Public Consultation Comments
and Responses
Agri-Food Deforestation andConversion Free (DCF) Sourcing
Criteria

Feedback received during Public Consultation various topic of the Criteria
No.

Category/Topic

Feedbacks

Our Response

1

Entities in Scope(Section 2.1)

I am not sure about it.
Yes.

We have included some changes here
based on the suggestion to use a fixed
threshold. Any company that generates
at least 50% of its revenue fromagriculture is eligible to certify underthese Criteria. We understand theimportance of engaging all the supply
chains and we acknowledge that every
company making revenue from the agrifood supply chain should target toachieve deforestation and conversion
free supply chains. However, underthese Agri-Food DCF Sourcing Criteria
entities will be certified as based on the
check carried out for agri-foodcommodities that accounts for morethan 1% of the agri-food procurement
spend. Therefore, including companies
generating a smaller amount of revenue
from agricultural supply chains indicatescertifying
thoseentities
as
Deforestation and Conversion freesourcing without checking theirassociation with Deforestation andConversion in other supply chains. Thisis a first step in addressing emissions inthe supply chains.

Agree
I agree with the flexible approach
We would encourage introducing a threshold related
to materiality, this reduces the likelihood oforganizations reducing the scope of their targets andthe likelihood of companies excluding at-riskvolumes/parts of the business from scope.
cut-off based on percentage, three year average
Yes, I agree with this approach. Given the often
diversified product mix of purchased goods, there
needs to be flexibility in determining eligibility. If thecriteria apply a defined percentage of revenue, thisneeds to be stated in the standard criteria in the
published document, otherwise there is ambiguity as
to which companies can quality for certification under
the critiera, and less transparency as to what thedetermination criteria are of Climate Bonds, should
thisdecision
sit
with
the
organisation.
I would recommend that a significant percentage be
defined as 5% or more of annual revenue. This
percentage is used in corporate Greenhouse Gas
Accounting, to determine when a change in emissions
resulting from a methodological or organisationalchange is deemed 'material' and therefore warranting
further investigation or the potential for a recalculationin emissions.
Truthfully, if we want to capture the full scope of the
impact and transform the global supply chain, we need
to be engaging with *all* players active in the sector.
This includes companies that even have only minimal
revenue generated from agri-food supply chains. Our
recommendation is to include *every* company
making revenue from agri-food supply chains (asotherwise defined in the relevant entities scope).
Additionally noting this is a voluntary standard, all who
are interested should be engaged to drive a market
transition. We are open to engaging with the Climate
Bonds Initiative and relevant working groups to discuss
how that data can be made available to allow for easeof truthful, trusted, transparent and timely monitoring,
reporting and verification. There is opportunity to also
leverage the Anthro platform, which will be available in
the near-future.

2

Materiality of thecommodities in scope(Section 2.4)

I am not sure about it.

This is an entity certification. These
Criteria are to certify the agri-foodentities (except the producers) having

Yes
Not feasible. Food manufacturers often procure a wide
variety of food ingredients and commodities - the 1%
threshold makes it onerous as may constitute a verylarge number of commodities particularly for large anddiversified food manufacturers. Would propose athreshold of 5%.
I disagree
General agreement with the materiality assessment ofcommodities in scope. Propose to also include agricommodities used in non-food contexts e.g. forpersonal care products (which would cover a more
complete scope of palm derivatives) and the inclusionof leather within scope as these complex supply chainsare also key to meeting DCF goals.
yes okdeforestation and conversion free
supply chains. The aim is to cover all
agri-food commodities and therefore
non-food
agri-commodities
arecurrently excluded and no fixed list of
the agri-food commodities to becovered under these Criteria isprovided. All the agri-food commodities
the applicant entity is dealing with will
have to undergo audit (based on theircontribution to procurement spend).
There are mixed suggestions to increase
and decrease the threshold from 1%
and therefore to maintain a balance andto clearly define the boundary of thecommodities to undergo audit we willgo with 1%. No changes in therequirement.

I partially agree with there being a specified
percentage of agri-commodity spend to qualify a raw
material level. However, I am unsure what the rightpercentage threshold should be, to ensure the scopeof the assessment covers commodities that are
deemed to be of material risk (financial,environmental, social, etc) to the company undergoingcertification. Should a company not have prioritised
risk management for a particular commodity, because
under their assessment, this was deemed to be apriority or as much of a priority as perhaps anothercommodity or set of commodities, then there will
naturally be a gap in coverage under their strategy,
policies and programs to address deforestation in
those commodity supply chains. Under this scenario,
many companies may fail to achieve the CBI criteria
benchmark for compliance and therefore fail the audit,
making the criteria less aligned to how companies
respondtosupply
chain
risk.

3

Cut-off date (Section
3.1)

Given that corporate action to address deforestation
tend to focus on those products and derivities
classified by global assessments (E.g. Curtis et al, CDP
Forest disclosure, EUDR) as primary deforestationlinked commodities, rather than those accounting for acertain threshold of agri-food commodity spend, it
might be worth considering to switch this critieria fromone using spend to a defined list of commodities thatmust be subject to certification under the Criteria.
Again here we are curious why we are setting limits forengagement? Is there concern regarding feasibility ofincluding and auditing all commodities that account foreven less than 1% of the procurement spend for a given
eligible entity? We would like to see all included, or
perhaps a plan to include all relevant agri-foodcommodities (as identified in the standard) to ensure
we minimize data gaps accounting for deforestation.
Recommend consideration for a lower threshold.
yes
Yes.
Agree.
I agree

The cut-off date "31st December 2020"is in alignment with AFi and EUDR. In the
background paper we have discussed
cut-off dates set by different initiatives
and guidelines and need to align theAgreement with AFi aligned cut-off date. Propose toinclude additional reference that best practiceconsiders commodity specific sectoral aligned cut-off
dates (eg. Palm RSPO is 2018 etc).
yes okglobal efforts. No changes in therequirement.

Yes, alignment with the EUDR and AFI ensures that the
CBI remain consistent with industry wide accepted
standards. However, there might be some compliancechallenges for entities pursuing certification, who are
ensuring they can meet this cut-off date under EUDR
for EU destined volumes, by excluding volumes fromcertain parts of their supply chains (e.g. smallholders,
untraceable volumes). Under this scenario, a subsidiaryof a group entity might comply with this cut-off date,but at group level, they cannot fully comply.
It might be helpful to provide a buffer in this criteria, toallow for up to 5% of volumes for applicablecommodities, to be derived from lands where
deforestation and conversion occurred after 31st
December 2020. Reasons are as follows:
1. The EUDR does not currently cover the definition of
conversion of other habitats (e.g. savannah, wetlands,etc). Companies working to comply with EUDR will
therefore not prioritise conversion-free status, given
it's exclusion at this time. Therefore, there may be a
portion of volume not in compliance with this cut-off
date.
2. Since the CBI's objective is for certification to help
company's
obtaininvestments
tofinancedeforestation and conversion-free interventions, thecriteria should not exclude actors working towards thisoutcome and for which certification might to help
accelerate
theirresponse.
3. There is widespread concern of how the EUDR will
impact on sustained smallholder inclusion in global
supply chains. Complex traceability requirements forplot level location data could nudge smallholders awayfrom sustainable commodity markets, as many don't
have access to technology to report such data. For thisreason, providing entities with a buffer for suchvolumes will avoid the potential exclusion ofsmallholders from supply chains in future.
This seems as reasonable as any other cutoff date andaligning with regional regulations is wise to trend
towards global standardization. Noting that thebaseline forest cover is taken from 2000 and that highor low risk countries are identified based on
deforestation over the 5-year period between 20182022, spanning the cutoff year of 2020.

4

Risk Classification
Methodology (Section
3.2 and Appendix 1)

Critical question for consideration…. why is the 5-year
period to assess risk spanning the cutoff date rather
than directly prior (ex. 2016-2020)? Noting that 20182022 is heavily during the period of the COVID-19
pandemic, which may skew data.
yes
Yes.
Agree.
I agree

The current approach used for risk
classification is based on data
availability and constraints of different
land used models. As these Criteria
covers all agri-food commodities,

We propose that the risk assessment should becommodity specific to capture the regional variation in
deforestation across commodities. WRI has done somework on this in addition to their GFW data. We also
have some concerns in using deforestation as a proxyfor conversion and degradation as there are key nonforest natural ecosystems which are impacted byconversion and not deforestation e.g. Soy and Beef
expansion in the Brazilian Cerrado or the US. We also
propose an approach in which risk assessments forhigh risk countries are then considered for a regional
level assessment (e.g. working to gain more granulardata). Various high deforestation countries haveregional variations in rates of deforestation andconversion, with some regions having negligible levelsof deforestation and conversion. A country levelclassification may not capture this level of variation.
Resources to support this analysis include WRI’s workon country assessment, which specifically links
deforestation to specific commodity, and Pendrill data.
Proforest would be happy to put CBI in touch with therelevant contact points.
not sufficient - risks should be classified in terms oflikelihood and impact (see OECD) and be commodityspecific by country
The Global Forest Watch tool is based on research byHansen et al. (2013), which focuses on tree cover loss,
gain and change. Using tree cover as a forest proxydoes not distinguish well between native forest andtimber, rubber, coffee and cocoa plantations, to namea few examples. This issue is most notable for crops
grown under agroforestry systems. Using tree coverloss can also lead to false positives (e.g. tree crop
renewal, which is classified as tree cover loss) and false
negatives (e.g. the layer won’t detect tree cover loss
for tree crops grown under forest canopy).
As a result of this, the rating of high or low risk might
be poorly classifying commodity-driven country risk,
because the Global Forest Watch tool is not effectiveat discerning land use change drivers, when taken inaggregation at country level. In addition, somecountries are not classified (perhaps because the focus
might have just been on countries with tropical forest
cover only). However, does this therefore mean thatany risks from e.g. the Boreal forest biome - such as
deforestation linked to timber production in Russia, are
not
in
scope
of
the
Criteria?
It might be worth considering whether a few different
risk classification sources would better serve thisobjective for ranking country risk.

therefore carrying out a commodityspecific risk classification which requires
wider database and modelling cannot
be done at this stage. There is lack of
databaseondegradation
andconversion and therefore, the data for
deforestation is currently used as proxyfor both. We acknowledge thelimitation the methodology has, and wehave also discussed it in detail in the
background paper. These lists can be
modified as more data becomes
available. For the countries currently
not covered under the list, the verifiers
will use the similar methodology toassess the risk. Further risk assessment
to be carried out but the companies
under due diligence.

In addition to our own public and private sources, wecross-reference our own satellite data capabilities with
Global Forest Watch data as a high-quality data sourceand see higher caliber results in the combined output.
The countries included in the list of 58 they are
currently monitoring do include the geographic regions(and ecosystems) most relevant for the target
commodities listed: palm oil, soy, cattle, cocoa, coffee,
rubber and wood; however it should be noted that thiswill not give a full picture. For example, Canada is notincluded, and they are a critical player in the timberindustry, which includes pulp & paper manufacturingthat is used for food packaging (noted as a focus of thisstandard).

5

Risk Classification
Methodology (Section
3.2 and Appendix 1)2

What will be the approach for a country not includedin this list? We recommend we consider that they areclassified as a “high-risk” country in that case. We could
work with your network of approved verifiers to gather
the needed impact reporting information.
noMay be not.
Agree.
I accept cover density greater than 10%
No comment
don't know
Yes, a lower density will ensure a larger area ofassessment and detection of tree cover loss.
We disagree and recommend the use of the 30%
canopy density assessment for risk classification. Not
only is this more rigorous and results in an inclusion of
more “high-risk” countries (critically including theUnited States, which is a *major* driver of
deforestation for cattle and feed in particular andneeds to be held under tight scrutiny andaccountability), but this brings the focus to regions thatwould be more widely considered to be a “forest”
rather than a mixed-use region and keep closer to totheintentionofthestandard.
The only tradeoff is that this doesn’t align directly withthe upcoming EUDR, so trends away from global
harmonization… that said, this would make Climate
Bonds’ standard more aggressive and risk-averse,
which is only an improvement and positive driver for

The definition of forest states "Landspanning more than 0.5 hectares withtrees higher than 5 meters and a canopy
cover of more than 10 %, or trees able
to reach those thresholds in situ,
excluding land that is predominantly
under agricultural or urban land use."
based on it the data was collected formore than 10% canopy cover.

behavior change in this sector. We recommend
collaborating with the EUDR so as to make
improvements that can fully harmonize to the best
efforts of the parties involved.

6

Traceability (Section
3.3)

I am not sure
Yes.
Strongly
disagree.
Polygongeo-referencing
requirements under EUDR is often too challenging to
implement especially for companies with complex
supply chains. Significant amount of human resources
are required to manually map production units andsuch mapping is also not easily accessible for nonproducer entities which is in-scope of this criteria.
EUDR compliance should be recommended as a matterof best practice, but flexibility should be afforded forentities that have administrative challenges incomplying with EUDR's traceability requirements.
I agree single-point georeferencing
While companies are currently working to ensure their
EU volumes are EUDR compliant, this rarely comprises
a company’s full sourcing/supply. This means thatcompanies don’t have systems in place to meet thisgeolocation criteria for their non-EU volumes, as aresult, in reality this criteria will not be achievable forthevastmajorityofcompanies.
Approaches which incentivize companies to shiftsourcing away high-risk areas to avoid risk areas or
green-picking suppliers, does not lead to sectoral
progress for not yet DCF volumes (in high risk areas), as
companies lose their commercial leverage to drive
positive change in these areas. These high-risk regions
will continue to supply unsustainable volumes toleakage markets with less stringent sustainability
requirements.
We would also like to point out unintended
consequences such as excluding independent
smallholders from supply chains as a result of thestringent geolocation requirements of the EUDR. For
further details, please refer to the discussion paper
published by IDH and Proforest in 2022
(https://www.proforest.net/fileadmin/uploads/profor
est/Photos/Publications/IDH_Forest_Positive_Options_Policypaper.pdf)
For a proposed alternative approach please find ourcomments under section 4.
yesThis is a voluntary certification scheme
for the entities that want to reflect they
are sourcing deforestation andconversion free agri-food commodities.
Considering the priority to address thedeforestation in the agricultural supply
chains and need for full traceability, theCriteria sets the requirement for thecommodities covered in EUDR andcommodities originating from the highrisk region to be traceable togeolocation of the original production
unit (polygon for more than 4 ha andsingle- point georeferencing for lessthat 4 ha). For commodities originatingfrom low-risk traceability a bandwidth
till 1st of Jan 2030 is provided after
which full traceability is required, tillthen traceability to the country of origin
or primary processing facility isrequired. No changes in therequirement

Yes, although this might be challenging for companies
to comply with for commodities not considered undera company's deforestation free policy but selectedunder this Criteria's commodity eligibility requirement.
We acknowledge that this makes sense and have beendeveloping our own tools for georeferencing. We are
adopting a polygon approach in all cases, that said, a
single point for a small-scale operation would allow fora focused analysis of satellite data and other externalsignals during the MRV process. It will be important toallow for ease of inclusion of small-scale farmers who
do play a critical role in this sector.

7

Due Diligence (Section
3.4)

Consider ground truth observations for sub 4ha
measurement needs.
No, all countries should bare the same costs ofcertification and due diligence.
Yes, absolutely.
Agree.
I agree demonstrate the traceability of commodities tothe relevant point of origin
Please see our comments on section 3.3. for high-riskcountry
traceability
criteria.
For low risk countries, alternative language could be
used, ‘traceability to production area at scale needed
to confirm to deforestation or conversion since cut-off
date’ as this will vary dependent on commodity or
region. We are supportive of approaches that do notprioritize resources for granular traceability in low risk
areas, as this diverts resources away from where they
may be most impactful (e.g. in high risk areas).
yes8

Monitoring (Section
3.5)

This requirement will require a wholesale change insupply chain governance and practice. It is logical, butmaybe not feasible in all cases if companies are any
now beginning to prepare themselves for such arequirement.
We agree and are extremely supportive of using thisstandard as a mechanism (alongside the EUDR
regulations) to drive a transition towards an industry inwhich these due diligence systems are the norm. One
note we are cautious of is the reference to considering
all commodities from high-risk countries that are notplaced on the EU market as low-risk. We understandthe intention to align with EUDR regulations in theinterest of global harmonization; however, this is a
global issue and global markets are at play here. We
need to maintain a global mindset.
yes
Yes.
Disagree. Such available monitoring systems in themarket are currently not set up for EUDR-type
traceability all the way to point of origin especially forentities with complex supply chains.
I agree
Please see our comments on section 3.3. for high-riskcountry traceability criteria.

Further due diligence is required is forthe commodities originating from highrisk regions to ensure the status ofdeforestation and conversion free. We
have included the suggested changes in
the wording, but the requirements
remain unchanged.

For high-risk regions entities are
required to demonstrate that there is amonitoring system in place to monitor
the geolocated production land plots
for deforestation and conversion. The
tools and methods for monitoring
system varies based on their availability,
the commodity to be monitored, scale
and type of production therefore
entities can adopt based on theiryes, though there should be distinctions be made byfirm type (see criteria for SMEs by OECD/ FAO 2023)
The EUDR does not provide adequate detail on whatparameters such a monitoring system must cover, inorder to comply. Further clarity would be given if the
EU were to publish a tool containing all required
parameters for monitoring. I would recommend that
CBI include more details on what a monitoring system
could cover as an annex. For example, defining
common indicators that companies should document
and track, types of data controls to put in place toensure data are robust and trustworthy, etc.

9

Reporting (Section 3.6)

Yes, at this point as there is no true global standard forthese monitoring systems, it is important to be
inclusive of a wider range of approaches. That said, it
will be the responsibility of the approved verifiers toclosely review and approve these systems. Gathering
data from external signals through Anthro’s
environmental intelligence can be supportive here to
cross-reference this monitoring effort.
yes
Yes.
Agree, however flexibility should be given on masking
supplier information for data protection and if theinformation is commercially sensitive.
Estoy de acuerdo
Agreement with annual basis of disclosing to provide
reports + tier 1 supplier lists. Also important that scopeis part of the disclosure, e.g. is it for all volumes(including complex supply like embedded soy,derivatives, smallholders etc.)
yesrequirements. It is beyond the mandateof the Climate Bonds to prescribe amonitoring system. As long as theoutcome (no deforestation andconversion) is clear and verifiers canassess the methodology used, it shouldbe left to companies. No change in therequirement, however, some changes
have been included in the wording of
Criteria.

The Climate Bonds requires annual
reporting for all the certified entities.
Maintaining consistency, the Criteria set
the requirement for annual reporting
and therefore no changes were
included. The applicant entities are
required to share the information listed
in the verification section of the Criteria
to the verifiers which also consists ofrevealing data calculation for scoping of
the commodities based of their share inprocurement spend.

Yes, I agree with this requirement

10

Verification –Requirement (Section
3.7)

We agree this is feasible and disagree that this isrobust. We feel that annual reports are far too
infrequent to share the granularity needed to truly
track these impacts. At Anthro, we are adopting realtime reporting protocols for full visibility. We know thisis not yet feasible to require from a system of individual
approved verifiers. In that case, we would ask if there
could be a streamlined process such that quarterly oreven biannual (twice a year) reports could be made?
We’re willing and able to help support more frequentand verifiable reporting practices.
yes
Yes.
Agree.
absolutely I agree
Please see our comments on section 3.3. for high-riskcountry traceability criteria (e.g. avoid only cleaning
supply chains, instead driving pro-active engagement
to stop deforestation in high risk areas).
yes - vi. should specifically ask for choke points,
likelihood and impact of risks
Yes, I agree with these requirements

The requirements of the verification arestated in the Criteria. As this is a pastlooking Criteria and any entity that canreflect that all the agri-foodcommodities (given the requirement ofmateriality) that are sourced are freefrom deforestation and conversion after
31st dec 2020 are eligible to certify. we
acknowledge the importance of proactive
engagement
tostopdeforestation, and these can be
included in the long-term plan for theentities.

11

Verification – Sampling(Section 3.7)

We agree this is feasible and disagree that this isrobust. We feel that annual reports are far too
infrequent to share the granularity needed to truly
track these impacts. At Anthro, we are adopting realtime reporting protocols for full visibility. We know thisis no+[@[Verification – Requirement (Section 3.7) ]]t
yet feasible to require from a system of individual
approved verifiers. In that case, we would ask if there
could be a streamlined process such that quarterly oreven biannual (twice a year) reports could be made?
We’re willing and able to help support more frequentand verifiable reporting practices.
yes
Yes.
Agree.
I agree
Please see our comments on section 3.3. for high-riskcountry traceability criteria.
yes, adequate to differentiate high low risks; improvebyfollowing
handbook:
https://www.fao.org/3/cc6595en/cc6595en.pdf
If the lower threshold is 10%, what is the upper
threshold? I anticipate that companies would want toknow whether they would be subject to an audit for
15% or 20% of purchased volume and suppliers, and on
what grounds this requirement would be higher fortheir
specificcase.
When an auditor is randomly selecting 10% ofpurchased volume and suppliers from a database, howwill the volume selection be conducted? Would any
volume listed (e.g. 15%) be subject to selection (at leastin part) no matter the absolute value and materiality
within the commodity group? For example, a supplier
might account for 15% of the total purchased volume
for a commodity, and the sampling could select 33% of
their volume to form part of the 10% coverage needed.
I would just like to ensure that the sampling approach
does not exclude large volume suppliers, because their
total contributions exceeds the 10% coverage.
As noted above, we recommend more frequentverification at least at the quarterly level or the
biannual (twice a year) cadence also consideringseasonal impacts. We recognize how the low-risk origin
countries are being identified, and especially if the 10%
canopy cover risk assessment is adopted, we guide
towards increased traceability. Given that thisverification process will be established for the high-riskcountries, it is absolutely feasible for the low-riskcountries and simply offers greater accountability forall.
Considering that the risk assessment is taken during
2018-2022, which is directly amidst the COVID-19
pandemic, it may also be a variable landscape in whichcountries would soon fall from the low-risk ranking to
the high-risk ranking and as such it will be important tocapture the fine-tuned data. Why not use the same
verification process for all countries? This also
streamlines the development of verification tools(even though we would be asking for more data). If it is

The verifiers adopts sampling techniqueduring the verification process and it
varies case by case. For the Agri-Food
DCF Sourcing Criteria, it was importantthat the selected sample reflects thetrue representation of the livestock (ifpresent) and nature of the supply chain.
Therefore, these requirements wereset. The verification process is for all
same countries however, for high-risk
regions verifiers may want to increase
the sample size and therefore no upper
threshold is included. No changes in therequirement.

deemed not possible to begin in this way, this could beconsidered as an expansion for the standard in the next
version.

12

Third-party certification(Section 3.8)

yes
Yes
Should also consider flexibility to accept mass balance
supply chains.
I agree
We are supportive of an approach in which companies
can choose between a variety of implementation
options to demonstrate DCF (e.g. negligible, 3rd party
certification, remote/field monitoring) – more details
can be found in Proforest’s generic DCF methodology(https://www.proforest.net/resources/publications/d
eforestation-and-conversion-free-methodology/). For
example, if the company’s volumes are Certified underan acceptable scheme and Chain of Custody (thecertification scheme has an appropriate mechanism toconfirm no deforestation/conversion post cut-off date
and to monitor remaining natural vegetation), wewould not request the additional requirement to also
remotely monitor these volumes (as the monitoring isalready covered through the certification scheme).
yes, this proxy seems ok for transition period

13

Human Rights (Section
3.9)

Given it's widespread usage in agricultural and forestry
value chains, I would say this is an appropriate
mechanism and substitute.
Yes, we encourage engaging third-party certifications
to also boost and expand that network, which will
overall catalyze the transition of the global sector. Thatsaid, we agree that all equivalent due diligence, risk
assessment, and MRV criteria as outlined above (and in
the standard) are met. Approved verifiers will need toreview these reports in detail and from there could also
identify approved third-party certifiers that deliver
sufficient, high veracity data.
yes
Yes
Agree.
I agree

The mass balance approach monitors
the certified total amount of thecommodity and ensures the selling ofthat certified amount. But it allows
mixing of the non-certified and certified
products, making it difficult for thepurchasers to identify what proportionof the product they bought is certified.
It also poses challenges in identifying
the original source of the commodities
and doesn’t ensure physical traceability
to a specific land management unit andthe geolocation information is lost in
mixing. Therefore, is not allowed underthese Criteria. Companies can use athird-party verification as a substitutefor this certification if it meets all therequirements set under these Criteria.

Included provision for smallholders

Please find below, some relevant resources linked toProforest’s Human Rights risk approach work
• Human Rights Policy Commitments Guide(https://www.proforest.net/resources/publications/h
uman-rights-policy-commitments-guide-14946/)•
Grievance
management
guidance(https://www.proforest.net/fileadmin/uploads/profor
est/Photos/Publications/HR_Grievances_Guidance_fo
r_Buyers.pdf)• Human rights due diligence library of tools - The Palm
Oil
CollaborationGroup(https://palmoilcollaborationgroup.net/hrdd-libraryof-tools)
seems encompassing, yet not sure this is feasible (notedistinction of type of enterprise by OECD)
Yes

14

Enabling Activities(Section 4)

Yes, this is critical to include and a major consideration
for intersectionality. Human rights and conservation
are inextricably linked. This list of principles andconventions is a great starting point. Our team has
been referencing this list compiled in reference to the
UN SDGs: https://sdg.humanrights.dk/en/goals-andtargets
blockchain
Inclusion in the local regulation.
I agree
The AFi common DCF methodology, is an aligned
approach across the sector (https://accountabilityframework.org/news-events/news/afi-releasesupdated-common-methodology-for-corporatereporting-and-assessment/). It offers a set ofrecommended metrics that can be used to assesscompany policies, actions, performance and progress
towards DCF supply chains. This standardized
approach also recognizes the need to track progress onvolumes which are not yet-DCF (or volumes withunconfirmed status) to progress towards DCF.
Our recommendation is to incentivize actions thatdrive progress towards DCF, particularly for complex
supply chains (e.g. smallholder volumes, derivatives
and embedded soy) which face additional challenges toachieving DCF. One of these approaches to drive
progress includes investing in risk mitigation strategies
through landscapes approaches, please see here for
moredetails(https://www.proforest.net/fileadmin/uploads/profor
est/Photos/Publications/ClimateNaturePeople_Global
Study.pdf). It is critical to incentivize approaches withmechanisms to support companies in demonstratingthese actions that drive on-the-ground positive
impacts.
Listed below are additional actions which support nonDCF volumes to progress towards DCF:
• Supplier engagement to work with non-compliant
suppliers•
Workingwithsmallholders• Working collaboratively in production landscapesandsectoralinitiatives• Increasing traceability, physical certification,
monitoring
https://www.fao.org/3/cc6595en/cc6595en.pdf

Not applicableIndustry coalitions with commodity-specific roadmaps
and investments in collective action programs.

15

Overall Framing for DCF
Sourcing

Yes, we can nominate ourselves (Anthropogenic) as a
traceability software and data platform. We are highly
supportive of this idea to essentially acknowledge data
providers and the supporting ecosystem of players thatwill enable the verification process. We are interested
in joining the Technical Working Group and cancontinue to share other actors in the space as we comeacross them.
Congratulations, Excellence. !
For more details on commodity specific approaches,
please find below the CGF-FPC DCF methodologies for:
•
Soy
–
annex
2
(https://www.theconsumergoodsforum.com/wpcontent/uploads/2023/02/CGF-FPC-Soy-RoadmapGuidance.pdf)
•
Palm
Oil
(https://www.theconsumergoodsforum.com/wpcontent/uploads/2023/10/CGF-FPC-Palm-Oil-DCFMethodology-v0.pdf)
•
PPP
–
annex
4
(https://www.theconsumergoodsforum.com/wpcontent/uploads/2023/02/CGF-FPC-PPP-RoadmapGuidance.pdf)
stronger focus on risk-based due diligence, integrationof GRI criteria in line with OECD handbook:https://www.fao.org/3/cc6595en/cc6595en.pdf
We appreciate that you went a step further than EUDR
to call out conversion-free in addition to deforestationfree sourcing, and actually really appreciate yourdefinitions for the scope of land-use conversion anddeforestation considered here. That said, the title does
come across as quite confusing because you lead withthe solo term “deforestation”. A more positive title
would be “Forest Cover & Land-Use Sourcing Criteria”→ which transforms the focus to be positive. It isclearly related to any deforestation-free standard
given the focus on forest cover. This is more
explanatory of what is being audited.

The title of the Criteria is 'Agri-Food
Deforestation and Conversion Free
Sourcing' reflecting that deforestation(and degradation) and conversion ofother natural ecosystem are covered
under these Criteria.

Summary table for public consultation feedback
No.

Topic

Feedback Received

Response1

Entitiesin(Section 2.1)

ScopeParticipants have mixed opinion around selection of
the entities that falls under the scope of these
Criteria, 50% of the participants agreed with theflexible approach however suggestions include
having a fixed threshold or to include every company
generating revenue from agriculture.

We have included some changes here based on the suggestion to use a fixed
threshold. Any agri-food entity that generates at least 50% of its revenue fromagriculture is eligible to certify under these Criteria. We understand theimportance of engaging all the supply chains and we acknowledge that every
company making revenue from the agri-food supply chain should target toachieve deforestation and conversion free supply chains. However, underthese Agri-Food DCF Sourcing Criteria entities will be certified as based on the
check carried out for agri-food commodities that accounts for more than 1%of the agri-food procurement spend. Therefore, including entities generatinga smaller amount of revenue from agricultural supply chains indicatescertifying those entities as Deforestation and Conversion free sourcing
without checking their association with deforestation and conversion in othersupply chains. This is a first step in addressing emissions in the supply chains.

2

Materiality of thecommodities in scope(Section 2.4)

Suggestions from participants includes increasing thethreshold from 1% to 5%, decreasing the thresholdfrom 1%, include agri-commodities in non-food items
and having a defined list of commodities to coverunder these Criteria.

This is an Entity Certification. These Criteria are to certify the agri-food entities(except the producers) having deforestation and conversion free supply
chains. The aim is to cover all agri-food commodities and therefore non-foodagri-commodities are currently excluded and no fixed list of the agri-foodcommodities to be covered under these Criteria is provided. All the agri-foodcommodities the applicant entity is dealing with will have to undergo audit(based on their contribution to procurement spend). There are mixedsuggestions to increase and decrease the threshold from 1% and therefore to
maintain a balance and to clearly define the boundary of the commodities toundergo audit we will go with 1%. No changes in the requirement.

3

Cut-off date (Section
3.1)

Participants agree with the selected cut-off date

The cut-off date "31 December 2020" is in alignment with AFi and EUDR. In
the background paper we have discussed cut-off dates set by different
initiatives and guidelines and need to align the global efforts. No changes in
the requirement.

4

Risk
Classification
Methodology (Section
3.2 and Appendix 1)

50% participants are in agreement with the risk
classification methodology. Suggestions includes
using a commodity specific approach. Few
participants shows their concern around theeffectiveness of the Global Forest Watch (GFW)
database and use of deforestation data as a proxy forconversion and degradation.

The current approach used for risk classification is based on data availability
and constraints of different land used models. As these Criteria covers all agrifood commodities, therefore carrying out a commodity-specific risk
classification which requires wider database and modelling cannot be done at
this stage. There is lack of database on degradation and conversion andtherefore, the data for deforestation is currently used as proxy for both. We
acknowledge the limitation the methodology has, and we have also discussed
it in detail in the background paper. These lists can be modified as more data
becomes available. For the countries currently not covered under the list, theverifiers will use the similar methodology to assess the risk. Further risk
assessment to be carried out but the companies under due diligence.

5

Risk
Classification
Methodology (Section
3.2 and Appendix 1)2

Participant who is not in agreement suggested to use
30% rather than 10% canopy density but also agrees
that using 30% will be a diversion from global
harmonization.

The definition of forest states "Land spanning more than 0.5 hectares withtrees higher than 5 meters and a canopy cover of more than 10 %, or trees
able to reach those thresholds in situ, excluding land that is predominantly
under agricultural or urban land use." based on it the data was collected formore than 10% canopy cover.

6

Traceability
3.3)(Section

More than 50% participant are in agreement with thetraceability requirement. The concern for nonagreement is that geolocation is not feasible for thecompanies and it might result in exclusion ofsmallholders.

This is a voluntary Certification scheme for the entities that want to reflect
they are sourcing deforestation and conversion free agri-food commodities.
Considering the priority to address the deforestation in the agricultural supply
chains and need for full traceability, the Criteria sets the requirement for thecommodities covered in EUDR and commodities originating from the high-risk
region to be traceable to geolocation of the original production unit (polygon
for more than 4 ha and single- point georeferencing for less that 4 ha). For
commodities originating from low-risk traceability a bandwidth till 1 January2030 is provided after which full traceability is required, till then traceability
to the country of origin or primary processing facility is required. No changes
in the requirement

7

Due Diligence (Section
3.4)

More than 50% participants are in agreement withthe due diligence requirement. One suggestion to
add/change the wording for low-risk countries:'traceability to production area at scale needed toconfirm to deforestation or conversion since cut-off
date’. Another suggestion is for countries to bare thecost of the due diligence system.

Further due diligence is required is for the commodities originating from highrisk regions to ensure the status of deforestation and conversion free. We
have included the suggested changes in the wording, but the requirements
remain unchanged.

8

Monitoring
3.5)(Section

More than 50% participants are in agreement withthe requirement of monitoring system. Concern isaround the availability of such system and non-clarity
for the system to be used under EUDR.

For high-risk regions entities are required to demonstrate that there is amonitoring system in place to monitor the geolocated production land plots
for deforestation and conversion. The tools and methods for monitoring
system varies based on their availability, the commodity to be monitored,
scale and type of production therefore entities can adopt based on theirrequirements. It is beyond the mandate of the Climate Bonds to prescribe amonitoring system. As long as the outcome (no deforestation and conversion)is clear and verifiers can assess the methodology used, it should be left tocompanies. No change in the requirement, however, some changes have been
included in the wording of Criteria.

9Reporting (Section 3.6)

All participants agreed to the reporting requirement.
However, suggestion includes to increase the

The Climate Bonds requires annual reporting for all the certified entities.
Maintaining consistency, the Criteria set the requirement for annual reporting
and therefore no changes were included. The applicant entities are required
to share the information listed in the verification section of the Criteria to theverifiers which also consists of revealing data calculation for scoping of thecommodities based of their share in procurement spend.

frequency and have scope as a part of the disclosure,e.g. is it for all volumes (including complex supply likeembedded soy, derivatives, smallholders etc.)
10

Verification–
Requirement (Section
3.7)

Participants are in agreement and one suggestion to
includepro-active
engagement
tostopdeforestation.

The requirements of the verification are stated in the Criteria. As this is a pastlooking Criteria and any entity that can reflect that all the agri-foodcommodities (given the requirement of materiality) that are sourced are freefrom deforestation and conversion after 31 dec 2020 are eligible to certify. we
acknowledge the importance of pro-active engagement to stop deforestation,and these can be included in the long-term plan for the entities.

11

Verification – Sampling(Section 3.7)

Participants are in agreement with the samplingtechnique to be used for verification. Suggestions
includes setting an upper threshold, increase thefrequency of the verification and to follow same
verification process for all the countries.

The verifiers adopts sampling technique during the verification process and it
varies case by case. For the Agri-Food DCF Sourcing Criteria, it was importantthat the selected sample reflects the true representation of the livestock (ifpresent) and nature of the supply chain. Therefore, these requirements wereset. The verification process is for all same countries however, for high-risk
regions verifiers may want to increase the sample size and therefore no upper
threshold is included. No changes in the requirement.

12

Third-party certification(Section 3.8)

Participants are in agreement. Suggestion to include
the mass balance, allow companies to choose
between a variety of implementation options todemonstrate DCF.

The mass balance approach monitors the certified total amount of thecommodity and ensures the selling of that certified amount. But it allows
mixing of the non-certified and certified products, making it difficult for thepurchasers to identify what proportion of the product they bought is certified.
It also poses challenges in identifying the original source of the commodities
and doesn’t ensure physical traceability to a specific land management unit
and the geolocation information is lost in mixing. Therefore, is not allowed
under these Criteria. Companies can use a third-party verification as a
substitute for this certification if it meets all the requirements set under these
Criteria.

13

Human Rights (Section
3.9)

Around 90% participants are in agreement.

Included provision for smallholders

14

Enabling(Section 4)

Activities

No agreement was required, this question was only
for suggestion

Not applicable

15

Overall Framing for DCF
Sourcing

One participant raised the concern that "the title
come across as quite confusing because you leadwith the solo term “deforestation”".

The title of the Criteria is 'Agri-Food Deforestation and Conversion Free
Sourcing' reflecting that deforestation (and degradation) and conversion ofother natural ecosystem are covered under these Criteria.