Cover Acknowledgement 2 Table of content 3 1. Introduction 1.1 BONSUCRO Bonsucro is a global multi-stakeholder non-for-profit initiative dedicated to reducing the environmental and social impacts of sugarcane production while recognising the need for economic viability. The mission of Bonsucro is to achieve a sugarcane sector that is continuously improving and verified as sustainable by acting collaboratively within the sector and working to continuously improve the three pillars of sustainability: economic, social and environmental viability. Bonsucro aims to achieve this mission through providing the definition for sustainable sugarcane and all sugarcane derived products through a multistakeholder approach. Bonsucro also aims at ensuring the integrity of the implementation of the Bonsucro Production and Chain of Custody Standards, through the implementation of the Certification Protocol. 1.2 Objective of The Chain of Custody Standard The objective of this Bonsucro Chain of Custody Standard is to provide assurance that claims about the sustainable production of sugarcane and their respective derivatives can be tracked along the supply chain. It is aimed at Bonsucro members who wish to achieve certification. It is also used by Licensed Certification Bodies and auditors when carrying out certification audits. Finally it is aimed at the wider audience of the sugarcane sector and any other interested parties. The document shall be read in conjunction with the Guidance for the Bonsucro Chain of Custody Standard as this document contains additional explanations to support compliance with the indicators of the Chain of Custody Standard. 1.3 History of the Document 1.3.1 Version 4.0 In March 2014, upon the recommendation of the Bonsucro Secretariat, the Board of Directors agreed to start the revision process of the Bonsucro Chain of Custody Standard and Guidance. The Board instructed the Secretariat to follow the Standard Revision Procedure set up in line with the ISEAL Code of Best Practice for Standard Setting. The Secretariat called for one representative of each class of membership to form the Standard Revision Taskforce (SRT). The SRT first met remotely in September 2014. The SRTF was given the task to draft the new version of the Bonsucro Chain of Custody Standard and Guidance. Each meeting was minuted and minutes were made public on the Bonsucro website. Description about the entire process to be added 4 Revision round Date Description of amendment A June 2010 B July 2010 Draft version send to Bonsucro EU Sub Committee Final version approved by Bonsucro Management Committee C December 2010 Revision made based on compliance with EU RED D February 2011 Revision made based on compliance with EU RED Draft version 4.0 November 2014 First draft open for public consultation Draft version 4.1 June 2015 Second draft open for public consultation To be continued This document is written in the English language. Bonsucro does not assume any liability for errors or misunderstandings introduced when this document is translated into other languages. Bonsucro Standards are reviewed at least every five years. The next review is scheduled for XXXX. 2. Scope This Chain of Custody Standard offers two scopes for certification: 1. “Bonsucro”: compliant with Bonsucro requirements 2. “Bonsucro EU”: compliant with Bonsucro requirements PLUS additional requirements that are needed for EU RED compliance (in line with the EU Renewable Energy Directive (RED) 2009/28/EC and the EU Fuel Quality Directive (FQD) 2009/30/EC) and those that are required for certification of sugarcane derived wastes and residues as feedstocks. Within the Bonsucro Certification System documents (i.e. Standards, Guidance, and Certification Protocol) the extra Bonsucro EU requirements are clearly marked. For certification against Bonsucro EU, the Bonsucro requirements PLUS all additional EU RED requirements must be met. Achieving Bonsucro EU certification is equivalent to achieving Bonsucro certification. Whereas the contrary does not apply; achieving Bonsucro certification is not equivalent to achieving Bonsucro EU certification. 3. Referenced Publications Guidance to the Bonsucro Chain of Custody Standard X Bonsucro Production Standard v4.01 September 2014 5 Bonsucro Certification Protocol v4.1 September 2011 Bonsucro Calculator v4.05 January 2015 Claims and Labelling; Logo Use requirements document v5.02 January 2014 EU Directive 2009/28/EC (RED) on the promotion of the use of energy from renewable sources EU Directive 2009/30/EC (FQD) as regards the specification of petrol, diesel and gas-oil and introducing a mechanism to monitor and reduce greenhouse gas emissions ISEAL Code of Good Practice for Setting Social and Environmental Standards v6.0 December 2014 ISO/IEC 17065:2012 – Conformity assessment – Requirements for bodies certifying products, processes and services ISO/IEC 17021:2011 – Conformity Assessment – Requirements for bodies providing audit and certification of management systems PAS2050:2008 – Specification for the assessment of the life cycle greenhouse gas emissions of goods and services Requirements for the operation of the Bonsucro Credit Trading System v1.2 April 2014 4. Definitions Normative references for definitions referring to: ISO 9000:2005; ISO 14001:2004; ISO IEC Guide 17000:2004; EU RED (2009/28/EC); EU FQD (2009/30/EC); CEN/TC383 Bonsucro certified members: Bonsucro members who are in compliance with the Bonsucro Certification System. Cane supply area: area which a mill defines as the farms/estates supplying cane for the purposes of certification. Certification Body: i.e. Conformity Assessment Body; Body that performs the audit Note 1 - An accreditation body is not a conformity assessment body (ISO/IEC 17000:2004) (Source: Adapted from ISO/IEC 17011:2005) Chain of Custody: the supply chain of a product including all stages from the feedstock production up until the release of the product for consumption. Client: next legal owner of the product in the Chain of Custody. Consignment: quantity (e.g. batch, lot, load) of product mass with unique identification number and attached data specifying the product content in terms of kilograms (or tons of 6 sugar or litres/m3 of ethanol), the sustainability characteristics and greenhouse gas emission values assigned to that quantity in terms of EU Directive 2009/28/EC (RED) annex V. Conversion factors: are the ratio between the output material and the input material. Conversion factors will be specific to facilities and should be accurately documented in the mass balance system. Document: Information and its supporting medium. Note 1 - The medium can be paper, magnetic, electronic or optical computer disk, photograph or master sample, or a combination thereof; Note 2 - Adapted from ISO 9001:2000; ISO 14001:2004 Economic operator: Individual, company or organization which has ownership and/or control of sugarcane and/or all sugarcane derived products, from their origin to their market availability, for one or several steps in the supply chain. Note 1 - Organization is being used here as defined in ISO 14001. Intermediate product: Output from a unit process that is an input to another unit process or processes involving further transformation within the system. (Source: CEN/TC383) Internal Control System (ICS): A documented set of procedures and processes that defines how a supply chain certification system works, ensures that records are maintained, records internal audits and explains responsibilities. It defines which standards are applicable and ensures that non-compliances are dealt with according to a set of procedures and sanctions. Inventory Period: A consistent period over which physical Bonsucro certified product and sustainability data is reconciled. Unallocated sustainability data may be carried over to the next inventory period following mass balance rules. This period must not exceed three months. Finished product: Where no further modification occurs. Mass balance: A system for administratively monitoring the inputs and outputs of certified material/product throughout the supply chain. It allows for mixing of these materials/products at any stage in the supply chain, provided that the outputs of certified material/product do not exceed the inputs of certified material/products. Material conversion rates need to be included. Multiple sites: A group of sites that have a contractual link, a defined Central Office and a minimum of two participating sites. Such sites may be groups of refineries, food processors, etc, brought together under a Central Office and administered using an Internal Control System (ICS). Central Offices that also physically handle and/or process Bonsucro certified product or sustainable data are counted as both Central Office and a participating site. Reporting period: This will be one year, starting from certification date, unless otherwise agreed. Site: A single functional unit of an economic operator or a combination of units situated at one locality, which is geographically distinct from other units. 7 Supplier: Previous legal owner of the product in the Chain of Custody. Sustainability characteristics: States or properties as a means of judging whether or not a sustainability principle has been fulfilled. (Source: CEN/TC383) Traceability: The ability of each economic operator in the chain of custody to trace back sustainability criteria one step back to the supplier and one step forward to the client. Symbols and Abbreviations ChoC g GHG ha HCV kg kJ L MJ t y Chain of Custody grams greenhouse gas hectares high conservation value kilograms kilojoules litres megajoules metric tonnes year 5. Framework for auditing 5.1 The Bonsucro Certification System The Bonsucro Certification System consists of three main elements: 1- Standards: Bonsucro has developed two standards: o The “Bonsucro Production Standard” contains principles and criteria for achieving sustainable production of sugarcane and all sugarcane derived products in respect of economic, social and environmental dimensions. o The “Bonsucro Mass Balance Chain of Custody Standard” contains a set of technical and administrative requirements for enabling the tracking of claims on the sustainable production of Bonsucro sugarcane and all sugarcane derived products along the entire supply chain from fields to mill including transportation; through to production (e.g. conversion, processing, manufacturing, transformation), to warehousing, transportation and trade, to the use of sugarcane and all sugarcane derived products. 2- Guidance for implementation: Bonsucro has developed guidance documents for members that provide further information on how to become compliant with the Bonsucro Production Standard and/or Chain of Custody Standard. 3- Certification Protocol: Bonsucro has developed a Certification Protocol for auditors that lists the process and procedures for certification against the Bonsucro Standards. This includes: 1.) rules and requirements for independent Certification Bodies to audit against the Bonsucro standards, and 2.) audit procedures for independent Certification Bodies to verify compliance with the Bonsucro Standards. 8 Together, these three elements form the Bonsucro Certification System. As such, these individual documents must always be used in relation to each other. 5.2. Unit of certification All Bonsucro certified mills are required to certify to both the Production standard and this Chain of Custody Standard. In addition, any economic operator who physically mixes, splits and/or reprocesses Bonsucro certified sugarcane products and/or derivatives thereof must be chain of custody certified. The unit of certification is an economic operator, either the mill and its cane supplying area and/or the economic operator taking ownership and centrally managing mass balance with their storage and reprocessing or other facilities. The economic operator has the ultimate responsibility for compliance with the Bonsucro Standards and is the certificate holder. The cane supply area included in the unit of certification comprises the farms/estates supplying cane in conformity with the Bonsucro Production Standard. This may be all of the farms/estates supplying cane to the mill, or a lesser number. In the latter case only a respective percentage of the mill’s production would be considered as Bonsucro certified, and/or: The storage and reprocessing facilities included in the unit of certification comprises of the storage and reprocessing facilities procuring and/or supplying products in conformity with the Bonsucro Chain of Custody Standard. This may be 100% of the storage/reprocessing facilities procuring and/or supplying Bonsucro certified products, or a lesser number. In the latter case only the sites included in the central management of the mass balance system would be able to handle Bonsucro certified products. To guarantee that the sugarcane included in the unit of certification is actually processed by the mill, the mill must have a management system in place to ensure that the sugarcane processed at the mill is coming from a given field included in the unit of certification. If the economic operator is purchasing sugarcane derived products (including sugarcane wastes and residues) not produced within the unit of certification, for reprocessing or not, it shall demonstrate whether the sources of production fulfil the requirements of the Bonsucro Production Standard and/or Bonsucro EU Production Standard. Eligibility of wastes and residues for double counting against the EU RED is defined by each Member State and economic operators should seek additional guidance on this. A confirmed list of eligible materials does not exist but any violation of the requirement to avoid waste would render the material ineligible. Retailers and distributers of finished products, where no further modification occurs, do not need Chain of Custody certification. 9 Economic operators that repackage sugarcane products need Chain of Custody certification. 5.3. Certification process Audits are conducted where the mass balance is held. Only after certification (date when the economic operator starts to be listed at the “certified members” list at Bonsucro’s webpage) are economic operators allowed to start claiming about their purchase of Bonsucro certified products and/or sell Bonsucro certified products and claim it as such. Any claims must adhere to the Bonsucro Claims and Labelling requirements. In order to achieve certification with the Bonsucro Chain of Custody Standard: o Full compliance with indicators, except for indicator 5.1.3, in the case of Bonsucro Chain of Custody Certification, and o Compliance with all indicators, including indicator 5.1.3, is required for Bonsucro EU Chain of Custody Certification. A mill that applies for certification against the Bonsucro Production Standard must also apply for certification against the Bonsucro Chain of Custody Standard. A certificate can only be issued when the mill is found compliant with both Standards. A mill cannot be issued a Bonsucro Production Standard certificate without being in compliance with the Chain of Custody Standard. The result of the audit will be the possibility of claiming and/or selling a volume of Bonsucro certified products, according to the certified volume procured. The certification decision will be based on the audit report. Documents showing evidence with the indicators must be presented by the economic operator and verified during the audit process. The audit will be performed according to the frequency defined by Bonsucro in the Certification Protocol. The audit must be performed by Bonsucro licensed Certification Bodies. For more certification requirements see the Bonsucro Certification Protocol 10 6. Bonsucro Chain of Custody Standard Principle 1. Implementing Mass Balance Chain of Custody The unit of certification is an economic operator. Each step in the chain of legal ownership shall implement the requirements within the scope of their direct control. A separate certificate will be issued for each economic operator. It is possible for multiple sites to be included within the scope of a single certificate. Criterion 1.1. The economic operator shall implement the Mass Balance requirements within the scope identified Indicator 1.1.1 1.1.2 1.1.3 Standard Notes The economic operator shall identify the scope of the Mass Balance system. The economic operator shall define the unit of certification, including number of sites and the type of operations covered by the scope of their mass balance Bonsucro Chain of Custody In cases where the economic operator seeking or holding certification outsources activities to independent third parties (e.g. subcontracts for storage, transport or other outsourced activities) it shall ensure that such independent third parties comply with the intent and requirements of all applicable requirements of the Bonsucro Chain of Custody standard. Y/N An economic operator may opt for Bonsucro Chain of Custody Certification and/or Bonsucro EU Chain of Custody Certification. Y/N An economic operator with multiple sites must implement the mass balance requirements at the level of a single physical site. A mixture can have any form where consignments would normally be in contact. This could include a processing site or physical onsite storage, or be at a smaller unit such as an individual tank. Y/N Where storage is outsourced and is not located at the same geographical location, the economic operator must consider this as a separate site, and the balance of volumes in/out must be applied separately to this site. 1.1.4 All sites shall have an agreement with the economic operator requiring appropriate reporting and communication. Y/N Criterion 1.2 The economic operator has a system in place to implement the mass balance requirements 1.2.1 The economic operator shall have an appointed management representative with overall responsibility and authority for implementation and compliance with all applicable requirements of the Bonsucro Chain of Custody standard. Y/N 1.2.2 The economic operator shall establish, implement and maintain procedures and/or work instructions covering all applicable requirements of the Bonsucro Chain of Custody standard. The procedures and/or work instructions shall be according to the scale and complexity of the economic operator, covering all sites included in the scope. Y/N 1.2.3 The economic operator shall implement a centrally administered and documented record keeping system for all records and reports related to implementation of the Bonsucro Chain of Custody standard, including purchase and sales documents, training records, production records and volume summaries. The record retention period shall be specified by the economic operator and shall be at least five (5) years. Y/N 1.2.4 The economic operator shall undertake an annual internal review of performance, including the Y/N The management representative can have other roles/functions in addition to implementation of the Bonsucro Chain of Custody Standard, including responsibity for entering and validating data in the mass balance system and per sites. This is not the same thing as the third party surveillance audit. 2 effectiveness of quality management systems and the compliance of the sites with the requirements of this Standard. 3 Principle 2. Validating Bonsucro Data Criterion 2.1 The economic operator shall validate the Bonsucro data Indicator Standard Notes 2.1.1 The economic operator shall check the supplier contract, invoice and supporting documentation to ensure the supplied Bonsucro certified product matches the accompanying documentation and includes all information required in Appendix X, and where applicable for EU RED, Appendix Y. 2.1.2 Where applicable, the economic operator shall use conversion rates in order to calculate the equivalent output weight or volume associated with the received Bonsucro consignment. 2.1.3 The economic operator shall maintain the accuracy of any measuring equipment used. Y/N Validation is counted from the date the supplier invoice and/or supporting documentation is received. This includes checking the validity of the supplier’s Bonsucro ChoC certificate. Y/N Methodology for the calculation of conversion factors should be documented. Calculation of conversion factors should take into account the different processing steps involved and spills or losses, to ensure that disproportionate allocation of losses to non-certified product does not occur. Y/N Calibration of metering and weighing equipment in the operations or used by subcontractors for volume or weight input and output should be undertaken as per manufacturer’s guidelines. 4 Principle 3. Reconciling Bonsucro Data Criteria 3.1 The economic operator shall record and manage the Bonsucro data Indicator Standard Notes 3.1.1 The economic operator shall define and use a consistent point to identify when Bonsucro certified product enters the system. Y/N 3.1.2 The supplier invoice and/or supporting documentation shall be received within 30 days after the economic operator becomes the legal owner or physically receives the product. Y/N 3.1.3 The volume or quantity of the Bonsucro certified product received and the associated sustainability characteristics shall be recorded in the system, within one week, after validity has been confirmed. 3.1.4 3.1.5 Allocation of Bonsucro and Bonsucro EU RED data shall only be to products which are fungible with sugarcane-derived products. The economic operator shall define and use a consistent point to identify when Bonsucro certified product leaves the system. The date which product enters the system (i.e. is available for allocation) may not always be on the same day that the economic operator receives the product physically. Product entering the mass balance system can either be the date it is physically received, or the date where the economic operator takes ownership. Whichever approach used must be consistent for all consignments received under the same contractual terms. Y/N One week is counted from the date the supplier invoice and/or supporting documentation is received. The economic operator may collect data and records an input these at regular intervals (if set out in procedures) rather than as received. Y/N For example, data can be allocated to any type of ethanol (e.g. corn, wheat, sugarcane) or any type of sugar (cane, beet), provided they could be mixed (are ‘fungible’). Bonsucro data cannot be allocated to products which can’t be made from sugarcane, for example no Bonsucro data could be allocated to vegetable oil biodiesel or wheat flour. Y/N Product leaving the mass balance system can either be the date it physically leaves the site, or the date where the client takes legal title. Whichever approach used must be consistent for all consignments received under the same contractual terms. 5 3.1.6 The volume or quantity of the Bonsucro certified product and the associated sustainability characteristics leaving the system shall be recorded in the system within one week. 3.1.7 The economic operator shall undertake inventories of the input/output balance of the Bonsucro certified product at fixed regular intervals, not exceeding three months. 3.1.8 The volume or quantity of Bonsucro certified product received should be greater than or equal to the volume or quantity of Bonsucro certified product supplied to clients over a fixed inventory period of maximum three months. 3.1.9 Where the balance of inputs and outputs is positive at the end of the economic operator’s inventory period, sustainability data shall be carried into the next inventory period. 3.1.10 Sustainability data shall only be valid for three years at the economic operator or until the end of certification of the economic operator, whichever occurs sooner. Y/N Y/N Y/N Y/N Y/N One week is counted from the date the Bonsucro data leaves the system. The economic operator may collect data and records and input these at regular intervals (if set out in procedures) rather than as received. This includes checking the physical stock-keeping and the data stockkeeping. This is applied at the unit at which the economic operator is applying the mass balance system. All original information, e.g. initial date of entry into the system, will be maintained. Sustainability data shall only be allocated within three years or until the end of certification of the economic operator, after this point the data will expire and cannot be allocated to product. If an economic operator is not re-certified then the data not transferred to clients will be considered expired immediately. 6 Principle 4. Tracing Bonsucro Data Criteria 4.1 Sustainability characteristics of consignments are traceable within the economic operator’s mass balance system Indicator Standard Notes 4.1.1 Each consignment received shall be given a unique identification code at the point when it is recorded as entering the mass balance system. Y/N 4.1.2 Where a volume or quantity of Bonsucro certified product less than the volume or quantity of the initial consignment is allocated to a client, a new code will be generated for this consignment and a new code generated for the remaining data. Y/N Where a combined consignment is supplied to a client, the sustainability characteristics allocated shall only be grouped if identical. Y/N 4.1.3 It is not necessary for the unique identification code to remain assigned to the original physical consignment within the economic operator’s site. A combined consignment may be allocated several codes or a new identification code can be generated. It is not allowed to average GHG data when combining consignments. See Appendix Z 7 Principle 5. Identifying Bonsucro Data to Clients Criterion 5.1 Sustainability characteristics of consignments are identified to clients Indicator Standard Notes 5.1.1 Each consignment supplied to clients shall contain a specification with at a minimum the data in Appendix X. 5.1.2 Consignments supplied to clients clearly specify the scope of compliance: Bonsucro compliant, Bonsucro EU RED compliant. 5.1.3 (Bonsucro EU Chain of Custody only) Each Bonsucro EU RED compliant consignment contains a specification with at a minimum the data specified in Appendices X and Y. GHG emissions figures must be calculated according to specifications laid down in the Bonsucro Production Standard. Y/N Specification meeting the minimum data of Appendix X does not need to be sent with each consignment, if it is included in a contract. Y/N Y/N Only required for option Bonsucro EU RED in addition to the above data for Bonsucro. 8 Appendix X: Minimum data assigned to consignments for Bonsucro compliance Description of the raw material (sugarcane or sugarcane residues or wastes) The quantity, kg (tons) or litres (m3) Type of sugar (e.g. Pol, colour, sugar content in % w/w) or type of ethanol (e.g. alcohol content in % v/v) Evidence showing compliance with the Bonsucro (certificate number) Production Standard Buyer and seller contact information Appendix Y: Additional data assigned to consignments for Bonsucro EU compliance Evidence showing compliance with the Bonsucro EU (certificate number) Production Standard A GHG emission figure derived from Bonsucro Production Standard or BioGrace GHG calculation tool Country of origin Appendix Z: Diagram on no GHG averaging, mixing and splitting TO BE ADDED