In the context of EUDR, “Land Use Change” is conversion of forest into other land use, such as agricultural crop land. This can happen either as clear cut and replanting with any commodity, or happen also as removing a significant number of trees and planting e.g. coffee underneath, turning the forest into an agroforestry system. – Both cases are not allowed as of 31.12.2020 under EUDR.

Our understanding is that a conversion of forest to agroforest system (i.e. shaded coffee) is not allowed if it happened after 31.12.2020. If it was already an established agroforest system at the cut-off date it isn’t considered a land use change and therefore allowed under EUDR.

In case the Managing Entity cannot provide evidence by correcting data or in-depth analysis by GRAS (please see website) can show evidence, that the coffee plot is deforestation free, the alert in the forest cover would continue to appear. The respective farm would need to be excluded from the group.

Yes, only coffee area.

The 4C Certification strictly prohibits any conversion or removal of primary forests and protected areas, as specified in its Code of Conduct with a cut-off date of 2006. This means that farmers engaged in these activities subsequent to this date are not eligible for certification. However, we actively support initiatives in coffee-producing regions aimed at promoting the preservation of forest and biodiversity. We also provide capacity-building opportunities for both certified and non-certified farmers, emphasizing the importance of these objectives.

It will be going to be required for all 4C certified coffee producers.

The brief answer is yes, EUDR involves all supply chain actors. The operator (importing to or exporting from the EU) is responsible to make the due diligence statement.

Please note, that coffee produced earlier (i.e. 2023/2024) is also required to fulfil EUDR compliance if it is imported to EU in 2025.

Yes, for coffee plots greater than or equal to 4ha.

Yes. (+see next question)

Assuming that no deforestation took place and therefore no individual farmer needs to be excluded from the group, yes, EUDR compliance can be achieved retroactively by going through the same process (to be published soon). This is assuming that e.g. recording the polygons instead of point coordinates is only a technicality.

For the context of verifying EUDR compliance the forest map of 2020 will be used. For 4C certification the original cut-off date 01/01/2006 will be kept.

We will allow KML and geoJSON as a starting point, but are flexible to adjust the import functionality for additional file formats.

GRAS uses global datasets such as Sentinel 1 & 2 imagery as recommended by the EU. It includes national datasets and ground truth data with 10m resolution. In case of deforestation alerts GRAS utilizes additional time series analysis approaches, higher resolution images and aero photos for data validation.

The self-assessment will cover relevant requirements to cover legality criteria as defined by EU member states (which are of course based on the EUDR).

It serves the purpose to support in the “risk analysis” step and is technically independent from the 4C audit.

As there is a major overlap with the existing 4C requirements, the 4C audit is then the “risk mitigation” as auditors will verify compliance on site.

We will make as much raw data available as possible to enable a thorough due diligence statement – of course anonymized.
We can support under specific circumstances in which for example detailed evidence was provided to 4C as part of the verification procedure, i.e. a deforestation alert was raised but sufficient evidence was provided that this was a false positive. The authorities may come to the same false positive result in which case we can support with the recorded evidence.

Yes, this is part of the core 4C System – verified in audits as well as continuous monitoring by 4C.

Yes, we are expanding to Cocoa.

If the coffee is physically entering (and/or leaving) EU, yes. According to our understanding the proof of compliance must be available at customs.

Collection of polygons is not required for farms smaller than 4 hectares.

All farms are checked.

Plausibility checks are part of the BPM upload procedure, yes.

This includes checking the general location inside the country, area in comparison to indicated farm size & overlap with urban areas.

No, this is currently not possible in the 4C System – it is part of the audit, but of course only on a sample basis.

It is still unclear what the EU is expecting regarding legality. 4C will adapt its standard in a way that it covers the requirements of EU.

According to the EUDR, original text:

• (50) In order to recognise good practice, certification or other third-party verified schemes could be used in the risk assessment procedure. They should not, however, substitute the operator’s responsibility as regards due diligence.
• Article 10 (n): complementary information on compliance with this Regulation, which may include information supplied by certification or other third-party verified schemes, including voluntary schemes recognised by the Commission under Article 30(5) of Directive (EU) 2018/2001 of the European Parliament and of the Council (21), provided that the information meets the requirements set out in Article 9 of this Regulation.

What further needs to be done to demonstrate compliance is up to further investigation by the operator.

The GRAS Tool used during risk assessment within 4C certification cannot be used as a reference tool as this is calculating a risk for a region and not verifying compliance for individual coffee plots.

However, GRAS offers this detailed deforestation analysis as an independent service.