Summary of Q&A session to 4C Online Webinar Implementation of EUDR Requirements along the Supply Chain, 25.10.2023
1. Kindly explain Land Use Change=Deforestation?
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.
2. A lot of shaded coffee meets the FAO criteria as being forest. How is this considered in EUDR? As conserving forest cover, or at the expense of natural forest?
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.
3. How is the analysis done once it is found that deforestation took place based on GRAS?
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.
4. Do you know if polygons must show just coffee area?
Yes, only coffee area.
5. Do you have a program to accompany farmers to avoid deforestation or do you just stop cooperation?
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.
6. Is the polygon requirement a mandate only for the coffee exported to Europe and not the internal country sales/purchases?
It will be going to be required for all 4C certified coffee producers.
7. EUDR requirements are applicable for supply chains by 2025?
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.
8. Is it now mandatory for 4C Managing Entities to collect the polygons for all BP Producers?
Yes, for coffee plots greater than or equal to 4ha.
9. How about certificates issued before 1 Jan 2024, for farmers who have 4ha, we need to add polygon?
Yes. (+see next question)
10. Can 4C coffee be considered EUDR compliant retroactively?
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.
11. 4C cert coffee will be verified with GRAS back to 2020 or back to the year of the standard (2006)?
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.
12. Which format will be used/required to upload the polygons?
We will allow KML and geoJSON as a starting point, but are flexible to adjust the import functionality for additional file formats.
13. Can you provide information about the data set of forest layer? What is the spatial resolution?
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.
14. Can you elaborate on the self-assessment?
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.
15. Will 4C assist operators in case competent authorities would question the data and/or find discrepancies with their own assessment?
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.
16. Is there a check to make sure that only the produced volume is sold and selling more than the realistic production provides an alert?
Yes, this is part of the core 4C System – verified in audits as well as continuous monitoring by 4C.
17. Are you aiming to expand the services to other commodities covered by EUDR?
Yes, we are expanding to Cocoa.
18. If the IB is based in EU and receiving the 4C coffee from out of EU and trading the 4C coffee to US are the EUDR requirements necessary?
If the coffee is physically entering (and/or leaving) EU, yes. According to our understanding the proof of compliance must be available at customs.
19. In Uganda the average farm size is 1acre (0,4ha), how can the polygon maps for such small holder farmers look like?
Collection of polygons is not required for farms smaller than 4 hectares.
20. Will all uploaded farms be checked or just a sample?
All farms are checked.
21. Will you offer solution to check the quality of polygons?
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.
22. Will there be a way to check and verify the volume sold from a specific farm so that it is a reasonable volume for the size of the farm?
No, this is currently not possible in the 4C System – it is part of the audit, but of course only on a sample basis.
23. Some of the legality requirements are not necessarily major points in the 4C Code of Conduct, they can be improved over time. Kindly explain if this will still be acceptable by the EU.
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.
24. EU has indicated that certifications can be used as one tool to help reach compliance but cannot be relied on as the only tool by operators. How do you see this, what is needed to be done in addition?
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.
25. Can we use the No-Deforestation Risk Assessment done by GRAS as a reference tool?
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.
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