SETTING THE
BIODIVERSITYBAR FORPALM OIL
CERTIFICATIONASSESSING THE RIGOR OF BIODIVERSITY
AND ASSURANCE REQUIREMENTS OF
PALM OIL STANDARDSSETTING THE
BIODIVERSITYBAR FORPALM OIL
CERTIFICATIONASSESSING THE RIGOR OF BIODIVERSITY
AND ASSURANCE REQUIREMENTS OF
PALM OIL STANDARDSACKNOWLEDGEMENTS
COLOPHON
IUCN NL would like to thank the consultants Jinke
van Dam, Bilge Daldeniz, Tony Hill and other

Authors

colleagues at Proforest for their diligence andThis report was authored bydedication in executing the benchmarks. We would

Bas Tinhout and Heleen van

like to thank Karlo Lumban Raja from Sawit Watchden Hombergh, IUCN National

for his input to the ISPO benchmark and comments

Committee of the Netherlands,

on the benchmark report. Also, we appreciatewith benchmark inputs andthe feedback on the benchmarks from the RSPO

expert advise from Jinke van Dam

secretariat, ISCC, MPOCC and Rainforest Alliance. A

Consultancy and Proforest.

special thanks to Jenny Walter-Thoss for her advice
Contact informationon the direction of this study.

Bas Tinhout

ABOUT IUCN NATIONAL COMMITTEE
OF THE NETHERLANDS (IUCN NL)IUCN National Committee of theNetherlands (IUCN NL)
Plantage Middenlaan 2K

IUCN NL is the Dutch national committee of the1018 DD Amsterdam

International Union for the Conservation of Nature,T + 31 (0) 20 626 17 32

the world’s largest and most diverse environmental

mail@iucn.nl

network. Greening the economy is one of its key

www.iucn.nl

topics. Stimulated by its partners in Indonesia andGraphic design: Margo Vlamings

other producing countries, IUCN NL has been an
advocate for sustainable palm oil. In recent years,
IUCN NL has contributed with advise and input tothe IUCN Oil Palm Task Force and the Amsterdam
Declaration Partnership. IUCN NL convenes Dutch
civil society discussions and exchange on topics
related to palm oil finance. IUCN NL advises civilsociety organizations, government, business andfinancial institutions on issues of agrocommodity
governance.

IUCN NL

4

Setting the biodiversity bar for palm oil certification

EXECUTIVE SUMMARYINTRODUCTION

standards namely: the newest RSPO standard of
2018, Sustainable Agriculture Network (SAN) 2017,

This report provides an overview of palm oil

International Sustainability and Carbon Certification

sustainability standards’ measures to stop

(ISCC) EU and Plus, Indonesia Sustainable Palm Oil

biodiversity loss and restore habitat for biodiversity(ISPO) and Malaysia Sustainable Palm Oil (MSPO).

conservation. It highlights critical areas (particularly

These six were chosen as they currently have thein standards’ biodiversity and level of assurance

biggest market share in certified palm oil production.

criteria) that need to be improved and recommends
specific actions for palm oil buyers and investors.

KEY CONCLUSIONS

Expansion of palm oil production has been a major

The report concludes that RSPO shows best resultscause of biodiversity loss. The Oil Palm Task Force ofin relation to both biodiversity protection and level

the International Union for the Conservation of Natureof assurance. RSPO attains almost 70 percent of(IUCN) however concluded that palm oil is one of thethe maximum score for biodiversity protection andmost productive vegetable oils per land area and thatslightly over 85 percent for level of assurance.

alternatives require more land and could lead to more

ISPO and MSPO lag behind in both benchmarks

biodiversity loss on a global level. A responsible,

resulting in 16 and 18 percent respectively of thedeforestation free, biodiversity friendly management

maximum score for biodiversity protection. MSPOof oil palm plantations is a high priority.

scores 55 percent on level of assurance. ISPO could
not be fully assessed for level of assurance criteria

IUCN NL supports the role of robust voluntary

due to lack of information from primary sources.

agrocommodity sustainability standards as an

These national standards play an important role inimportant element in a mix of governance measures

ensuring a countrywide level playing field for palmthat aim to improve sustainability of agricultural

oil producers. Their current criteria on biodiversity

production, trade and consumption. This report

protection and level of assurance however is far fromattempts to address the main knowledge gap on

satisfactory and risks providing a sustainability stamp

the feasibility and effectiveness of the multiple

without robust criteria and assurance.

certification standards currently available tocompanies, in order to identify strengths,

ISCC EU and Plus show almost equal results on both

weaknesses and similarities between them.

the biodiversity and level of assurance benchmark.
The slight difference in relation to level of assurance

APPROACH

lies in how other standards are recognised, andunder which conditions. Under ISCC EU certified

This report combines two new benchmarks onpalm oil for biofuel sold as “EU Renewable Energy

biodiversity and level of assurance (i.e. the degree of

Directive (RED) compliant” there is a higher risk that

confidence a standard can provide that its criteria are

its certified palm consists of certified palm from otherindeed met) with the analysis of previous benchmark

EU recognised, and possibly weaker, standards.

studies on palm oil sustainability standards.
These new benchmarks include six sustainability

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Setting the biodiversity bar for palm oil certification

2. Players in the palm oil supply chain, like buyers and

The report found that standards with stronger
biodiversity protection safeguards also had a stronger

investors, should demand RSPO certified palm oil.

level of assurance. This suggests that standards withFor biofuels imported into the EU, combined ISCC

advanced criteria recognise the importance of level

EU and RSPO certification should be demanded.

of assurance better than those lagging behind.

3. I SCC should set stronger criteria to prevent weaker

The conclusions drawn from the new benchmark

standards being used in the supply chain whenstudies are in line with previous benchmark studies.

selling under the “EU RED compliant” claim.

As social safeguards were not part of this study, it

4. Standards should engage in jurisdictional 		

is interesting to note that the previous benchmark

or landscape approaches that aim to realise 		studies analysed also show strong social safeguards

sustainability goals across commodities and 		of the RSPO 2013 standard.

stakeholders. Even if more complex to 			implement they will reduce costs, conflicts

KEY RECOMMENDATIONS

between stakeholders and risks for investors andincrease legal compliance.
5. S tandards and their member companies andA full list of recommendations for the separate
standards and companies (producers and financial

financial institutions should collectively invest

institutions) in the palm oil supply chain can be foundin implementation through sufficient capacity toin chapter 6 of the report. Key recommendations aremonitor, audit compliance and reconcile conflicts.
6. S
 tandards should involve civil society to improve

listed below:

audits, carry out truth finding and have effective
1. ISPO and MSPO should be strengthened on both

early warning systems of conflict.
7. The capacity of companies and smallholders

biodiversity protection and level of assurance
criteria to utilise their role to attain sector-wide

should be enhanced to enable them to implement

sustainability at a national level.

the standards

The report concludes that RSPO
shows best results in relation toboth biodiversity protection andlevel of assurance

IUCN NL

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Setting the biodiversity bar for palm oil certification

TABLE OF CONTENTS
Executive summary • 5Contents • 7
Acknowledgement • 4
About IUCN National Committee of the Netherlands (IUCN NL) • 4
Contact information • 4
Executive summary • 5
List of tables • 9
List of annex • 9
List of abbreviations • 10
1. Introduction • 11
2. Methodology • 14
2.1 Biodiversity benchmark • 12
2.2 Level of assurance benchmark • 14
2.3 Correlation of biodiversity protection and level of assurance scores • 15
2.4 Benchmark study analysis • 15
3 Biodiversity protection benchmark: results and conclusion • 16
3.1 Overall • 16
3.2 Process to ensure protection of biodiversity • 16
3.3 Habitat loss and degradation • 17
3.4 Habitat fragmentation and connectivity loss • 18
3.5 Direct mortality (of Rare Threatened or Endangered species) • 19
3.6 Anthropogenic climate change (with indirect impacts on biodiversity) • 19
3.7 Legality in the context of biodiversity • 20
3.8 Restoration • 21
3.9 Community engagement for biodiversity protection • 22
4 Level of assurance benchmark: results and conclusion • 23
4.1 Limitations • 23
4.2 Overall conclusion • 23

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Setting the biodiversity bar for palm oil certification

TABLE OF CONTENTS
4.3 Accreditation • 23
4.4 Independency of audit • 24
4.5 Selection of and requirements to Certification Bodies • 25
4.6 Standard requirements and compliance levels of standard • 26
4.7 Scope of certification at farm producer level • 27
4.8 Complaints mechanism • 28
4.9 Auditing (frequency) and risk assessment • 28
4.10 Stakeholder consultation • 29
4.11 Non-conformities and sanctions • 30
4.12 Group certification / verification • 30
4.13 Cross-recognition • 32
4.14 Transparency • 33
5 Benchmark study analysis • 34
5.1 Limitations • 34
5.2 Comparison of benchmark studies • 34
5.2.1 Environmental benchmark • 34
5.2.2 Social benchmark • 35
5.2.3 Level of assurance benchmark • 35
6 Overall conclusion and recommendation • 36
6.1 Biodiversity and level of assurance benchmark • 36
6.2 In comparison to previous benchmarks • 36
6.3 Recommendations for the standards • 38
6.3.1 General recommendations • 38
6.3.2 Biodiversity • 38
6.3.3 Level of assurance • 37
6.4 Recommendations for palm oil buyers and investors • 39
7 References • 40

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Setting the biodiversity bar for palm oil certification

LIST OF TABLES
Table 1: Standards score on the process to ensure protection of Biodiversity • 17
Table 2: Standards score to prevent habitat loss and degradation • 18
Table 3: Standards score to prevent habitat fragmentation and connectivity loss • 19
Table 4: Standards score to prevent direct mortality (of RTE species) • 19
Table 5: Standards score to prevent anthropogenic climate change (with indirect impacts on biodiversity) • 20
Table 6: Standards score on ensuring compliance to the legal context • 21
Table 7: Standard score on restoration • 21
Table 8: Standards score on community engagement for biodiversity protection • 22
Table 9: Standards score on assurance of accreditation • 24
Table 10: Standards score on independency of audit • 24
Table 11: Standards score on selection of and requirements to certification bodies • 25
Table 12: Score on standard requirements and compliance levels of standard • 26
Table 13: Standards score on scope of certification at farm producer level • 27
Table 14: Standards score on complaints mechanism • 28
Table 15: Standards score on auditing (frequency) and risk assessment • 29
Table 16: Standards score on stakeholder consultation • 29
Table 17: Standards score on non-conformities and sanctions • 30
Table 18: Standards score on group certification / verification • 31
Table 19: Standards score on cross-recognition • 32
Table 20: Standards score on transparency • 33

LIST OF ANNEX
Annex 1: Summary of benchmark studies • 41
Annex 2: Comparison of standard scores for biodiversity protection • 46
Annex 3: Comparison of standard scores for level of assurance • 48
Annex 4: Main changes between versions of RSPO and SAN standards • 51

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Setting the biodiversity bar for palm oil certification

LIST OF ABBREVIATIONS
Abbreviations

Explanation

Abbreviations

BLE	German Federal Office for

ISPO	Indonesia Sustainable Palm Oil

Agriculture and Food
BMPBest Management PracticeCAT

Certification Assessment Tool

CB

Certification Body

IUCN	International Union for theConservation of Nature
IUCN NL 	IUCN National Committee of
the Netherlands

EA	European co-ordination for

MPOB

Accreditation

Malaysia Palm Oil Board

MPOCC	Malaysian Palm Oil

EIA	Environmental Impact
EU RED

Explanation

Certification Council

Assessment

MSPO

Malaysia Sustainable Palm Oil

EU Renewable Energy Directive

P&C

Principles & Criteria

POIG

Palm Oil Innovation GroupRA

Rainforest Alliance

FPIC	Free and Prior Informed
Consent
GHG emissions	Green House Gas emissions
HCS

High Carbon Stock

HCVHigh Conservation Value

RSB	Roundtable on Sustainable
Biomaterials
RSPO	Roundtable Sustainable

HCVRN	High Conservation Value

Palm Oil

Resource Network

RTE SPECIES	Rare Threatened andIAF	International Accreditation

Endangered Species

Forum

SAN

ISEAL alliance	International Social andSustainable Agriculture 		
Network

Environmental Accreditation

SEIA	Social and Environmental

and Labelling allianceImpact Assessment

ISCC	International Sustainability andCarbon CertificationISO	International Organization for

SIA

Social Impact Assessment (SIA)

SOP

Standard Operation Procedure

WHO

World Health Organization

Standardization

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Setting the biodiversity bar for palm oil certification

1. INTRODUCTION
1.1. BEFORE WE START: ROBUST STANDARDSAS INGREDIENTS IN A COMBINATION OF
MEASURES

the application of sustainability standards toagrocommodity value chains that include robust
norms on deforestation and conversion but
also integrate strong social criteria. We promote

Last year, the Oil Palm Task Force of the Internationaland support their continuous improvement andUnion for the Conservation of Nature (IUCN)

implementation – mainly through our members, allies

published a study on palm oil and biodiversity

and partners.

(Meijaard et al. 2018) that aimed to provide aconstructive path to improving sustainability in the

We regard the Roundtables, on palm oil, soy, sugar

palm oil industry. The report concluded that palm oiland biomaterials, as important multi-stakeholder

is here to stay and is, compared to other vegetable

forums for dialogue and negotiation of sustainability

oils, a very land efficient edible oil. Alternatives

standards for production at field and company levels.

generally require more land and could potentially

To provide clarity to the market and policy makers weresult in losing more biodiversity in case of large-

support, and occasionally commission, benchmarks

scale replacement at a global scale. However, theof agrocommodity standards against deforestation/

expansion of palm oil has had a major effect onconversion/biodiversity criteria as well as against

biodiversity and should be prevented from doing so“level of assurance” criteria. The latter is often

in the future, in whatever geography. A responsible,

neglected in benchmark studies but very important

deforestation free, biodiversity friendly management

to ensure quality of governance and control andof oil palm plantations is a high priority and robust

enhances the field-level implementation.

sustainability standards are part of that roadmap. The
task force concluded however that a main knowledge

Robust voluntary standards can be additional to,

gap is the feasibility and effectiveness of theand examples for government measures to ensure

multiple sustainability standards that are available tolegality and sustainability of production. When large

companies, in order to identify strengths, weaknesses

downstream market players, financial institutions andand similarities between them. This report attempts togovernments adopt the norms as requirements, theseaddress that gap.

can become mainstreamed on country or sectorallevel. In fact, increasing recognition of market

IUCN NL supports the role of robust voluntary

players and financial institutions is evolving in the

agrocommodity standards as an important elementcase of RSPO. To have success at scale in producing

in a mix of governance measures that aim to improvecountries, value chain instruments need to be flanked

sustainability of agricultural production, tradeby government-backed landscape-wide/jurisdictionaland consumption. Not as a silver bullet but as an

approaches and policy and finance initiatives that set

important and indispensable element among other,robust norms and boundaries to all land use and land

mandatory and voluntary, measures. Deforestation

users (see also Meijaard et al. 2018, page 52).

and conversion of natural habitats (including
peatland) is a key concern in agrocommodity

Control, to this all, is key; especially in the many

production and trade. It causes biodiversity loss

contexts of weak governance. In many instances,and climate and social impact. We advocate for“legal compliance” is already a challenge to

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Setting the biodiversity bar for palm oil certification

strive for. The paradox of voluntary sustainability

1.2. OBJECTIVE

standards in this complex picture is that–in spite

The objective of this benchmark study is to provideof their voluntary origin- they may in practice often

an overview of standards’ measures to stop

be the highest quality tool to check on “legality”

biodiversity loss and restore habitat for biodiversityof plantation development and management.

conservation. This is done by both analyzing

On the other hand, they often cannot sufficiently

provisions on biodiversity and level of assurance i.e.

guarantee the sustainability norms they stand forthe degree of confidence a standard can provide thatwhen this basic level of legality is not assured byits criteria are indeed met.

government. On labour, hunting and other issues
related to biodiversity protection, it is hard to create

1.3. APPROACH

islands of responsibility in lakes of illegality andSix years ago, IUCN NL produced an overview ofrights violations, which various case studies of field

9 benchmark studies of biomass, palm oil and soy

level realities have shown (Meijaard et al. 2018, page

standards, and added an extra benchmark on the61). Also, such as in the case of soy, the adoption oflevel of assurance (IUCN NL 2013). This study isvoluntary standards is more costly when there is aa detailed benchmark on biodiversity and level of

weak legal level playing field. It would mean a jump

assurance of selected palm oil standards and theirfrom illegal production to responsible production forbenchmarks1.

many, which is a challenge both to large producers
and to smallholders. Step-wise approaches, where

This report combines two new benchmarks onneeded, seem logical. However, given the urgent

biodiversity and level of assurance with the analysis

challenges of climate change and biodiversity loss,of previous benchmark studies of palm oil standards.

combatting deforestation and conversion needs to be

The methodology is described in chapter 2 and,a number one priority now, striving for the applicationin chapters 3 and 4, the outcomes of the two newof integrated social and environmental norms at bothbenchmarks for biodiversity and level of assurance

farm and landscape levels.

respectively. IUCN NL has collaborated with Proforest
for the biodiversity benchmark and with Jinke

Given all of the above, on the mid-term, government,

van Dam consultancy for the level of assurance

financial institutions multi-stakeholder platforms ofbenchmark. These new benchmarks include four

collaboration and consumers need each other to havevoluntary standards namely:

success. The readiness to pay a fair price to those who• Roundtable Sustainable Palm Oil (RSPO) principles

help conserve our planet is key to the success of theand criteria of 2018,transformation towards sustainable agrocommodity• Sustainable Agriculture Network (SAN) 2017,

production. It is the combination of routes and•International Sustainability and Carbon Certificationdifferent approaches that will lead to success. How this

(ISCC) EU and Plus.

will work, is a continuous real-life experiment, in which
IUCN NL is a critical observer, small grant-maker,

And two national standards namely:

dialogue facilitator, knowledge producer, advisor, and•Indonesia Sustainable Palm Oil (ISPO) and–sometimes– insistent advocate. We hope this report•Malaysia Sustainable Palm Oil (MSPO).

may be useful to many decision-makers on palm oil
production, trade and consumption.
NOTE
1 In parallel, also a benchmark study is published for soy
standards (Kusumaningytyas and van Gelder 2019).

IUCN NL

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Setting the biodiversity bar for palm oil certification

They are chosen as they currently have the biggest

The level of assurance (of the standards) is greatly

market share in certified palm oil production.

influenced by the governance structures of voluntary

Other more generic standards allowing multiple

schemes that are in place. It should be noted that,

commodities like Roundtable on Sustainablegiven the scope of the assessment, governance

Biomaterials (RSB) do not have any palm oil certified

issues are only covered by a limited number ofat the moment (pers. comm. Rolf Hogan). The

provisions.

national standards, ISPO and MSPO, aim to certify
industrial and smallholder plantations but areThis study does not cover an analysis of actual field-

restricted to the two largest producing countries,

level implementation of the standard. It however does

Indonesia and Malaysia. It is good to note that theassess the level of assurance that the standard isSAN 2017 standard is at exclusive direction of theactually implemented. Also, the assessment does not

Rainforest Alliance since the end of 2017 and iscover social issues. However, it is recognized that thealso known as the Rainforest Alliance Sustainablerisk for loss of biodiversity can be influenced by social

Agriculture Standard.

issues such as lack of land rights.

The assessment focuses on biodiversity conservation.

An overview of the conclusions of previous

The criteria included are inevitably a selection ofbenchmark studies (chapter 5) provides additional

all criteria that could be analysed. However, every

information on some aspects, such as social aspects,

effort has been made to choose relevant criteria thatand will allow to put the new benchmarks into

can give a good representation of the standards’

perspective. Finally in chapter 6 overall conclusions

measures on biodiversity conservation.

and recommendations are presented.

Agrocommodity standards are
an important element in a mix ofgovernance measures

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Setting the biodiversity bar for palm oil certification

2. METHODOLOGY
2.1 BIODIVERSITY BENCHMARK

2.2 LEVEL OF ASSURANCE BENCHMARKOur own benchmark on biodiversity criteria includes

A set of 12 themes were selected for the analysis ofthemes concerning how standards face the mainlevel of assurance, being:

threats to biodiversity loss:• accreditation,• habitat loss and degradation,• independency of audit,• fragmentation and connectivity loss,• selection of and requirements to Certification• direct mortality (i.e. through over exploitation,

Bodies,pollution, invasive species, anthropogenic• standard requirements and compliance levels of

introduced disease and, fire) andstandard,• anthropogenic climate change.

• scope of certification at farm producer level,• complaints mechanism,

It also includes other themes, being:• auditing (frequency) and risk assessment,• the process for protection of biodiversity,• stakeholder consultation,• legality in the context of biodiversity,• non-conformities and sanctions,• restoration and• group certification / verification,• the involvement of communities in protection of• cross-recognition andbiodiversity.

• transparency.

Within those themes a total of 33 main questions

Within those themes 40 provisions where analysedand 64 subsidiary questions were posed. See theand standards scored within the categories: strong,assessment sheets for the full list of questions:good, medium and weak, with corresponding

www.iucn.nl/node/580. The main questions were

3-0 scores and reasoning provided. The analysis

rated in the categories: strong, good, medium andwas done as much as possible based on standard

weak with corresponding 3-0 scores and explanation

documentation.

and justification provided. The assessments weresent to the scheme owners of the assessed standards

As information from especially ISPO is more limited,

for their review and feedback. All schemes except

reports and literature were used, which means

ISPO reverted and provided further clarifications

that the assessment from ISPO is largely based on

and/or comments. Where justified, further edits weresecondary sources. The assessments were sent tomade to the analysis. The scores of the standards

the scheme owners of the assessed standards forwere then compared in an overview, cross-checked

their review and feedback. All schemes except ISPOand conclusions drawn.

reverted and provided further clarifications and/orcomments. Where justified, further edits were madeto the analysis. The scores of the standards werethen compared in an overview, cross-checked andconclusions drawn.

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Setting the biodiversity bar for palm oil certification

2.3 CORRELATION OF BIODIVERSITYPROTECTION AND LEVEL OF ASSURANCESCORES

in number of scores. This resulted in a percentageof the maximum score. These percentage values
were plotted in a graph to see the relation between
biodiversity protection and level of assurance.

The two benchmark results were then correlated,

2.4 BENCHMARK STUDY ANALYSIS

allowing the combination of biodiversity content
criteria with the level of assurance result. This meansthat the commitment on paper in the standard text

This part of the current report analyses six earlier

is evaluated in the context of the implementation

benchmark studies of palm oil sustainability

assurance of these requirements by the standard

standards. These cover environmental, social andscheme, meaning where a higher level of assurance

assurance level criteria. The benchmark purpose andis prescribed by a standard, e.g. through third party

methodology is described as well as its scope andindependent auditing, the biodiversity criteria theirmain conclusions. Where known the commissioner

standard outlines can been seen as more likely to be

and funder of the study is mentioned. The analysis

implemented, compared to a scheme that has lower

can be found in Annex 1. An overall comparison isrequirements on assurance.

done focusing on where conclusions of the different
benchmarks concur and differ. Finally, similarities,

To ensure each theme is equally weighted indifferences and complementary conclusions

an overall score, the score of the provisions andbetween the benchmark study analysis and newquestions per theme is averaged. These averages

benchmarks where highlighted in the overall

have been summed and divided by the number ofconclusion.

provisions/questions scored, to correct for difference

The commitment on paper in thestandard text is evaluated in thecontext of the implementation
assurance of these requirements by
the standard scheme

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Setting the biodiversity bar for palm oil certification

3. BIODIVERSITY PROTECTIONBENCHMARK: RESULTS AND
CONCLUSION
The results and conclusions of the biodiversity benchmark are shown below pertheme. This includes a comparison table with scores and a narrative with the main
results highlighted. The full comparison table for the biodiversity protection themes
can be found in Annex 2. All questions and sources used as well as the scheme
requirements found and score given, can be downloaded from this web-page:
WWW.IUCN.NL/NODE/580.

3.1 OVERALL

3.2 PROCESS TO ENSURE PROTECTION OF
BIODIVERSITYRSPO scores highest with only 6 out of 33 provisions
scoring medium or weak followed by ISSC EU/Plus

RSPO scores best with both strong provisions

with 11 out of 33 and SAN with 18 out of 33. Overall,to protect biodiversity before expansion and

ISPO and MSPO generally scored weak or medium

intensification and during operations, requiring Highwith 29 and 31 out of 33 respectively. It can beConservation Value Resource Network (HCVRN)

concluded that RSPO has the strongest safeguards

licensed High Conservation Value assessors to be

for biodiversity. ISCC EU/Plus and SAN score goodused for any High Conservation Value assessments

to strong on some themes like processes to protect

prior to new plantings and use of High Conservation

biodiversity before expansion and prevention of

Value – High Carbon Stock Assessment (HCV HCSA)

habitat loss. However, SAN scores generally low

joint methodology for these evaluations. ISCC doesin relation to climate change prevention and bothnot provide sufficient provisions for biodiversity

ISCC EU/Plus and SAN in relation to community

protection during plantation management. SAN

engagement for biodiversity protection. Interestingly,

requires monitoring and reporting on biodiversity

ISPO scores best in this theme. In terms of biodiversity

conservation plans during operations but does

protection there are only minor differences between

not require sufficiently to report on impacts

ISCC EU/Plus which did not affect the scoring. Fromon biodiversity nor does it demand change innow they will be addressed as “ISCC” when the

management when needed to protect biodiversity.

conclusion applies for both standards.

MSPO and ISPO score medium on all requirements
before expansion and for biodiversity monitoring
during operations. However, there is no requirement
to measure impact on biodiversity nor to change
management to prevent biodiversity loss during
operations. Before operations both standards do

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Setting the biodiversity bar for palm oil certification

BIODIVERSITY BENCHMARK
not require the use of HCV assessment. For MSPO

high biodiversity value identification is insufficient.

LEGENDA

there is a need to identify high biodiversity value

ISPO only refers to the Environmental Impact

Weak / non-compliant / non-existant

Strongi.M. Infornation missing / not accessible

Good

N.A. Not applicable / relevant

defined as primary forest, areas protected by law orby international
Mediumagreements for the protection ofAssessment (EIA) assessment (AMDAL) for companies
and organized smallholders which could potentiallyYes or No

Rare
Threatened* Assurance
requirements and Endangered (RTE) species.

provide some biodiversity protection but is not

However, the methodology and requirements for

specifically geared towards that purpose

PROCESSENSURE PROTECTION
OF BIODIVERSITY*
Table 1.TOStandards
score on theprocess to ensure
protection of biodiversity
Requirements prior to significant intensification or expansion of cultivation, infrastructure or processing;
Does the standard require the identification of biodiversity values that would be potentially affected byoperations, and the assessment of potential impacts on those biodiversity values?
ISCC EU
2

ISCC Plus
2

SAN
2

RSPO
3

MSPO
1

ISPO
1

Does the standard require identification of measures to maintain or minimize and mitigate negative impacts fromoperations on biodiversity values?

2

2

1

3

1

2

3

3

1

Does the standard require regular monitoring and reporting on implementation of plans for biodiversity
conservation?

0

3

3

Strong2

Good1

Medium0

Weak / noncompliant /non-existant?

Information
missing / notaccessible

1

Requirements after expansion of cultivation or infrastructure - for existing plantations, infrastructure andprocessing operations;

0

3

1

Does the standard specify any particular measures to be applied in given circumstances to minimize and mitigate
negative impacts from operations on biodiversity values?

2

LEGENDA

1

N.A.

Not applicable /relevant

1

Yes or No
Does the standard require regular monitoring of actual impacts on biodiversity and adaptive management as
necessary for improvement?

1

1

1

3

0

3.3 HABITAT LOSS AND DEGRADATION

0

Unlike ISCC and SAN, RSPO has no clear definition onprotected areas but follows the rules under the HCVISPO and MSPO score medium or weak in allassessments as well as referring to international andprovisions. None of the standards explicitly

national legislation.

encourages expansion to degraded lands that are
not important for species survival. RSPO is the only

SAN and MSPO have no provision on thestandard that has strong provisions to ensure thatmaintenance of bufferzones around protected

HCV is not deteriorated including with measures likeareas. MSPO only requires riparian bufferzones

bufferzones and corridors outside of the HCV area.

and SAN a zone of non-application of pesticides.

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Setting the biodiversity bar for palm oil certification

For ISPO the application of bufferzones depends
on the conclusions of the EIA in order to obtain an
Environmental Permit.
HABITAT2.LOSS
AND DEGRADATION
Table
Standards
score to prevent habitat loss and degradation
Is the standard explicit in requiring the protection of all natural ecosystems that are important for species survival?
ISCC EU
2

ISCC Plus
2

SAN
3

RSPO
3

MSPO
1

ISPO
1

Does the standard require protection of ecosystems providing services critical for off site biodiversity conservation?

2

2

1

3

0

0

1

1

0

1

Does the standard exclude any palm oil development in protected areas?

3

3

3

2

Does the standard require the mainenance of buffer zones around protected areas?

3

3

0

3

Does the standard require that representative areas of native ecosystems in the management unit be actively
conserved?

2

2

1

3

1

0

Does the standard incorporate P&Cs that provide positive encouragement to direct socio-economic pressure for
PO expansion within a given landscape towards degraded lands that are not critical for species survival?

0

0

0

1

0

3.4 HABITAT FRAGMENTATION AND
CONNECTIVITY LOSS0

and HCV management plans developed based on
HCV assessments conducted by HCVRN licensed
assessors for any new plantings taking place.

MSPO and ISPO score medium or weak in prevention

SAN recommends maintenance or installation ofof habitat fragmentation and connectivity loss, very

corridors but not specifically as a contribution to

relevant to the survival of species and ecosystems.

avoid fragmentation nor give guidance how to assess

In the RSPO 2018 standard it is explicitly mentioned

habitat connectivity. MSPO requires to consider thethat HCV should be protected from degradation

wider landscape in management plans but do notand one of the measures is to install corridors. RSPO

require protection or installation of corridors. ISPO

requires habitat connectivity to be evaluated using

does not mention habitat connectivity at all.

the HCV methodology as outlined by the HCVRNIUCN NL

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Setting the biodiversity bar for palm oil certification

HABITATANDto
CONNECTIVITY
LOSSfragmentation and connectivity loss
Table 3.FRAGMENTATION
Standards scoreprevent habitat
Does the standard require protection of corridors of natural vegetation where these are critical for connectivity
between habitats, to avoid fragmentation of ecosystems (e.g. large landscape-level ecosystems/HCV 2 areas)?
ISCC EU
2

ISCC Plus
2

SAN
2

RSPO
3

MSPO
1

ISPO
0

DIRECT MORTALITY (OF RTE SPECIES)

good provisions against overexploitation but weak
3.5 DIRECT MORTALITY (OF RARE
and medium provisions in relation to invasive species
THREATENED OR ENDANGERED SPECIES)
Does the standard require that particular threats be considered and mitigated in palm oil production, i.e.
and anthropogenic disease. ISCC falls short in

HABITAT FRAGMENTATION AND CONNECTIVITY LOSS
Over exploitation

SAN scores strongest to prevent direct mortality

relation to over exploitation and has good provisions

Does
theEU
standardof corridors
natural vegetationthese
areothercriticalcauses
for connectivity
ISCC
ISCCprotection
Plus
RSPO wherefor
SAN ofto
ISPO
ingeneral,onlyrequire
falling
short inrelation
theMSPOof
direct mortality. ISPO andbetween(e.g. large2landscape-level ecosystems/HCV
2 areas)?
1 habitats, to avoid1fragmentation of ecosystems
311

anthropogenic introduced disease (weak). RSPO has

MSPO have medium to weak provisions.

ISCC EU
ISCC Plus
SAN
strongfire and pollution
prevention
requirementsRSPO
andPollution
22
2
3
DIRECT
RTE SPECIES)
2 MORTALITY (OF 2

3

3

MSPO
1

ISPO
0

1

1

Table 4. Standards score to prevent direct mortality (of RTE species)
Invasive species
Does the standard require that particular threats be considered and mitigated in palm oil production, i.e.
2Over exploitation

2

3

1

0

0

Anthropogenic
introduced
ISCC EU
ISCCdisease
Plus
1
1

SAN
3

RSPO
2

MSPO
1

ISPO
1

2
Pollution

2

0

0

1

0

2

2

3

3

1

1

2
Invasive species

2

2

3

1

1

2

2

3

1

0

0

Fire

Anthropogenic introduced disease

2

2

0

0

1

0

2

2

2

3

1

1

Fire

3.6 ANTHROPOGENIC CLIMATE CHANGE(WITH INDIRECT IMPACTS ON BIODIVERSITY)

targets. In relation to prevention of climate change,
RSPO scores strong on all requirements and reallysets the bar high for other standards. ISCC lags

No standard actively requires linking of climate

behind on the protection of significant carbon stocks

change emission reductions to national reduction

including the prevention of CO2 emission fromIUCN NL

19

Setting the biodiversity bar for palm oil certificationpeatlands already planted. In contrary, ISPO scoresfor protection of naturally functioning peatland as anrelatively well on the protection of peatlands alreadyimportant carbon store, SAN scores medium to weakplanted as these are part of the measures taken byon the other requirements. MSPO is the only standard

the government to prevent peatland fires. Other thanthat scores weak on all provisions.

ANTHROPOGENIC
CLIMATECHANGE(WITH anthropogenic
INDIRECT IMPACTSclimate
ON BIODIVERSITY)
Table
5. Standards
score
to preventchange (with indirect impacts on biodiversity)
Does the standard reference HCS (High Carbon Stock) forest?
ISCC EU
3

ISCC Plus
3

SAN
0

RSPO
3

MSPO
0

ISPO
0

0

1

0

1

Does the standard require the protection of significant carbon stocks?

1

1

1

3

Does the standard preclude the conversion of peatland to palm oil production?

3

3

2

3

Does the standard require measures to limit CO2 emissions from peatlands already planted with oil palm?

1

1

0

3

0

2

Does the standard require monitoring and control of GHG emissions from land use change?

2

2

0

3

0

1

Does the standard require monitoring and control of GHG emissions from production operations after planting?

2

2

1

3

0

0

0

0

Does the standard allow for linking of emissions reductions to national targets?

0

0

0

0

3.7 LEGALITY IN THE CONTEXT OF
BIODIVERSITY

provides for it through the HCV methodology, which
includes a strong component of local stakeholder
consultation and evaluation of social HCVs as

Here we are only looking at explicit referencing ofwell, however RSPO does not refer to customary

biodiversity related legislation, not provisioning

rights for protection of biodiversity specificallyfor legal compliance in general. In that context,(unlike customary rights of local and indigenous

SAN, RSPO, MSPO and ISPO require explicitly tocommunities, which are clearly referenced andfully adhere to national regulation. All standards

protected). No standard requires explicitly to adhere

except of RSPO score weak in relation to respect forto all relevant international conventions on thislocal and customary laws providing for protection

topic, however, ISCC and RSPO refer to some andof biodiversity. In relation to the latter, only RSPOMSPO only to international conventions requiring

IUCN NL

20

Setting the biodiversity bar for palm oil certification

protection of habitats. The Indonesian peatland

not automatically have to comply with the peatland

protection law (PP57/2016) post-dates the ISPO

protection law until ISPO is updated.

legislation and therefore ISPO licensed growers do
LEGALITY
Table
6. Standards score on ensuring compliance to the legal context
Does the standard include requirements to comply with relevant international conventions? (e.g. RAMSAR, CITES)
ISCC EU
2

ISCC Plus
2

SAN
0

RSPO
2

MSPO
1

ISPO
0

Does the standard explicitly require compliance with national legislation on protection of biodiversity (wherethese requirements are more rigorous or restrictive than those of the voluntary standard)?

2

2

3

3

3

3

Does the standard require respect for local and customary laws providing for protection of biodiversity (wherethese requirements are more rigorous or restrictive than those of the voluntary standard)?

0

0

0

1

0

0

LEGALITYRESTORATION
Does the standard include requirements to comply with relevant international conventions? (e.g. RAMSAR, CITES)
Does the standard require restoration of natural habitats where their past conversion for palm oil production
restorepeatlands when
3.8
RESTORATIONISCC Plus
RSPO
MSPO
ISCC
EU the requirements
ISPOthe peatland protection
contravenesof the standardSAN
and/or national legislation?
220
20 Requiring certification oflaw will1come into force.
ISCC EU
ISCC Plus
RSPO
MSPO
SAN
ISPO
SAN hasstrongest requirements
in relationtoall units1under managementof a company, RSPO
1
1
3
2
0
Does the standard explicitly require compliance with national legislation on protection of biodiversity (where
restoration
as itarerequiresa minimum
area
ontheoffarmisstandard)?
the only standard that provides the possibility tothese requirements
more rigorous
or restrictive
than
those
the voluntaryDoesstandard byrequirerestorationof peatlands,
damagedatobethecoverednativevegetation
andnatural
if not water
met,bodies or ripariancertifyvegetationcompanies
thatashave
converted areas after
result of palm oil production in contravention of the requirements of the standard and/or national legislation?
this should
be restored.
RSPO restricts
to restoration
the cut-off
22
3
3
3 date without
3 a prior HCV assessment. A

requirements of riparian bufferzones, set-aside HCV223

so-called Remediation and Compensation Procedure

2

1

0

Does the standard require respect for local and customary laws providing for protection of biodiversity (where
andundrainable (in time) peatland HCV. MSPO only
will determine a compensation and remediation plan,these requirements are more rigorous or restrictive than those of the voluntary standard)?

requires restoration of riparian areas. In time, forwhich may include restoration or other compensation

ISPO the requirement will come to (hydrologically)000measures.

1

0

0

RESTORATION
Table
7. Standard score on restoration
Does the standard require restoration of natural habitats where their past conversion for palm oil production
contravenes the requirements of the standard and/or national legislation?
ISCC EU
1

ISCC Plus
1

SAN
3

RSPO
2

MSPO
1

ISPO
0

Does the standard require restoration of peatlands, natural water bodies or riparian vegetation damaged as aresult of palm oil production in contravention of the requirements of the standard and/or national legislation?

2

IUCN NL

2

3

2

1

21

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Setting the biodiversity bar for palm oil certification

3.9 COMMUNITY ENGAGEMENT FOR
BIODIVERSITY PROTECTION

awareness of local communities on the existence forrare plants and animals and functioning of protectedareas. RSPO shows best results to let smallholders

Social safeguards are not benchmarked in this study.

participate in certification including through a new

However, the analysis of previous benchmarks instandard geared towards smallholders. ISPO also haschapter 5 shows standards do cover social criteria.

a version of the standard for smallholders. ISCC takes

Knowing that standards do have social criteria, thisefforts to reduce risks and costs to let smallholders

benchmark looks at community engagement inparticipate in a group certification. For palm oil

biodiversity protection.

developers only RSPO has the requirement to engage

In relation to awareness raising about biodiversity

with the local community to protect biodiversity. Also

conservation among local communities, SAN, RSPORSPO is the only standard that requires to identify

and ISPO score ‘good’. SAN and RSPO requires

and manage potential risks between community

workers to be trained in biodiversity protection.

needs and biodiversity conservation through the

ISPO requires industrial plantation owners to raise

HCV methodology.

COMMUNITYENGAGEMENT
FOR
Table
8. Standards
score
onBIODIVERSITY
communityPROTECTION
engagement for biodiversity protection
Does the standard include requirements for raising the awareness of workers, smallholders and local communities
on biodiversity protection?
ISCC EU
1

ISCC Plus
1

SAN
2

RSPO
2

MSPO
1

ISPO
2

Does the standard make special provision for disadvantaged small producers, enabling them to overcome barriers tocertification and participate in certified supply chains, thereby engendering their support for biodiversity protection?

2

2

0

3

1

2

Does the standard require palm oil project developers to engage with local communities on
biodiversity protection?

1

1

1

3

1

0

Does the standard include a requirement to identify and manage potential conflicts between social/community needs/livelihoods and biodiversity conservation?

0

IUCN NL

0

0

3

1

22

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Setting the biodiversity bar for palm oil certification

4. LEVEL OF ASSURANCEBENCHMARK: RESULTS AND
CONCLUSION
The results and conclusions of the level of assurance benchmark are shown below
per theme. This includes a comparison table with scores and a narrative with the main
results highlighted. The full comparison table for the assurance themes can be foundin Annex 3. The provisions and sources used as well as the scheme requirements
found and score given, can be downloaded from this web-page:
WWW.IUCN.NL/NODE/580.

4.1 LIMITATIONSISCC Plus. Therefore, there are only minor differencesin terms of level of assurance between the two

Assurance covers a wide range of themes; thisstandards. This is because they have the same origin

benchmark looks at the most relevant aspects but isand scheme owner and are only different in the end-

never complete. However, the total scoring gives amarkets they aim to certify (EU for biofuels and Plus

good impression of the total level of assurance. It is

for food). The only major difference is in relation toimportant to note that assurance aspects cannot becross acceptance (see 4.13). From now they will beseen separately from each other; they impact on eachaddressed as “ISCC” when the conclusion applies forother.

both standards.

4.2 OVERALL CONCLUSION

4.3 ACCREDITATION

For the selected criteria, RSPO scores highest withAccreditation assures the quality of auditors. RSPO

only 3 out of 37 provisions scoring medium or weak.

and ISCC score strong in each of the three provisions.

Followed by ISCC Plus and EU with 4 and 5 out ofUnder ISCC, certification bodies must be recognised

39 respectively and SAN with 8 out of 37. MSPO

by a competent national public authority (the Germanhas 15 scores out of 37 medium or weak. It can beFederal Office for Agriculture and Food, BLE, inconcluded that RSPO has the strongest level ofGermany), or accreditation must be performed byassurance followed by both ISCC EU/Plus and SAN.

a national accreditation body. In the case of the

ISPO could not be fully scored due to lack of resource

German BLE, this means that recognized certification

documents and documentation in UN language. ISCC

bodies are subject to office audits and witness audits

EU and ISCC Plus are widely harmonized and mostaccompanied by BLE auditors. The respective body

ISCC EU documents also apply to ISCC Plus. The

responsible for recognition or accreditation is also

ISCC EU System Documents lay down the general

responsible for monitoring the certification body’s

ISCC system principles which are also valid undercompliance with the preconditions for its recognition

IUCN NL

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Setting the biodiversity bar for palm oil certification

LEVEL OF ASSURANCE
or accreditation.
comparable assurance requirements as IAF or ISEAL.
BENCHMARKFor ISCC, accreditation can take place by bodies thatFor SAN, the scheme owner, Rainforest Alliance, canare member of the International Accreditation Forum“accept” a certification scheme as long as they are(IAF) or are a full member or associate member of theISO 17065 or ISO 17021 accredited. ISPO and MSPOInternational Social and Environmental Accreditation

only score strong for the approach to get certification

1 Mediumand(ISEAL) alliance,
havinga bilateral
Strong3 Labelling
0 orWeak/ non-compliant / non-existant
Good
2
Information missing for/ not accessible
agreementwith the European? co-operation

N.A.

LEGENDANot applicable / relevantbodies accredited;the other scores are medium or
Yes or No* Assurance
requirements
weakor, inthe case of ISPO, information is missing on

Accreditation (EA). EA is considered to work withthis provision.

ACCREDITATION*
Table
9. Standards
score on assurance of accreditation
The accreditation or oversight body is independent from the scheme owner. It is responsible for decisions on theaccreditation status of a certification body, including application, approval, suspension or termination.
ISCC EU
3

ISCC Plus
3

RSPO
3

SAN
1

MSPO
1

ISPO
?

Accreditation of certification bodies takes place through one of the following approaches:• Accreditation by a national accreditation body affiliated to the International Accreditation Forum (IAF) or;• Accreditation by a full member of associate member of ISEAL or;• Certification bodies accredited by Accreditation Services International (ASI)• Accreditation by bodies having a bilateral agreement with the European co-operation for Accreditation (EA) or;• Certification bodies accredited by American National Standards Institute (ANSI)

3

3

3

3

3

3

The accreditation organizationmonitors, conducts review and/or surveillance of accredited certification bodies.

3

3

1

3

0

4.4 INDEPENDENCY OF AUDIT?

on reviews of audit reports and recommendations
provided by the CB. ISPO is however working on aAll, except of ISPO score strong for having

revision of the organizational structure that attempts

independent third-party audits. ISPO relies upon

to decouple responsibilities from the ISPO secretariat

accredited third-party certification bodies to conduct

and to shift the lead over the ISPO certification system

audits, but the ISPO Commission itself (not the

towards the Indonesian Ministry of Economic Affairs.

Certification Body (CB) issues certificates based
INDEPENDENCYOF AUDITscore*
Table 10. Standards
on independency of audit
The audits or verifications are carried out by an external third party (not the economic operator). This means thatthe auditor or verifier is free from conflict of interest, independent of the activity being audited and independent
in providing, suspending or withdrawing certificates.
ISCC EU
3

ISCC Plus
3

SAN
3

RSPO
3

MSPO
3

ISPO
1

SELECTION OF AND REQUIREMENTS TO CERTIFICATION BODIES *“The certification bodies to undertake audits on behalf of the scheme and the procedure to select or exclude
certification bodies shall be described by the scheme owner
ISCC EU
3

ISCC Plus
3

SAN
3

RSPO
3

MSPO
3

ISPO
?

The scheme owner requires certification bodies to be compliant with ISO/IEC 17065, ISO/IEC 17021, ISO/IEC
17020 or equivalent

24

IUCN NL
2

2

3

3

Setting the biodiversity bar for palm oil certification

33

4.5 SELECTION OF AND REQUIREMENTS TO
CERTIFICATION BODIESis accredited, but this requirement is not clearlymentioned when the CB is recognized by a national
public authority (although the German BLE does

All standards require generally quality requirements

have this as requirement). Next to that, ISCC mentions

to auditors. This benchmark has not looked into detailin its standard that CBs should ensure appropriate

what quality requirements are exactly required, andexpertise and experience, for instance, in conformity

differences on this may exist between the standards.

with or according to the principles of ISO 17065.

INDEPENDENCY OF AUDIT *All standards have strong criteria for certification

It is not clear whether ISPO has a formal procedure on

bodiescompliantto ISOoutstandards,
often
as (not the economic
how to operator).
select (andwithdraw)
The auditstoorbe
verifications
are carriedby an external
third party
This meansthat certification bodies. The
the auditor or verifier is free from conflict of interest, independent of the activity being audited and independent
partof accreditation, except of ISCC which scores
secretariat of the ISPO commission has the authority
in providing, suspending or withdrawing certificates.

good. Under ISCC, ISO/EC 17065 is in the standard

to do so.

ISCC EU
ISCC Plus
RSPO
SAN
itself 3explicitly required
when the certification
body3
3
3

MSPO
3

ISPO
1

SELECTION
OF AND REQUIREMENTS
TO CERTIFICATION
BODIES *Table
11. Standards
score on selectionof and requirements
to certification bodies“The certification bodies to undertake audits on behalf of the scheme and the procedure to select or exclude
certification bodies shall be described by the scheme owner
ISCC EU
3

ISCC Plus
3

SAN
3

RSPO
3

MSPO
3

ISPO
?

The scheme owner requires certification bodies to be compliant with ISO/IEC 17065, ISO/IEC 17021, ISO/IEC
17020 or equivalent

2

2

3

3

3

3

There are quality requirements (competences) for auditors documented by the scheme.

3

IUCN NL

3

3

3

3

25

3

Setting the biodiversity bar for palm oil certification

4.6 STANDARD REQUIREMENTS ANDCOMPLIANCE LEVELS OF STANDARD

no requirement to meet the other 40% of the minor
requirements. MSPO requires full compliance ofall producers by a certain deadline but there is no

Only RSPO scores fully strong with these provisions

further information on how the compliance should be

followed by SAN and ISCC. All standards clearly

realized in time.

distinguish between mandatory requirements andrecommendations and guidance. SAN has a slightly

ISPO is the only standard that does not revise theirlower score for its differentiation between core andstandard at least every five years, as it is mainly driven

improvement criteria of which the latter does notby changes in legislation. Every five years, the ISCC

require full compliance over time. ISCC differentiates

standard is revised. Next to that, ISCC EU must apply

between critical non-conformities in principle 1,

for re-recognition of the ISCC EU system by the Euro-and for principles 2-6 between major and minor

pean Commission every five years to meet changes

requirements. The critical non-conformities andin the regulatory environment. If ISCC EU changes inmajor requirements must be fully complied withsuch a way that might affect the basis of recognition,and of the minor requirements only 60%. There is

the European Commission must be notified.

STANDARD
AND COMPLIANCELEVELS
STANDARD * levels of standard
Table
12. REQUIREMENTS
Score on standard
requirements
andOF
compliance
The certification standards of the voluntary scheme are revised at least every five years.
ISCC EU
3

ISCC Plus
3

SAN
3

RSPO
3

MSPO
3

ISPO
0

The certification standard clearly distinguishes mandatory requirements from recommendations and guidance.

3

3

3

3

3

3

Requirements for compliance to achieve certification. The sustainability criteria need to be fully complied with
(100%) over a defined timeline. A certain flexibility is possible for economic operators with small scale, lowintensity and/or low risk.

1

1

2

3

3

3

The scheme has a progressive entry level (this means 100% compliance with the criteria is not required from thestart but should be reached over time)

YES

YES

YES

YES *

YES

YES *

* (timeline for realizing certification)

In case of a progressive entry level, the scheme owner has set clear requirements on how to increase thepercentage of compliance over time.

3

IUCN NL

3

3

3

0

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Setting the biodiversity bar for palm oil certification

4.7 SCOPE OF CERTIFICATION AT FARM
PRODUCER LEVEL

of all units under their control (i.e. all subsidiaries ofa parent company) in accordance to a time-boundplan against the principles and criteria. In the ISCC

The identification of farms is a precondition forsystem however, partial certification on farm level is

audit preparation and can have a major impact on

not possible while SAN allows this.

the audit scope. For example, it determines thetotal number of group members and thereby the

For ISCC, the identification of a farm (legally

sample size of farmer groups, risk management andindependent, independent own management

the possible exclusion of farms in the case of non-or centrally managed) is a precondition for audit

compliances.

preparation and audits at first gathering points and

RSPO scores strong on all provisions as it does notcentral offices. Note that the farm identification has

allow for partial certification on farm (including

impact on the audit scope as it determines who hasleased and rented land) nor company group levelto sign the self-declaration, the total number of groupand outsourced activities.

members and thereby the sample size of groups, risk
management and the exclusion of farms in the case of

Given that both ISPO and MSPO are national

non- compliances.

standards that need to be legally implemented
over time, they automatically require all operators

For SAN the certified organization may request toto abide on national level and score relatively

change the certificate scope at any time in order towell. MSPO does, however, not specificallyincrease or reduce the production area, or increase

cover outsourced activities under the scope ofor reduce the number or composition of member

certification and for ISPO this aspect is unclear.

farms. Leased portions of land inside certified farms
shall comply, at least, with Rainforest Alliance zero-

ISCC scores in general good under this category.

tolerance critical criteria, so it is not required to be

ISCC and SAN score weak in relation to certification

certified against the full set of requirements.

SCOPE
AT FARMrequirements
PRODUCER LEVEL* compliance levels of standard
Table OF
13.CERTIFICATION
Score on standard
andExternal audits take place on a producer unit level (farm level). The audit scope is the full production
unit. The producer level is the first point of certification in the chain of custody.
ISCC EU
3

ISCC Plus
3

SAN
3

RSPO
3

MSPO
3

ISPO
3

Partial certification of the farm area is not possible. Producers are required to certify their whole unit of certification,
which shall include owned land, leased and rented land.

3

3

0

2*

3

2*

* (on national level, due to legal timeline)

Organisations are required to certify all (eligible) units under their control in accordance with a time-bound plan. Thismeans that allall subsidiaries of a parent company required to become certified (in time) against the P&C requirements.

0

0

0

2*

3

2*

* (on national level, due to legal timeline)

Outsourcing of activities: The activities of third parties as outsourced activities fall in the scope of
certification, and they shall fully comply with the relevant requirements of the standard.

3

IUCN NL

3

3

3

1

27

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Setting the biodiversity bar for palm oil certification

4.8 COMPLAINTS MECHANISMMSPO does not require CBs to have a procedure inplace but mentions that disputes should be dealt withRSPO scores strongest in relation to complaints

by dispute resolution procedures of the CB. There ismechanism both at CB and scheme owner (RSPO)

no requirement on public availability nor timeline oflevel. SAN also requires CBs to have strong complainscomplaint handling. The MSPO scheme owner hasmechanisms but the scheme owner, Rainforesta dispute resolution procedure in place but is not

Alliance can only be contacted and does not have antransparent about the exact procedure. ISPO provides

official procedure and therefore scores weak. ISCC

insufficient insight about the requirements for aalso requires CBs to have complaints mechanisms incomplaints mechanism hence it can be concluded,

place, but they do not have to be publicly available

based on available information, that at best, theand transparent, whilst for the scheme owner they domechanism is not transparent nor publicly available.

and therefore score strong.
COMPLAINTSMECHANISMscore*
Table 14. Standards
on complaints mechanism
Certification bodies have formal and transparent, publicly available procedures in place for handling disputes andcomplaints related to certification and surveillance.
ISCC EU
2

ISCC Plus
2

SAN
3

RSPO
3

MSPO
0

ISPO
?*

* (partly covered under ISO?)

The scheme owner has formal and transparent, publicly available procedures in place for handling disputes andcomplaints related to conflicts resulting from the relationship between a certification body and the organization orentity to be certified.

3

3

0

3

2

?

AUDITING (FREQUENCY) AND RISK ASSESSMENT*

4.9 AUDITING (FREQUENCY) AND RISK
There is a documented assessment methodology for certification bodies on how to assess compliance with the
ASSESSMENT
standards of the voluntary scheme
ISCC EU

ISCC PlusSAN

SAN scoresstrongest3
3 for auditing and3 risk

RSPO
3

MSPO
3

ISPO
3?

assessment. RSPO scores in general strong with a
As a general rule, a voluntary scheme should ensure that economic operators are audited before allowing them toweakspot not to require and conduct unannounced
participate in the scheme. Producer members (if applicable) should commit to the standard’s P&C

audits. ISCC scores slightly lower than SAN

because: 1) scheme participation as membership
2

2

3

3

3

of ISCC Association is possible without certification

3

Certification
required
to conduct
annualor more frequent surveillance audits of certificate holders.
and,2) forbodies
only arehavingCBs
entitled
to undertake

unannounced audits and not requiring them to do so.
3 allows unannounced
33MSPO
audits but
does not3

3

3

require them. For ISPO, requirements remain

The audit is based in part on a risk assessment of the client. Certification bodies are required to adjust the intensity

unclear.
in relation
to ISPO,
based inonof auditing Alsoand surveillance
to matchobservations
theavailable
field.
information, is also unclear on the needs of theauditing
system to be3
3 based on a risk
3 assessment. 3

3?

The scheme owner requires economic operators (and/or its members) to allow unannounced audits. Certification
bodies conduct unannounced audits

2

2

3

?

2

0

Certificates are valid for no more than five years after which a new full certification audit is required.

IUCN 3
NL

3

3

3

28

3

3
Setting the biodiversity
bar for palm oil certification

ISCC EU
2

ISCC Plus
2

SAN
3

RSPO
3

MSPO
0

ISPO
?*

* (partly covered under ISO?)

The scheme owner has formal and transparent, publicly available procedures in place for handling disputes andcomplaints related to conflicts resulting from the relationship between a certification body and the organization orentity to be certified.

3

3

0

3

2

?

AUDITING
RISK
Table 15.(FREQUENCY)
Standards AND
score
onASSESSMENT*
auditing (frequency) and risk assessment
There is a documented assessment methodology for certification bodies on how to assess compliance with thestandards of the voluntary scheme
ISCC EU
3

ISCC Plus
3

SAN
3

RSPO
3

MSPO
3

ISPO
3?

As a general rule, a voluntary scheme should ensure that economic operators are audited before allowing them toparticipate in the scheme. Producer members (if applicable) should commit to the standard’s P&C

2

2

3

3

3

3

Certification bodies are required to conduct annual or more frequent surveillance audits of certificate holders.

3

3

3

3

3

3

The audit is based in part on a risk assessment of the client. Certification bodies are required to adjust the intensityof auditing and surveillance to match observations in the field.

3

3

3

3

3

?

The scheme owner requires economic operators (and/or its members) to allow unannounced audits. Certification
bodies conduct unannounced audits

2

2

3

0

2

?

Certificates are valid for no more than five years after which a new full certification audit is required.

3

3

3

3

3

4.10 STAKEHOLDER CONSULTATION

3

stakeholders prior to the audit. In Indonesia there
is a legal requirement to have a one-off consultation

Only RSPO and MSPO require some stakeholder

for the environmental impact assessment for landconsultation during audits. ISCC and SAN do notlarger than 3000 ha, which consequently also

require that, although ISCC does look at the risks forapplies to ISPO.

STAKEHOLDERCONSULTATION
Table
16. Standards
score*on stakeholder consultation
Certification bodies are required to proactively consult with affected stakeholders during both certification andsurveillance audits.
ISCC EU
0ISCC Plus
0

SAN
0

RSPO
2

MSPO
2

ISPO
1

NON-CONFORMITIES AND SANCTIONS *The scheme owner has a procedure in place which describes how certification bodies are required to address
non-conformities, including when a certificate or license is suspended or revoked. The scheme should describe
what the implications are for any non-conformities identified during the audit.
ISCC EU
3

ISCC Plus
3

SAN
3

RSPO
3

MSPO
1

ISPO
2

Certificate holders are required to rectify non-compliances identified during certification and surveillance audits
within a set timeframe that does not exceed one year.

3

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Setting the biodiversity bar for palm oil certification

Severe (major) non-compliances that are not rectified in time lead to suspension or termination of the certificate

4.11 NON-CONFORMITIES AND SANCTIONS

or withdrawing of certification without guidance on
what this procedure should look like (which is not

All except of the ISPO and MSPO score strong inpart of ISO).

relation to non-conformities and sanctions. RSPO,SAN and ISCC have strong procedures in place to

In comparison to MSPO, ISPO has a clearer andaddress non-conformities with clear implications

stronger procedure which describes how certification

if they remain unaddressed. Rectification on non-bodies are required to address non-conformities.

compliances should be done in a defined timeline

MSPO is weak in relation to describing terminationthat should not exceed one year and continued non-of certification in response to severe cases and in

conformities, both major and minor, are adequately

relation to applying adequate sanctions in response

sanctioned and can lead ultimately to suspension or

to minor non-conformities. In both cases, there is no

terminationof the certificate.
STAKEHOLDER CONSULTATION *information found about this for ISPO.

Certification bodies are required to proactively consult with affected stakeholders during both certification andISPO
and MSPO do require the non-conformities
surveillance audits.

to be rectified within one year. MSPO relies on ISO
ISCC EU

ISCC Plus

SAN

RSPO

MSPO
2

17021
in relation to renewing,suspending,restoring,
0
0
0
2

ISPO
1

NON-CONFORMITIESANDSANCTIONS*
Table
17. Standards
score
on non-conformities
and sanctions
The scheme owner has a procedure in place which describes how certification bodies are required to address
non-conformities, including when a certificate or license is suspended or revoked. The scheme should describe
what the implications are for any non-conformities identified during the audit.
ISCC EU
3

ISCC Plus
3

SAN
3

RSPO
3

MSPO
1

ISPO
2

Certificate holders are required to rectify non-compliances identified during certification and surveillance audits
within a set timeframe that does not exceed one year.

3

3

3

3

3

3

Severe (major) non-compliances that are not rectified in time lead to suspension or termination of the certificate

3

3

3

0

3

0

Adequate sanctions are applied in situations where less severe (minor) non-compliances are not rectified in time.

3

3

3

1

3

4.12 GROUP CERTIFICATION / VERIFICATIONN.A.?

ISPO could not be assessed as no information wasavailable. This is very unfortunate given the large

Group certification shows a mixed result amongst the

number of smallholders operating in Indonesia.

standards, except of the fact that all standards allow
for group certification (ISCC only on producer level).

RSPO scores strong on all provisions except on the

No standard scored strong on all the benchmark

minimum percentage of individual smallholders

requirements on group certification.

audited which is too low for smallholders with low

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Setting the biodiversity bar for palm oil certification

risk level, and results in a medium score. Also, RSPO

conditions a sample group can be changed. Under

scores medium as it accepts a high heterogeneity

SAN group certification, a maximum of 20% of thein groups and only elevates the risk level when

audited sample in the improvement criteria may fail.

members are geographically or jurisdictionally

MSPO scores strong in relation to the fact that the

separated from one another. For SAN, groups should

group should be led by a legal entity and good in

operate in the same country which risks a potentiallyrelation to the fact that the groups should have anvery high heterogeneity. SAN scores medium oninternal management system in place. On the otherthe conditions under which a group (member)requirements MSPO scores weak.

can be suspended from a group and under which
GROUP 18.
CERTIFICATION*
Table
Standards/ VERIFICATION
score on group
certification / verification
The scheme allows for group certification or verification
ISCC EUYES *ISCC Plus
YES *

SAN
YES

RSPO
YES

MSPO
YES

ISPO
YES

* (to certain parts in supply chain)

There is a sample size formula to determine the number of group members that is externally verified. The samplle
is determined by risk level.

3

3

3

1

3

?

As a minimum, it is required that a sample of at least the square root of the number of group members is audited
individually annually (in line with the ISEAL standard P035.

3

3

3

1

1

?

The group is lead and supervised by a legal entity. This entity is managed by a group manager, responsible for
ensuring that the group complies with the standard.

2

2

2

3

3

?

The group must have an internal quality management system in place, which includes an internal audit system.

3

3

2

2

3

?

The requirements on group certification/verification define the conditions under which a group (member) shall besuspended or removed from a group. A group sample cannot be changed (i.e. a single member can be excluded
from the group) due to failure of an individual group member.

1

1

1

1

3

?

Group auditing for compliance with the scheme’s land related criteria is only acceptable when the areas concerned
are relatively near each other and have similar characteristics (such as management practices).

3

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1

1

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Setting the biodiversity bar for palm oil certification

4.13 CROSS-RECOGNITION
In order to recognize another certification system as
Only ISCC cross-recognizes other standards.

“ISCC compliant” that would require a benchmark

ISCC EU recognizes other certification systems forto assess full equivalence of criteria, also those that

agricultural biomass that are recognized by the

go beyond the EU RED requirements (e.g. social andEuropean Commission in the framework of the EU

assurance criteria).

Renewable Energy Directive (RED). Acceptance in thiscase means that agricultural biomass that is certified

For ISCC Plus the recognition of voluntary schemes

under one of the recognized schemes complies withother than ISCC requires at least a positive

the EU RED requirements and thus can be claimed

equivalence benchmarking result. An exception“EU RED compliant” in the ISCC supply chain. This

exists for raw materials certified under other schemes,means that ISCC “EU RED compliant” certified palm

only if the country of origin of the raw material isoil that is sold under EU RED regulation could consist

Germany and if the certification proves complianceof certified palm oil from other standards recognizedwith SAI GOLD or SAI SILVER (i.e. the performanceby the European Commission. However, ISCC does

level GOLD or SILVER of the Sustainable Agriculture

not accept other schemes for high-risk materials. In

Initiative (SAI) is reached for the production ofcase of uncertainty an equivalence benchmark may

the biomass).

be conducted.
CROSS-RECOGNITION* score on cross-recognition
Table
19. Standards
The scheme has signed a mutual recognition agreement with at least one other scheme, or accept other schemes
ISCC EUYES

ISCC Plus
YES

SAN
NO

RSPO
NO

MSPO
NO

ISPO
NO

The cross-recognition is based on a benchmark and on the requirement that the recognized scheme has equitable
requirements or higher.

1

2

N.A.

N.A.

N.A.

N.A.

The scheme owner requires to certification bodies the verification of claims of other relevant (recognized)
certification schemes to avoid double counting

3

3

N.A.

N.A.

N.A.

N.A.

TRANSPARENCY *The scheme owner makes, or requires certification bodies to make, summary certification/verification reports(with personal and commercially sensitive information removed) publicly available
ISCC EU
3

ISCC Plus
3

SAN
3

RSPO
3

MSPO
0

ISPO
0

The scheme owner makes its certificates publicly available (on the website), including withdrawn ones. A databasewith information about the certified units is publicly available.

3

3

3

3

1

1

The standard documentation is publicly available. The standard documentation is available in a UN language.

3

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3

0

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Setting the biodiversity bar for palm oil certification

CROSS-RECOGNITION *The scheme has signed a mutual recognition agreement with at least one other scheme, or accept other schemes
ISCC EUYES

ISCC Plus
YES

SAN
NO

RSPO
NO

MSPO
NO

ISPO
NO

The cross-recognition is based on a benchmark and on the requirement that the recognized scheme has equitable
requirements or higher.

2
4.141TRANSPARENCY

N.A.

MSPON.A.
scores weak onN.A.
the availability of the standard

N.A.

documents. For ISPO this is available but not in a

The scheme owner requires to certification bodies the verification of claims of other relevant (recognized)
Allschemes
exceptof ISPOMSPO score strong
UN language. Both standards publish the names ofcertification
schemesto avoid
doubleandcounting

on transparency. ISPO and MSPO score weak on thecertificate holders. MSPO also publishes the sizes and3 availability of 3certification/verification
N.A.
N.A.
publicreports.

N.A.of all certified
N.A.
locationsunits but not the expiry dates.

Table
20. Standards score on transparency
TRANSPARENCY *The scheme owner makes, or requires certification bodies to make, summary certification/verification reports(with personal and commercially sensitive information removed) publicly available
ISCC EU
3

ISCC Plus
3

SAN
3

RSPO
3

MSPO
0

ISPO
0

The scheme owner makes its certificates publicly available (on the website), including withdrawn ones. A databasewith information about the certified units is publicly available.

3

3

3

3

1

1

The standard documentation is publicly available. The standard documentation is available in a UN language.

3

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5. BENCHMARK STUDYANALYSIS
5.1 LIMITATIONS

5.2 COMPARISON OF BENCHMARK STUDIESThe benchmark studies analysed have in common

5.2.1 Environmental benchmarkthat they are all desk studies and do not assess
implementation of the standard in the field. The

According to 3keel & LMC (2018) ISCC EU provides abenchmark studies are all done for different

better coverage of environmental criteria than RSPO

purposes: comparing mandatory standards based

2013 using EU and UN policy requirements. It should

on national laws (ISPO and MSPO) with voluntary

be noted however that ISCC EU was developed forstandards (e.g. Daemeter 2014,WWF (2018) orthe EU RED providing the obvious link to its policy

assessing standards to a set of criteria based on legal

requirements. Interestingly, NRDC (2014)’s scoring

frameworks of the USA or EU (NRDC (2014), 3keelof ISCC EU shows a totally different picture: RSPO

& LMC (2018)). The scope of the benchmarks are

2007 scores much better against the environmental

different e.g. Efeca (2016) only uses a limited set ofcriteria set. An explanation could be that NRDC

criteria whilst FPP (2017) has a detailed assessment(2014) framework of criteria are largely based on

only on social criteria. This yields a spread of 1-5

US laws and ISCC EU is highly specific to EU market

benchmarks covering the different standards (seeand purpose. Daemeter (2014) is also supportingtable 21). RSPO and SAN have updated their standard

the conclusion of good environmental measures ofsince the studies were published.

ISCC EU as well as for SAN 2010, which was the only
environmental benchmark covering SAN. The RSPO

Table 21. Studies covering the different standards
Standard

Study

NumberRSPO 2013

Daemeter (2014), Efeca (2016), WWF (2018), FPP (2017) (social), 3keel & LMC (2018)

5

RSPO 2007

NRDC (2014)

1

MSPO

Efeca (2016), WWF (2018), FPP (2017) (social), 3keel & LMC (2018)

4

ISPO

Daemeter (2014), Efeca (2016), FPP (2017) (social), 3keel & LMC (2018)4

ISCC EU

Daemeter (2014), FPP (2017) (social), NRDC (2014)3

ISCC PlusFPP (2017) (social)1

SAN 2010

Daemeter (2014), FPP (2017) (social)

2

RSB

FPP (2017) (social), NRDC (2014)

2HCS

FPP (2017) (social)

1

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Setting the biodiversity bar for palm oil certification

2013 standard clearly outperforms MSPO and ISPO,

Daemeter (2014) looks also at the audit frequency

also on environmental criteria mainly through fully

which is annually for all studied standards (RSPO

applying the HCV approach (Daemeter (2014) and2013, ISPO, ISCC EU and SAN 2010). WWF (2018)

Efeca (2016). Also WWF (2018) concluded RSPO

refers to the audits that can (but do not need to)2013 sets a higher bar in relation to environmental

be unannounced for MSPO and do not need to bemeasures than MSPO. For RSB only NRDC (2014)

unannounced for RSPO 2013. Daemeter (2014) statesassessed environmental measures and concluded itthat RSPO 2013 and ISPO require all subsidiaries

best covers environmental criteria, also better thanunder its management control (defined as majority

RSPO 2007.

of ownership) to be certified whilst MSPO does
not require this. This study continues that for ISPO

5.2.2 Social benchmark

this is restricted to operations (plantations/mills)
in Indonesia (as this is the legal scope of the ISPOOn social issues 3keel & LMC (2018), FPP (2017),

standard) and for SAN 2010 and ISCC EU thisDaemeter (2014) and Efeca (2016) conclude

varies e.g. in relation to smallholder administrator

that RSPO 2013 standards outperforms the othermodels. ISCC EU also accepts biomass standards

standards, including ISCC EU/plus, RSB, ISPO andthat are verifiably compliant with the EU’s biofuels

MSPO. NRDC (2014) shows a higher score of RSB

sustainability criteria.

on social requirements in comparison to RSPO
2007, due to weaker food security safeguards of

Two studies (Daemeter (2014) and Efeca 2016))

the latter. Especially ISPO scores weak on social

concluded that ISPO provides the most generalissues (Daemeter (2014), FPP (2017)). FPP (2017)and practical requirements. Efeca (2016) also

additionally concludes that ISPO and also MSPO

concluded this for MSPO. These standards have aprovide weak access to remedy. FPP (2017)

legal basis, covering a whole sector, which does notcontinues that the standards aiming to serve theallow for multi-stakeholder processes like RSPO andsustainability front runners, RSPO NEXT and POIG

therefore resulting in a less detailed, more pragmatic,(Palm Oil Innovation Group) indeed better address

standard. This results for ISPO, however, in a lesssocial safeguards.

comprehensive framework of criteria. E.g. key social
issues depend too much on national legislation

5.2.3 Level of assurance benchmark(Daemeter (2014) and Efeca 2016)).

Previous benchmark studies have given no or limited
attention to the level of assurance. Daemeter (2014)and Efeca (2016) refer to the degree of obligation tomeet each criteria before getting certified. Meeting
all criteria is required for RSPO 2013 and ISPO andnot required for SAN 2010 and ISCC. The FPP (2017)and Efeca (2016) studies are contradicting as FPP(2017) mentions that MSPO requires compliance of
all criteria while Efeca (2016) claims that an action
plan to show continuous improvement and corrective
action on on-compliant criteria is sufficient.

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6. OVERALL CONCLUSION
AND RECOMMENDATION
6.1 BIODIVERSITY AND LEVEL OF ASSURANCEBENCHMARK

risks providing a sustainability stamp without robust
criteria and assurance. ISPO criteria are underrevision in the areas of environment, labour andBringing together the two new benchmarks it can becontrol and a new version is expected to come out

concluded that RSPO shows best results in relation tolater this year. What has started to be a participatory

both biodiversity protection and level of assurance.

process with involving NGOs, is currently seems to be

In figure 1 below, RSPO attains almost 70 percent ofa black box2 in terms of process and content of thethe maximum score for biodiversity protection andnew standard.

slightly over 85 percent for level of assurance. ISPO

6.2 IN COMPARISON TO PREVIOUS
BENCHMARKS

and MSPO lag behind in both benchmarks resulting
in 16 and18 percent respectively of the maximum
score for biodiversity protection. MSPO scores 55
percent on level of assurance. ISPO could however

RSPO 2013 showed the best results in the

not be fully assessed for level of assurance criteria

benchmarks by Daemeter (2014), Efeca (2016), WWF

due to lack of information from primary sources,(2018) and, FPP (2017). RSB and ISCC scored better

hence figure 1 shows the possible range.

on environmental criteria in the studies by 3keel &Standards with stronger biodiversity protection

LMC (2018) and NRDC (2014) respectively. For ISCC

safeguards also have stronger level of assurance.

this can be explained by the research framework

This suggests that standards with advanced criteria

used by 3keel & LMC (2018) which are based on therecognize the importance of level of assurance better

policy instruments of the EU and UN, a framework

than those lagging behind (figure 1).

ISCC was developed upon. RSB currently does notcertify any palm oil plantations (pers. comm. Rolf
Hogan).

As mentioned in the separate conclusions, ISCC
EU and Plus show an almost equal scoring on bothbiodiversity and level of assurance. The slightdifference lies in how other standards are recognized,
and under which conditions. Under ISCC EU certified
palm oil for biofuel sold as “EU RED compliant” there
is a higher risk that its certified palm consists ofcertified palm from other EU recognized, and possibly
weaker, standards.
National standards fall short of providing sufficientlevel of assurance and biodiversity protection,
also in comparison to their voluntary peers. They
however play an important role for the creation of

NOTE

a level playing-field and inclusion of smallholders

2  https://eia-international.org/news/backtracking-reformindonesias-government-weakening-palm-oil-standards/

on national level. That said, the current standard

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Setting the biodiversity bar for palm oil certification

Biodiversity protection (%)

BIODIVERSITY PROTECTION VS. LEVEL OF ASSURANCE100

ISCC EU80

ISCC PLUS

60

SAN

40

RSPO

20

MSPO

0

ISPO
0

20

40

60

80

100

Level of Assurance (%)
Figure 1 percentage scores of level of assurance (x-axis) plotted against biodiversity (y-axis).

Whilst Efeca (2016) and Daemeter (2017) concluded

conclude RSPO 2013 scores best in comparison to allthat ISPO provides the most practical framework, ourthe standards in the new benchmarks.

benchmark analysis contradicts this as 1) standard
documentation is not available in UN language andPrevious benchmark studies did not provide2) there is a lack of detail, procedures and guidelines,

sufficient attention to level of assurance. The

most notably a lack of information on assurance

conclusions that are drawn in this regard coincidelevel, providing a lot of room to interpretation. This

with the conclusions from the new benchmark

complicates enforcement of the standard and creates

study on level of assurance. From the contradicting

a risk for robustness and creating trust about thestatements in Efeca (2016) and FPP (2017)) we cansustainability of palm oil.

provide clarity that there is a mandatory timeline in
Malaysia for realizing MSPO certification by 30 June
2019.

As the new benchmark studies do not look at social
safeguards, it is interesting to note that RSPO 2013shows best results in this area in comparison to

The main changes between RSPO 2013 and RSPOMSPO, ISPO and ISCC. Additionally, it should be2018 and between SAN 2010 and SAN 2017noted that RSPO 2018 principles and criteria

standards can be found in Annex 4.

have further strengthened social safeguards forlabour, human rights, gender, community rights andsmallholder inclusivity. Unfortunately, the studies
covering social safeguards have been published
before SAN 2017 was published so we cannot

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6.3 RECOMMENDATIONS FOR THE
STANDARDS

5. All standards should enhance its recognition of

6.3.1 General recommendations

ISPO should do more in awareness raising andlocal and costmary law that contribute throughbiodiversity protection. ISCC, SAN, MSPO andengaging of local communities in biodiversity

1. Engage in jurisdictional or landscape approaches

protection.

that aim to realize sustainability goals across

6.3.3 Level of assurance

commodities and stakeholders. Even if more
complex to implement they will reduce costs,

1. ISPO and MSPO should enhance their credibility

conflicts between stakeholders and risks for

as a sustainability standard by developing or re-investors and increases legal compliance, also of

formulating critical governance aspects.

smallholder actors.

2. ISPO should make accessible standard

2. National standards like ISPO and MSPO are key
to ensure a country-wide level playing field but

documentation in UN language and be available

should strengthen their criteria and control tofor feedback upon request of civil society, also

address sustainability issues in the palm oil sector.

from the international actors.
3. ISCC, SAN and ISPO should ensure sufficient

3. I nvest in implementation through sufficientand proactive stakeholder consultation during

capacity to monitor, audit and reconcile conflicts.
4. Involve civil society in audits, truth finding andaudits.
4. ISCC should explicitly require in its standards

early warning systems.
5. The capacity of companies and smallholders

that certification bodies should be compliant
with international ISO standards.

should be enhanced to enable them to implement

5. RSPO is recommended to perform unannounced

the standards

audits.

6.3.2 Biodiversity

6. SAN and ISCC are advised to certify all
production under control of certified companies,

1. ISPO and MSPO should execute an in-depth

including all subsidiaries of a parent company,

revision of its standards to protect Indonesia’s andover a set time-frame.
7. SAN should set stricter requirements that farms

Malaysia’s biodiversity and use the full potential ofcovering all operators on national level.

do change the scope of certification at any point

2. ISCC, ISPO and MSPO should make biodiversity

in time, as a result of (risk for) non-compliance.
8. ISCC should set stronger criteria to prevent

protection an integral part of the managementof palm oil plantations including throughweaker standards being used in the supply chain

consideration of all causes of direct mortality.

when selling under the “EU RED compliant”

3. A
 ll standards should consider to provide positive

claim, and be more transparent under which

encouragement to direct palm oil expansion withinconditions other schemes are not accepted, e.g.

a given landscape towards degraded lands that arein the case of high-risk materials.

not critical for species survival.
4. SAN, MSPO and ISPO should recognize that
agricultural expansion and practice is one of themain drivers of climate change, stop expansion
in high-carbon stock ecosystems and demand
climate-smart land-use practices.

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6.4 RECOMMENDATIONS FOR PALM OIL
BUYERS AND INVESTORS

3. o utreach to civil society to be able to play an
informed role as sounding board for auditors
4. outreach to local companies to understand P & C

RSPO continuously shows the best scores in relationand to be motivated to implement themto biodiversity protection and level of assurance.

5. an early warning system in case of rising conflicts,

Previous benchmark studies also show good scoring

6. t ruth finding (such as community based wateron the level of social safeguards. Therefore, wemonitoring) and7. reconciliation capacity of the RSPO Dispute

recommend buyers and investors to demand RSPO
certified palm oil.

Settlement Facility

Even though RSPO has strong level of assurance,

This way, the strong paper work of RSPO shouldreports from the field suggest that plantation level

become genuine strong practice, which will not

implementation lags behind. We recommend palm oil

be easy in complex governance environments. To

buyers and investors to become member of RSPO to

additionally support governments to achieve theirimprove its implementation capacity and collectively

basis requirements for the sector with stronger

invest in:criteria and control, and achieve, for example inIndonesia, the implementation of policies such as the

1. concerted monitoring of deforestation, humanMoratorium to new palm oil permits, will help create

rights and other concerns with RSPOa level playing field of sustainable production and a

2. sufficient auditor capacity

limit to expansion across producing countries.

This way, the strong
paper work of RSPO
should become
genuine strong
practice

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Setting the biodiversity bar for palm oil certification

7. REFERENCES
See for source documentation for the biodiversity and level of assurance benchmark
the respective assessment sheets for the standards here: WWW.IUCN.NL/NODE/580.

3keel & LMC (2018) Study on the environmental

Kusumaningtyas, R. and Van Gelder, J.W. (2019,

impact of palm oil consumption and on

March), Setting the bar for deforestation-free soy

existing sustainability standards. For European

in Europe; A benchmark to assess the suitability

Commission, DG Environment. 3Keel LLP and LMC

of voluntary standard systems, Amsterdam, The

International Ltd. https://publications.europa.eu/en/

Netherlands: Profundo. https://www.iucn.nl/en/

publication-detail/-/publication/89c7f3d8-2bf3-11e8-

node/547/b5fe-01aa75ed71a1
Meijaard, E. et al (2018) Oil palm and biodiversity.
Efeca (2016) Comparison of the ISPO, MSPO andA situation analysis by the IUCN Oil Palm Task

RSPO Standards. EFECA, economics, climate,

Force. IUCN Oil Palm Task Force. https://portals.

environment. http://www.efeca.com/efeca-

iucn.org/library/node/47753

published-comparison-palm-oil-standards/
NRDC (2014) Biofuel Sustainability Performance
IUCN NL (2013) Betting on Best Quality,

Guidelines. Natural Resources Defense Council

International Union for the Conservation of(NRDC). https://www.nrdc.org/media/2014/140729

Nature - National Committee of the Netherlands.
https://www.iucn.nl/en/updates/iucn-nl-compares-

WWF (2018) Roundtable on Sustainable Palm Oil

sustainability-certification-for-biomass(RSPO) vs Malaysian Sustainable Palm Oil (MSPO).
A comparison based on WWF’s Certification

Daemeter (2014) A Comparison of Leading Palm

Assessment Tool (CAT). World Wildlife FundOil Certification Standards Applied in Indonesia.

Malaysia (WWF-Malaysia). http://www.wwf.org.

Towards Defining Emerging Norms of Goodmy/?25465%252FWWF-Malaysia-releases-reports-

Practices. (Deameter). http://daemeter.org/en/

on-the-comparison-between-RSPO-and-MSPO-

publication/detail/36/a-comparison-of-leading-palm-

Certification-Schemes-and-assessment-of-the-MSPO-

oil-certification-standards-applied-in-indonesia-

Certification-Scheme=

towards-defining-emerging-norms-of-goodpractice#.XOUOfrjgpPY
FPP (2017) A Comparison of Leading Palm
Oil Certification Standards. Forest Peoples
Programme (FPP) https://www.forestpeoples.org/
en/responsible-finance-palm-oil-rspo/report/2017/
comparison-leading-palm-oil-certification-standards

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ANNEX 1 SUMMARY OF
BENCHMARK STUDIESA COMPARISON OF LEADING PALM OIL
CERTIFICATION STANDARDS APPLIED IN
INDONESIA (DAEMETER, 2014)

compliance, with a time-bound plan for addressing
minor non-compliances, under SAN 2010 and ISCC
EU only ‘critical criteria’ and ‘major musts’ should befully fulfilled and others only partly with a minimum

Daemeter (2014) aimed to contribute to discussions

percentage or through a step-wise approach. The

on sustainable and legal palm oil by describing

study provides the following summary results with‘norms of good practice’ and benchmarking

the disclaimer that for a deeper understanding of how

Indonesia’s regulatory framework against voluntary

the issues are addressed in each standard, the fullcertification standards. It includes a comparison

comparison should be read:of environmental and social requirements of four
certification standards: RSPO 2013, ISPO, ISCC EU• Overall, RSPO 2013 has the most clearly worded andand SAN 2010. It additionally highlighted where

thoroughly explained principles, criteria, indicators,

Indonesia’s regulatory system supports or creates

guidance, and requirements for compliance withchallenges to compliance. The certification standards

environmental provisions; two weaknesses concern

were compared using 15 themes reflecting priorities

flexibility in treatment of deforestation and peatland

identified in the discourse on sustainable palm oil

development.

production. The comparison was described both in a

• ISCC EU and SAN 2010 are very strong in theirnarrative and by scoring, indicating relative strength

treatment of environmental concerns, whereas ISPOand clarity of the standard in the respective themes.

was found to be less restrictive and/or provides less

The benchmark was funded by the Climate and Landdetail.

Use Alliance, a collaboration of US-based private• On social themes, RSPO 2013 again ranked

donors.

strongest, reflecting broad consideration of social
issues facing the industry and communities affected

While –according to the study- all standards cover all

by it.

themes, the depth, breadth and level of detail varies• ISCC EU and SAN 2010 are weaker than RSPO 2013

widely amongst the standards. Depending on thefor a handful of social themes reviewed, but ingoals of the different initiatives behind the standard,

general also give robust treatment of social issues.

restrictions imposed differ on specificity and extent. A• ISPO’s treatment of social issues is lessgeneral observation is that ISPO shows least detailed

comprehensive than other standards, due tobut most straightforward, streamlined (touching uponomission of key topics (e.g., FPIC) and/or lessmain points in brief) and practical requirements,

detailed explanation of requirements for compliance.

that is compatible with regulation and applicability
to the sector as a whole. In relation to the degree ofobligation to meet each criteria, standards differ inminimum requirements for compliance to achievecertification. Whilst RSPO 2013 and ISPO require full

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COMPARISON OF THE ISPO, MSPO AND RSPO
2013 STANDARDS (EFECA, 2016)2013 has described the requirements around Social
Impact Assessment (SIA) including the need for aparticipatory process and Free and Prior Informed

Efeca (2016) aims to provide a reference to buyers

Consent (FPIC). Both ISPO and MSPO refer tofor sourcing sustainable palm oil. The study was

national laws in relation to workers’ rights, RSPO

commissioned by the Department for Environment,2013 has detailed requirements around workers’

Food & Rural Affairs of the UK government. Itrights. All three standards require third party audits

compared two standards based on legal compliance,

while RSPO 2013 and ISPO require compliance to all

ISPO and the MSPO with RSPO 2013. The aim

criteria. MSPO does not require full compliance butof the document is to provide stakeholders withto show continuous improvement against the criteria.

information on palm oil standards, as part of Efeca

Grievance mechanisms are best defined for(2016)’s wider programme to increase knowledge on

RSPO 2013.

palm oil sustainability. The comparison is done on 4
environmental and 3 social themes.

In summary the main conclusions are:

The greatest difference found was that RSPO 2013 in• All three standards cover the same general themes:comparison to ISPO and MSPO requires transparency

legality, environmental responsibilities, socialand ethical conduct in business operations andresponsibilities, and business practices.

transactions. Also, RSPO 2013 depends on a• Environmental issues are best addressed in RSPOtransparent process in standard development and2013 especially through its HCV requirements.

improvement through its multi-stakeholder platform.

• ISPO and MSPO rely on national laws for workers’

ISPO and MSPO are developed on a legal basis whichrights whilst RSPO 2013 has detailed requirements

restrict transparency pending on national regulation.

for SIA’s and FPIC.
• RSPO 2013 and ISPO require full compliance to

In relation to environmental safeguards, RSPO 2013

criteria, MSPO not as long as there is continuous

adopts the HCV approach requiring to identify,

improvement.

maintain or enhance HCV whereas ISPO only

• ISPO and MSPO are considered more practical toidentifies HCV and MSPO does not mention HCV

implement, only having to comply with a limited

but refers to maintaining and management of High

number of criteria, in comparison to the detailed

Biodiversity Areas as per national regulation. RSPO

criteria in RSPO 2013.

2013 permits only limited planting on peatlands and

RSPO 2013 VS MSPO (WWF 2018)advices the use of Best Management Practices (BMP).
ISPO specifies peatlands cannot be developed where>70% is on peatland >3m deep and, when planted,

The underlying aim of the study was to stimulate

adverse impacts should be avoided including

continuous improvement in the palm oil sector inmaintenance of water levels. In Malaysia state law

Malaysia and move from MSPO to RSPO and RSPO

allows for plantation development on peatland

NEXT (for voluntary additional efforts for companies

and refers to the Malaysia Palm Oil Board (MPOB)

that have met the requirements and guidance of the

BMP guidelines. Of the standards compared, only

RSPO P&C) compliance. WWF (2018) also aims to

RSPO 2013 has a cut-off date. It mentions that after

improve the MSPO standard both through exposing

November 2007, new plantings should not replacemain differences between MSPO and RSPO 2013,

primary forest or areas required to maintain HCV

as well as through active participation in MSPO

areas. In relation to social safeguards, only RSPO

committees. This study used the Certification

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Setting the biodiversity bar for palm oil certification

Assessment Tool (CAT) developed by WWF (2018).

compared are RSPO 2013, ISCC (EU and Plus), ISPO,CAT evaluates the requirements of the standard

MSPO, SAN 2017, High Carbon Stock (HCS) and(“standard strengths”) as well as the rules andRoundtable on Sustainable Biomaterials (RSB). Basedprocedures that determine how the standard is

on depth, detail, and stringency of requirements for

implemented, assessed and managed (“systemcompliance points between 0 and 3 where given

strengths”). The direct aim is to take away confusionfrom not addressed/clear to strongly addressed andaround the difference in intention, credibility andclear. The themes addressed arefocus area of the standards. CAT numbers a total of
160 questions on environmental and social measures.

• customary rights,

Possible answers are ‘true’, ‘false’ or Not applicable• treatment of smallholders,(‘N/A’).

• social and environmental safeguards,• core labour standards,

MSPO did not performed better on any criteria than• gender and discrimination,

RSPO 2013 and, when RSPO 2013 scored low, MSPO• quality assurance andalso shows a low score. Both standards scored low• access to remedy.

in the categories Chain of Custody, Pollution, Waste
and GHG emissions and “Agriculture: other good

Finally RSPO NEXT and Palm Oil Innovation Grouppractices”. In relation to level of assurance, RSPO(POIG) are benchmarked against the RSPO 20132013 does not require unannounced audits. MSPO

standard as these both tried (and succeeded) torequires certificate holders to agree to unannounced

enhance the RSPO P&C in 2018.

on-site audits but does not require auditors to carryout unannounced visits. MSPO does not require all

RSPO 2013 provides overall the most robust

management units that fall under the companies’

standard and highest sustainability assurance.

control to be certified while RSPO 2013 does.

The main challenge for RSPO is however to ensure
implementation of its standard. ISCC EU/Plus and• RSPO 2013 scored better (84% of the questions

SAN 2017 criteria are not all mandatory in contrast

were rated as “true”) than MSPO (54% of theto RSPO 2013, ISPO and MSPO. Key difference

questions rated as “true”).

between multi-stakeholder standards and ISPO• On system strength and governance this is 89% forand MSPO is that the latter two provide very weak

RSPO 2013 and 41% for MSPO.

access to remedy. RSB and RSPO 2013 provide the• On standard strength concerning environmental

most stringent human rights protections and socialand social questions this is 78% for RSPO 2013 andsafeguards. The HCS approach is not a stand-alone

68% for MSPO.

standard draws heavily on RSPO P&C but insufficientsocial assessment and safeguards.

A COMPARISON OF LEADING PALM OIL
CERTIFICATION STANDARDS (FPP, 2017)• RSPO 2013 scored highest with 103 points overall• RSB and SAN 2017 followed RSPO 2013 with 91 and

The Forest Peoples Programme (FPP (2017)) study

79 points respectively

aims to determine which standard provides the• ISCC, HCS and MSPO scored 68, 66 and 62

most comprehensive coverage of social safeguards

respectively

for palm oil production. This study compares 7• ISPO lags behind most with 34 points

different standards against a comprehensive set of
39 social and human rights indicators. The standards

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The standards providing an enhanced framework of

3keel & LMC (2018) mentions that MSPO is in

criteria (RSPO NEXT and POIG) indeed better address

the process of developing similar supply chain

forced and child labour, inequalities faced by migrantverification procedures.

workers, gender discrimination and harassment andfood security and provide a better framework to

Alongside differences in the certification andprotect smallholder’s rights than RSPO 2013.

accreditation processes the study continues that
there are differences in how the standards cover

STUDY ON THE ENVIRONMENTAL IMPACT
OF PALM OIL CONSUMPTION AND ON
EXISTING SUSTAINABILITY STANDARDS(3KEEL & LMC, 2018)environmental and social themes. For example,
the four standards differ markedly regarding
deforestation. The ISCC EU excludes production fromprimary forest, and forests of high biodiversity value(Criterion 1.1), and degraded forest (Criterion 1.3).

The objective of 3keel & LMC (2018) with thisDegraded forest is defined with a high proportion

study is three fold: 1) broaden knowledge onof logged forest included in the restriction, only

sustainability aspects of palm oil supply chain andallowing to develop highly degraded forests.

actions undertaken to improve sustainability, 2)

The RSPO 2013 standard had the less exacting

Analyse completeness of existing sustainability

requirement that forest clearance must be legal, butstandards in relation to environmental objectives ofprimary forest and High Conservation forest are not

EU and other International policy instruments and,allowed to be cleared for oil palm cultivation. The3) examine initiatives of EU and other countries to

ISPO standard permits forest clearance provided

enhance sustainability in the supply chain of palm

it is within land zoned for agriculture; is allowed

oil. This study compared RSPO 2013, ISCC EU, MSPO

under the environmental impact assessment; andand ISPO against 7 environmental and 5 social

the government has granted the necessary permits.

sub-themes. These themes were valued against

The MSPO standard is broadly similar to ISPO, but

policy instruments of the EU and UN to formulate

with additional requirements on Environmentallythem in actual benchmark provisions. This enables

Sensitive Areas and areas with high biodiversity

comparison of the standards against subthemes

value. The study concludes that, the ISCC provides

relevant for the European Commission who

the most restrictive environmental safeguards, whilecommissioned the study late 2016.

the RSPO 2013 is strongest on the social issues
relating to oil palm. MSPO provides strict standards

The study summarizes that all four standards rely on

for plantation management (dealing with burning, airthird party, independent audits to verify complianceand water pollution). The ISPO is based on existingwith the standards, and surveillance audits are

Indonesian regulations that pertain to oil palm

repeated annually. The RSPO 2013, ISCC EU andcultivation and processing and has a more limited

MSPO standards have independent, internationallycoverage, addressing to a lesser extent the possible

recognized, accreditation of the certification bodies

negative environmental and social impacts of palm

who decide whether a certificate is granted oroil production. The coherency with EU legislation is

not, and the same standards provide a degree ofsummarized as follows:transparency through making documents on audits
1. No single certification standard wholly addresses

and complaints publicly available. The ISPO system
has less robust and transparent procedures on

all of the policy requirements assessed (as they

these elements, but like the ISCC EU and RSPO 2013

were not designed to do so)standards, has supply chain verification mechanisms.

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Setting the biodiversity bar for palm oil certification

2. In general terms, the ISCC standard was more

Also RSPO 2007 has not sufficient provisions tocoherent with the environmental requirements ofreduce GHG emissions, to address food security

EU and UN policies than the other standards (N.B.

and lacks GMO-specific cultivar protocols. ISCCHigh Carbon Stock)

EU has overall a low score as it lacks sufficient

3. T he RSPO 2013 standard was in general terms

assurance and accreditation and criteria to address

more coherent with the social requirements of EU

financial viability, invasive species, GMO, continualand UN policies than the other standards

improvement and public health /environmental

4. The ISPO standard was generally less coherent

justice concerns. ISCC EU is also insufficient towith EU and UN policies than either RSPO 2013

ensure consistency, transparency and relevanceor ISCC standards, with the MSPO standard

as well as compliance with financial laws and allintermediate.

indicators set for environment except for soil health,nutrient requirements /fertilizer use, pesticides/

BIOFUEL SUSTAINABILITY PERFORMANCEGUIDELINES (NRDC, 2014)

herbicide use and management practices, supply
chain management, COC, and product certification.
In relation to social provisions, ISCC EU did not

NRDC (2014) offers a sustainability framework andsufficiently cover the provisions in relation to foodguideline to inform procurement and investment

security, public outreach/ stakeholder participation,

decisions in biofuels. The framework addresses U.S.

transparency and compliance with safety, health, andlaws, regulations, best practices, and policies as wellparticipation laws. The results can be summarized as

as international norms and consists of pillars andfollows:

criteria, namely:
1. RSPO 2007 and RSB 2010 meet almost all criteria• economic: (financial) viability and management;

sufficiently with none lacking or not addressed and• environment: air, water, soil, productivity,

respectively only 4 and 1 insufficiently addressed.

• land-use, biodiversity and waste;

2. ISCC EU lacks or not addresses 6 criteria and• social: food security, human rights, safety and healthinsufficiently addresses 19 out of 35.

and participation.
For each criterion indicators were formulated. Also
key attributes were formulated namely: Consistent,balanced and consensus driven, transparent,
objective and traceable, assured and accredited andrelevant. The sustainability standards assessed thatwere relevant to palm oil are: RSB 2010, ISCC EU, and
RSPO (2007). The study was financially supported by
Packard Foundation and the Energy Foundation, toUS-based private donors.
RSPO 2007 and RSB 2010 both scored high as
they sufficiently addressed almost all criteria.
RSB 2010 has in explicit guidance for Sustainable
Harvest Rates/Biomass Yield. RSPO 2007 is not
sufficient in the area of assured and accredited
as RSPO at the time was not a full ISEAL member.

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Setting the biodiversity bar for palm oil certification

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Setting the biodiversity bar for palm oil certification

Strong

Good

3

2

0

1
Weak / non-compliant / non-existantMedium2

Does the standard specify any particular measures to be applied in given circumstances to minimize and mitigate negative impacts
from operations on biodiversity values?

1

1

Does the standard require regular monitoring of actual impacts on biodiversity and adaptive management as necessary for improvement?

2
3
3
2

2
3
3
2
0

2

Does the standard require protection of ecosystems providing services critical for off site biodiversity conservation?

Does the standard exclude any palm oil development in protected areas?

Does the standard require the mainenance of buffer zones around protected areas?

Does the standard require that representative areas of native ecosystems in the management unit be actively conserved?

Does the standard incorporate P&Cs that provide positive encouragement to direct socio-economic pressure for PO expansion within agiven landscape towards degraded lands that are not critical for species survival?

Does the standard require protection of corridors of natural vegetation where these are critical for connectivity between habitats, toavoid fragmentation of ecosystems (e.g. large landscape-level ecosystems/HCV 2 areas)?

1
2

1
2

Pollution

2

Over exploitation

Does the standard require that particular threats be considered and mitigated in palm oil production, i.e.

DIRECT MORTALITY (OF RTE SPECIES)

HABITAT FRAGMENTATION AND CONNECTIVITY LOSS

02

Is the standard explicit in requiring the protection of all natural ecosystems that are important for species survival?

2

HABITAT LOSS AND DEGRADATION

0

0

2

2

2

ISCC Plus

Does the standard require regular monitoring and reporting on implementation of plans for biodiversity conservation?

Requirements after expansion of cultivation or infrastructure - for existing plantations, infrastructure and processing operations;

2

Does the standard require identification of measures to maintain or minimize and mitigate negative impacts from operations on biodiversity
values?

ISCC EUNot applicable / relevant

Information missing / not accessible

2

N.A.

?

Does the standard require the identification of biodiversity values that would be potentially affected by operations, and the assessment ofpotential impacts on those biodiversity values?

Requirements prior to significant intensification or expansion of cultivation, infrastructure or processing;

PROCESS TO ENSURE PROTECTION OF BIODIVERSITYLEGENDA

3

3

2

0

1

0

3

1

3

1

3

3

1

2

SAN

3

2

3

1

3

3

2

3

3

3

3

3

3

3

RSPO

1

1

1

0

1

0

1

0

1

0

1

1

1

1

MSPO

Yes or No

1

1

0

0

0

1

1

0

1

0

1

1

1

1

ISPO

ANNEX 2 COMPARISON OF STANDARD SCORES FOR BIODIVERSITY PROTECTION

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Setting the biodiversity bar for palm oil certification

2
2

2
2

Anthropogenic introduced disease

Fire

3
1
2
2
0

3
1
2
2
0

Does the standard preclude the conversion of peatland to palm oil production?

Does the standard require measures to limit CO2 emissions from peatlands already planted with oil palm?

Does the standard require monitoring and control of GHG emissions from land use change?

Does the standard require monitoring and control of GHG emissions from production operations after planting?

Does the standard allow for linking of emissions reductions to national targets?

2
1

2

1
2
1
0

Does the standard require restoration of peatlands, natural water bodies or riparian vegetation damaged as a result of palm oil
production in contravention of the requirements of the standard and/or national legislation?

Does the standard include requirements for raising the awareness of workers, smallholders and local communities on biodiversity
protection?

Does the standard make special provision for disadvantaged small producers, enabling them to overcome barriers to certification andparticipate in certified supply chains, thereby engendering their support for biodiversity protection?

Does the standard require palm oil project developers to engage with local communities on biodiversity protection?

Does the standard include a requirement to identify and manage potential conflicts between social/community needs/livelihoods andbiodiversity conservation?

COMMUNITY ENGAGEMENT FOR BIODIVERSITY PROTECTION

0

1

2

1

1

RESTORATION

Does the standard require restoration of natural habitats where their past conversion for palm oil production contravenes therequirements of the standard and/or national legislation?

0

2
0

2

Does the standard explicitly require compliance with national legislation on protection of biodiversity (where these requirements are
more rigorous or restrictive than those of the voluntary standard)?

Does the standard require respect for local and customary laws providing for protection of biodiversity (where these requirements are
more rigorous or restrictive than those of the voluntary standard)?

2

Does the standard include requirements to comply with relevant international conventions? (e.g. RAMSAR, CITES)

2

1

1

Does the standard require the protection of significant carbon stocks?

LEGALITY

3

3

Does the standard reference HCS (High Carbon Stock) forest?

ANTHROPOGENIC CLIMATE CHANGE (WITH INDIRECT IMPACTS ON BIODIVERSITY)

2

2

Invasive species

0

1

0

2

3

3

0

3

0

0

1

0

0

2

1

0

2

0

3

3

3

3

2

2

2

1

3

2

0

3

3

3

3

3

3

3

0

1

1

1

1

1

1

1

0

3

1

0

0

0

0

0

0

0

1

1

0

0

0

2

2

0

0

0

3

0

0

0

1

2

1

1

0

1

0

0

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Setting the biodiversity bar for palm oil certification

2
3

2
3

The scheme owner requires certification bodies to be compliant with ISO/IEC 17065, ISO/IEC 17021, ISO/IEC 17020 or equivalent

There are quality requirements (competences) for auditors documented by the scheme.

In case of a progressive entry level, the scheme owner has set clear requirements on how to increase the percentage of compliance over
time.

YES

YES

2

3

3

3

3

3

3

1

3

1

SAN

3

3

3

3

YES

3

3

3

3

3

3

3

3

3

3

RSPO

* (timeline for realizing certification)

YES

1

Requirements for compliance to achieve certification. The sustainability criteria need to be fully complied with (100%) over a defined
timeline. A certain flexibility is possible for economic operators with small scale, low intensity and/or low risk.

The scheme has a progressive entry level (this means 100% compliance with the criteria is not required from the start but should be reachedover time)3

3

The certification standard clearly distinguishes mandatory requirements from recommendations and guidance.

1

3

3

The certification standards of the voluntary scheme are revised at least every five years.

STANDARD REQUIREMENTS AND COMPLIANCE LEVELS OF STANDARD

3

3

3

3

“The certification bodies to undertake audits on behalf of the scheme and the procedure to select or exclude certification bodies shall be
described by the scheme owner

SELECTION OF AND REQUIREMENTS TO CERTIFICATION BODIESThe audits or verifications are carried out by an external third party (not the economic operator). This means that the auditor or verifier is free fromconflict of interest, independent of the activity being audited and independent in providing, suspending or withdrawing certificates.

INDEPENDENCY OF AUDIT

3

3

ISCC Plus

3

ISCC EUNot applicable / relevant

The accreditation organizationmonitors, conducts review and/or surveillance of accredited certification bodies.

N.A.

Information missing / not accessible

3

Weak / non-compliant / non-existant

?

3

0

Medium

Accreditation of certification bodies takes place through one of the following approaches:• Accreditation by a national accreditation body affiliated to the International Accreditation Forum (IAF) or;• Accreditation by a full member of associate member of ISEAL or;• Certification bodies accredited by Accreditation Services International (ASI)• Accreditation by bodies having a bilateral agreement with the European co-operation for Accreditation (EA) or;• Certification bodies accredited by American National Standards Institute (ANSI)

Good

2

1

3

Strong

3

The accreditation or oversight body is independent from the scheme owner. It is responsible for decisions on the accreditation status of acertification body, including application, approval, suspension or termination.

ACCREDITATIONLEGENDA

0

YES *

3

3

3

3

3

3

3

0

3

1

MSPO

Yes or No

ANNEX 3 COMPARISON OF STANDARD SCORES FOR LEVEL OF ASSURANCE

?

YES *

3

3

0

3

3

?

1

?

3

?

ISPO

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Setting the biodiversity bar for palm oil certification

2

Certification bodies have formal and transparent, publicly available procedures in place for handling disputes and complaints related tocertification and surveillance.

2

3

3

3
3

Certification bodies are required to conduct annual or more frequent surveillance audits of certificate holders.

The audit is based in part on a risk assessment of the client. Certification bodies are required to adjust the intensity of auditing andsurveillance to match observations in the field.

3
3
3

3
3
3

Certificate holders are required to rectify non-compliances identified during certification and surveillance audits within a set timeframe that
does not exceed one year.

Severe (major) non-compliances that are not rectified in time lead to suspension or termination of the certificate

Adequate sanctions are applied in situations where less severe (minor) non-compliances are not rectified in time.

3

3

The scheme owner has a procedure in place which describes how certification bodies are required to address non-conformities, including
when a certificate or license is suspended or revoked. The scheme should describe what the implications are for any non-conformities
identified during the audit.

NON-CONFORMITIES AND SANCTIONS

0

Certification bodies are required to proactively consult with affected stakeholders during both certification and surveillance audits.

0

3

3

Certificates are valid for no more than five years after which a new full certification audit is required.

STAKEHOLDER CONSULTATION2

2

The scheme owner requires economic operators (and/or its members) to allow unannounced audits. Certification bodies conduct
unannounced audits

3

2

2

As a general rule, a voluntary scheme should ensure that economic operators are audited before allowing them to participate in the scheme.
Producer members (if applicable) should commit to the standard’s P&C

3

3

3

3

There is a documented assessment methodology for certification bodies on how to assess compliance with the standards of the voluntary
scheme

AUDITING (FREQUENCY) AND RISK ASSESSMENT

0

0

3

3

3

3

3

3

0

3

3

3

3

3

3

0

* (partly covered under ISO?)3

The scheme owner has formal and transparent, publicly available procedures in place for handling disputes and complaints related toconflicts resulting from the relationship between a certification body and the organization or entity to be certified.

0

3
3

3

3

3

3

3

3

2

3

0

3

3

3

3

3

3

3

* (on national level, due to legal timeline)0

Outsourcing of activities: The activities of third parties as outsourced activities fall in the scope of certification, and they shall fully comply
with the relevant requirements of the standard.

COMPLAINTS MECHANISM

3

3* (on national level, due to legal timeline)

3

Partial certification of the farm area is not possible. Producers are required to certify their whole unit of certification, which shall include
owned land, leased and rented land.

Organisations are required to certify all (eligible) units under their control in accordance with a time-bound plan. This means that allall
subsidiaries of a parent company required to become certified (in time) against the P&C requirements.

3

SCOPE OF CERTIFICATION AT FARM PRODUCER LEVEL

External audits take place on a producer unit level (farm level). The audit scope is the full production unit. The producer level is the first pointof certification in the chain of custody.

0
N.A.?

1

3

2

1

3

?

0

3

1

2

3

2

?

3

3
3

3

3?

?

?

?

2*

2*

3

3

3

2

0

1

2*

2*

3

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Setting the biodiversity bar for palm oil certification

YES *

2
3

2
3
1
3

The group is lead and supervised by a legal entity. This entity is managed by a group manager, responsible for ensuring that the groupcomplies with the standard.

The group must have an internal quality management system in place, which includes an internal audit system.

The requirements on group certification/verification define the conditions under which a group (member) shall be suspended or
removed from a group. A group sample cannot be changed (i.e. a single member can be excluded from the group) due to failure of anindividual group member.

Group auditing for compliance with the scheme’s land related criteria is only acceptable when the areas concerned are relatively neareach other and have similar characteristics (such as management practices).

3

The scheme owner requires to certification bodies the verification of claims of other relevant (recognized) certification schemes to avoid
double counting

3
3

3
3

The scheme owner makes its certificates publicly available (on the website), including withdrawn ones. A database with information
about the certified units is publicly available.

The standard documentation is publicly available. The standard documentation is available in a UN language.

3

3

The scheme owner makes, or requires certification bodies to make, summary certification/verification reports (with personal andcommercially sensitive information removed) publicly available

TRANSPARENCY

2

1

The cross-recognition is based on a benchmark and on the requirement that the recognized scheme has equitable requirements or higher.

3

YES

YES

The scheme has signed a mutual recognition agreement with at least one other scheme, or accept other schemes

3

1

3

3

As a minimum, it is required that a sample of at least the square root of the number of group members is audited individually annually (inline with the ISEAL standard P035.

3

3

CROSS-RECOGNITION

YES

SAN

3

3

3

N.A.

N.A.

NO

0

1

2

2

3

3

* (to certain parts in supply chain)

YES *ISCC Plus

There is a sample size formula to determine the number of group members that is externally verified. The samplle is determined by risk level.

The scheme allows for group certification or verification

GROUP CERTIFICATION / VERIFICATIONISCC EU

3

3

3

N.A.

N.A.

NO

1

3

3

3

1

3

YES

RSPO

0

1

0

N.A.

N.A.

NO

1

2

1

0

N.A.

N.A.

NO

?

?

?
2
1

?

?

?

YES

ISPO

3

1

1

YES

MSPO

ANNEX 4 MAIN CHANGESBETWEEN VERSIONS OF RSPOAND SAN STANDARDSIMPROVEMENTS RSPO 2018 VS. RSPO 2013

IMPROVEMENTS SAN 2010 VS. SAN 2017

Legality - Assured legal compliance of contractors

System – introduction of continuous improvement

and 3rd party Fresh Fruit Brunch supplier (with threecriteria levels A to C with compliance percentages

year transition period for smallholders).

over a period of 6 years. Service providers have tocomply with critical criteria. Identified terms with

Fire - Clear no burning policy

specific definitions are binding elements within thestandard’s criteria. Clearly defined applicability for

System - Improvements on plans, procedures anddifferent operation types (smallholders, group admi-

systems incl. SOP and SEIA’s.

nistrators, single certificate farms).

Peatlands - No new planting on peat and clear rules

Pesticides – Increased number of forbidden subs-

for replanting on peattances including those mentioned in WHO 1 a + b,
Stockholm & Rotterdam conventions (incl. Paraquat)

Pesticides - Minimization, best practice and justifica-

and those categorized as having risk for wildlife,

tion of use of pesticides. No use of pesticides of WHO

aquatic life, pollinators and risk of inhalation. Imple-

1 a + b, Stockholm & Rotterdam conventions andmentation of specific risk mitigation requirements

Paraquat unless in exceptional circumstances.

while using pesticides.

No-deforestation - Use of HCV-HCS assessment,

Biodiversity conservation - maintain or increaseusing the HCSA Toolkit and the HCV-HCSA Assess-native vegetation on all certified farms and for all

ment Manual. Adapted procedures to be developed

production systems. Environmental and social impactfor High Forest Cover countries and there specificallyassessment upgraded to critical criteria level.

High Forest Cover Landscapes, legacy cases andClimate change – energy efficiency and limitation ofcommunity development needs.

GHG emissions from operations.
Human rights - Improved safeguards to protect
human rights and human right defenders. Improved

Labour - living wage implementation plan and salarygrievance mechanism including guaranteed ano-increases.

nymity and confidentiality and access to technical
Human Rights – introduction of Free Prior andadvice.

Informed Consent (FPIC). Legitimate land use rights
Labour - Enhanced effort to include smallholders

upgraded to critical criteria level.

in certification and provision of continuous support
through capacity building, legal advice and pesticideuse. Better protection of vulnerable groups and mandatory payment of a living wage.

IUCN NL

51

Setting the biodiversity bar for palm oil certification