need to extend again or consider a remote audit, which is encouraged.
If a group has already applied for an extension and the re-certification audit is scheduled to take place in June 2020 but due to COVID-19 they are unable to prepare for the audit and still the physical audit cannot take place. What are the options?
You can request a second extension, or you can consider doing a full or partial remote audit depending on the risk level of the group.
What is the procedure in case the surveillance audit failed to be conducted in the required timeframe set by the Rainforest Alliance due to COVID-19 impact?
If the timeframe of the surveillance audit has passed, then you do need to apply for an extension and let us know that the on-site audit will be conducted outside of the normal timeframe so that we can document this. The exception procedure of the COVID-19 Policy needs to be followed.
If members only used part of the Force Majeure volume extension, can we include the remaining volume as carry over stock in the new license?
No, the force majeure volume is not linked to carry over volume. If the Certificate Holder only uses part of the force majeure volume by the time the new license/certificate is submitted, the remaining volume of the extension will still be available in the relevant system (MTT, Salesforce, GIP).
What are CBs supposed to do when preparing to submit a new license/ certificate for a member that received a time extension?
UTZ coffee & hazelnut, RA Farm Certificates: In MTT and Salesforce the whole amount of new certified volume needs to be submitted with the new license/certificate. The system will calculate it automatically as follows: remaining volume force majeure + (total new certified volume – total force majeur volume originally asked).
UTZ cocoa & tea: In GIP, volume extensions are treated all the same. In this case, since the Force Majeure was an advance on the new certified volume, it will need to be subtracted from the total amount of certified volume granted after the physical audit.
For volume extension, will this volume be lost when a new license is granted to the member?
No, once granted through the extension, the volume remains available in the CH account, even when the new license is activated. When the onsite recertification / surveillance audit takes place, the new certified volume is verified by the auditor. The new certified volume also includes the “advanced” volume received through the extension.
Is the timeline indicated in the policy for of October 30th for conducting the verification audit and for decision making?
No, this date is only the cut-off for conducting the on-site audit. Normal rules apply as in the relevant UTZ and Rainforest Alliance documents.
If there is an audit scheduled during this period (now), could they be conducted remotely?
The remote audits are being approved only for certificates that are ending during the timeline of the policy or if the audit was scheduled on this period. It is possible to do the remote audits in a partial form and then after, when the restrictions are over, it will be possible to conduct the process on the field. For further details and information please refer to the Rainforest Alliance guidelines for conducting remote audits.
What happens if the country in which the producer is situated does not have mobility restrictions?
The audits can be conducted normally, if there are also no security issues for foreign visitors (e.g. an auditor from outside the community).
In case of new auditors that need to participate on audits, the remote audits will count as for his/her preparation?
Yes, the desk audits may count, but when possible to conduct field audits it must be complemented to this remote experience. In case of doubts, please check with CBMonitoring@ra.org.
UTZ Code of Conduct & Rainforest Alliance Farm Standard
How is the 50% volume extension for Certificate Holders calculated? Is it based on the previous year’s harvest estimation or a new harvest estimation?
The 50% volume extension will be calculated from the previous year’s harvest estimate. When the on-site audit is finally conducted, this 50% will then be subtracted from the new certified volume.
Why are licence extensions limited to 50% of the previous annual certified volume?
The Rainforest Alliance takes the credibility of our certification seriously and we therefore need some level of assurance to be conducted, even in this force majeure situation, before granting a license for the whole volume. The Rainforest Alliance considers that granting 50% volume without an audit is an acceptable risk that allows producers to continue to trade while safeguarding the credibility of our certification system. This rule already exists in the current Rainforest Alliance Certification Rules and we are now extending it to the UTZ program and applying it specifically for the COVID-19 situation.
There are audits from 2019 that are still pending conclusion. In some cases a physical verification of NCs should have been done to close the NCs and finally award the certificate. Would it be possible to do a remote verification of proper closure of NCs?
It is possible for the CB to carry out remote verification of corrective actions to close an NC, if the member is able to send good evidence of closure also online. We do realize that in some cases it will be almost impossible to check all aspects of the closure for example if worker interviews were required. In these cases we will have to allow the CB to make the best decision with regards to whether or not the member should receive the certificate based on the information they can gather. However in ALL cases, the CB still needs to check these NCs onsite as soon as possible once travel bans have been lifted. If at that stage there is evidence that the NCs were not properly closed, this will still serve as a binding part of the audit and the certificate will be suspended or cancelled in line with the normal Rainforest Alliance/UTZ procedure.
Due to the situation can a re-certification audit be postponed and conducted after the harvesting season for short-window crops (e.g.: herbs), accepting the whole volume as certified? And what happens if this re-cert audit includes a scope change to increase number of members more than 10% of the previous list?
Yes, the audit can be postponed or done remotely, and 100% of the volume can be given. However, this still needs to be checked either during the on-site audit if still possible or during the next year’s harvest. If during this next on-site audit, the volumes do not add up and there is any suspicion of fraudulent actions by the member, then the certificate should be cancelled immediately, and the member give a ban of 1 year before they are able to reapply for certification. With regards to the scope change, more than 10% is possible but these new members would need to have undergone an internal inspection and proof of compliance sent to the auditor remotely.
Does the follow-up onsite visit mean a surprise audit?
No, the follow-up on-site audit is not a surprise audit. It is a continuation of the original audit which was done remotely. Now only certain aspects will be verified on-site which were difficult to or not able to be verified remotely. Only when the full audit needs to be done remotely for this cycle, will we request that the next full on-site audit be conducted as a surprise audit.
If we are carrying out remote audits and follow-up onsite audits, can the CB charge members for both the audits?
Yes, this is possible, but it should not be two separate audits that can be charged for. Rather the member should be charged for the part of the audit that was done remotely and then for part of the audit that was done on-site. The member should never be charged twice for checking the same points. So, for example if during the remote audit you check the group’s management plan and charge for this, you should not check again the group’s management plan during the on-site audit and charge for this again.
UTZ Chain of Custody
In 2.5.3.a. – it states that the first audit should shall be conducted no later than 4 months after the SCA has received their first purchase of UTZ product. SCAs may not sell UTZ product until they have received a valid certificate.
In this instance if the 4 months will now expire and no physical audit can take place, the same rule applies as for small volume operators that have now passed the minimum threshold. In other words CBs can perform a desk audit for these companies. Once the travel restrictions are lifted and an onsite audit can be performed again, the CB will need to verify the audit findings onsite.
Do we have the right to deny remote audits (ChoC) and rather go for extensions until an onsite audit is possible again?
Yes, this is possible. If you think it makes more sense to do it onsite, then we need to give an extension until that time.
In the policy, 2.2.a) Chain of Custody, it says that the fulfillment of the UTZ Protocol is still mandatory. Would be possible for remote audits, to change the criteria of maximum 3 audits for the same auditor? The previous knowledge of the operation could be an added value on the remote audits.
For the moment the rules for auditors will not be changed, so the information on the policy needs to apply.
Rainforest Alliance Chain of Custody
A company has already received RFA approval for the labels through Marketplace, but audit is not likely to be completed within 1 year of CRA issuance. If audit is done by 31st May (current end date of COVID-19 exception policy), is the company allowed to use the logo after the date that marks 1 year of CRA issuance?
Yes, if you have been granted an extension for completing your audit, you are still within the application process for certification and can continue to use the Seal through this time as long as you have received the proper approvals for your design in Marketplace.
In 2.2 c) – it states that licenses can be extended until 30 August 2020, does that also include certificates, since in RA CoC certification we don’t work with licenses?
Yes it also includes certificates in the case of the RA program. Please send a request to certification@ra.org with the following information: Certificate #, Country of member, Certified crop, Original certificate end date. The time extension will then be issued by us in Salesforce.
What is a Participating Operators (CoC POs), and why is there a clause specifically for them in the new policy?
CoC POs are the equivalent of SCAs in the PM RA chain of custody program.
For an existing certificate holder under the chain of custody standard, if we complete a desk audit to replace an on-site audit and there are less than 2 NCs, the validity of such CH will be 1 year or 2 years?
The validity of the certificate should be the same as per normal in whichever program. This will not change as the remote audits replace the onsite audits for the current audit cycle (2.2.b).
Besides this policy, please clarify if producers can ask for mutual recognition beginning 1st July 2020?
Mutual Recognition is currently not an option at producer level. Please refer to the Mutual Recognition page on the Rainforest Alliance website.
