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 from the Rainforest Alliance.

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 currently makes allowance for “minor conversion” of land to agriculture or other land use in two specific instances – please see Annex Chapter 6: Environment for more details.   

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

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 (a polygon or a point from the center of the farm unit) 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, Ghana, Côte d’Ivoire, Nicaragua, Honduras, 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.  

There are many tools available for the collection of geolocation data. The Rainforest Alliance is not prescriptive in terms of which tools can and cannot be used for geodata collection for Rainforest Alliance certification. We provide guidance on how to collect geodata and provide forms to use for the Rainforest Alliance certification process – more information can be found here.  

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.  In addition to this process, third-party auditors check for evidence of deforestation or false positives.
 
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.

The Rainforest Alliance proprietary AI forest layers have been trained to include this type of distinction. However, this process only provides a risk assessment. Ground truthing must be done to validate the risk assessment results which is done through the internal inspections and third-party auditing as part of the Rainforest Alliance certification process.

No. A farm Certificate Holder can only be Rainforest Alliance Certified with the EUDR-aligned criteria or Rainforest Alliance Certified without the EUDR-aligned criteria.  
 
If a farm Certificate Holder self-selects the EUDR-aligned criteria during the certification registration process, the four additional criteria will show up in the farm’s certification scope. If the farm receives a non-conformity for any of those four criteria and does not close the non-conformity within the permitted timeline, then the farm Certificate Holder can remain Rainforest Alliance Certified, assuming all non-conformities related to criteria in the SAS are closed. This would mean the farm Certificate Holder would show up on the public List of Certificate Holders, but not in the PowerBI report indicating farm Certificate Holders that have been audited and met the EUDR-aligned criteria.   

If a group farm Certificate Holder passes the certification or surveillance audit with the self-selected EUDR criteria, this includes all members of the group, meaning that all cocoa coming from that group is EUDR-aligned.

If a farm group wants to take advantage of the Rainforest Alliance EUDR offering, farm group managers must gather the necessary data which aligns to EUDR.  
 
The Rainforest Alliance Sustainable Agriculture Standard defines small farms as farms which have fewer than 10 permanent workers. Such farms may either be part of a group or be individually certified. If a small farm is part of a group, the group’s management, not individual farmers, is responsible for gathering information on EUDR-aligned criteria for the small farm.   

This is the same process for general Rainforest Alliance Certification as well.

Yes. As a certified producer, it is now also possible to add the EUDR self-selected criteria to your active license immediately, without waiting for the next license renewal. Note: there may be additional costs for geodata collection and onsite verification. Contact your Certification Body to begin the process.

As a producer, if you have already been audited with EUDR but have open Non-Conformities (NC) and still want to benefit from the EUDR offering with Rainforest Alliance:

• Close any open NC, even if it is past the normal 10-week timeline for NC closure.
• Contact your Certification Body to conduct an onsite verification.
• Certification Body contacts Rainforest Alliance team via email once non-conformities are closed.

Note: Ensure your geodata meets EUDR criteria in the RACP.

If you have not been audited with EUDR criteria yet, but you do want to add EUDR to your active license, here’s how you can proceed:

• Contact your Certification Body for Rainforest Alliance to indicate you want to include EUDR criteria, and ask to set your license to non-active status temporarily.
• Edit your license to opt-in for EUDR, validate geodata and update your self-assessment in RACP. Follow the RACP manual or get help from Customer Success.
• Notify your Certification Body after updates; they will inform Rainforest Alliance to reactivate your license.
• Schedule and conduct the onsite audit focused on the four EUDR requirements.
• Certification Body sends audit documents to RA. The final decision will be sent to you and your Certification Body automatically once the license is granted. 

Producers should collect geodata according to EUDR criteria, implement EUDR requirements, and prepare for an onsite verification with their Certification Body; noting there may be additional costs for geodata collection and onsite verification, contact your Certification Body for more information.

EUDR inclusion will be valid from the date your license is granted with the EUDR requirements, retroactively applied to the license start date for the estimated volume of the license.

For more detailed instructions and support, refer to the RACP manual or EUDR E-course, or contact Customer Success.

• Contact the Rainforest Alliance Customer Success team to request adding EUDR to your active license.
• Customer Success will provide a template for you to agree to legal terms for data sharing.
• Respond with your agreement using the template.
• Customer Success will confirm once the process is complete and EUDR is added to your license.

For more detailed instructions and support, refer to the RACP manual or contact Customer Success.

Companies interested in receiving supply chain geolocation data and risk assessments for certified products from the Rainforest Alliance will need to purchase cocoa or coffee using the IP or Mixed IP traceability levels. Guidance on Rainforest Alliance traceability levels is accessible here: Annex Chapter 2: Traceability

If your company does not yet have IP in your certificate scope, but you would like to leverage the Rainforest Alliance EUDR offering, it is still important that you encourage farm Certificate Holders you purchase from to opt-in to EUDR. This will help to ensure that these farm Certificate Holders are prepared in time for their audits and that they are EUDR-aligned by the time their cocoa is reaching your facilities.

As an aside, Rainforest Alliance mass balance and segregated traceability levels are still an option for purchasing certified products if your company will not leverage the Rainforest Alliance EUDR offering.

Any Supply Chain Certificate Holder that would like to sell cocoa or coffee forward as IP or Mixed IP will need to have IP within their certificate scope. The last Supply Chain Certificate Holder in the chain interested in receiving access to the EUDR aligned data from their supply chain can buy cocoa or coffee as IP or Mixed IP without having IP in their certificate scope.

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.

When the farm Certificate Holder receives their certificate they will be included in a PowerBI report specific to those that have been audited and met the EUDR-aligned criteria. A hyperlink to this report will be available on the page for the public List of Certificate Holders on the Rainforest Alliance website: List of Certificate Holders

Once a Supply Chain Certificate Holder begins receiving Identity Preserved or Mixed Identity Preserved transactions in MultiTrace that originated from EUDR-aligned farm Certificate Holders, then the Supply Chain Certificate Holder will be able to access a report in PowerBI with the EUDR-aligned information from their supply chain.

The EUDR-aligned data will be delivered to Supply Chain Certificate Holders through PowerBI. It will be organized based on transactions in MultiTrace, so you should discuss with your suppliers at what level you would like to receive transactions (e.g., by shipment, delivery, etc.).

A file compatible with the EU system will be downloadable per transaction which will include all of the geodata from EUDR-aligned farm Certificate Holders that are part of the footprint of that transaction.

More information will be available soon on what other details the PowerBI report will include.

You as the company who wants access to the EUDR-align data for your supply chain will need to opt-in, and the farms in your certified supply chain will need to opt-in. If your direct supplier does not opt-in, but they sell you a certified cocoa or coffee product as IP or Mixed IP in MultiTrace, you will still have access to the Rainforest Alliance EUDR report with the data relating to your farm supply base.

As with other supply chain actors, retailers can access this data by having traceability in place. This would mean that a retailer would need to opt-in to traceability.

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 enable traceability at the IP or Mixed IP level that will permit them to access this data.  

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 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 Certification Body and sent to the Rainforest Alliance. The Certification Body 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 does not issue due diligence statements or upload anything to the EU platform on behalf of companies.