ASC Programme Centre Beta

Feed Standard Interpretation

Which Feed Standard Criterion does this apply to?

Criterion 5.1 – The UoC works towards a deforestation/conversion-free supply chain.

What is the intent of this Criterion?

The feed mill conducts further Due Diligence on primary plant raw material production and commits to transition towards deforestation and conversion free supply chains.

Which RUoC sections need considering?

4.1 Feed mill staff competency requirements

4.2 Ingredient Approval Process

Annex C Competency Requirements

How do I interpret the Requirements?

Public commitment and cut-off date (5.1.1)

A commitment could also be known as a policy or pledge.

The feed mill sets a cut-off date which is no later than June 2021. Clearance of natural forest or natural ecosystems after the cut-off date renders the affected area or production unit, and the primary raw material produced there, non-compliant with no-deforestation/conversion commitments. 

What do better practices look like?
Feed mills may wish to align their cut-off dates with the proposed EU Deforestation Regulation which sets a deforestation cut-off date of 31st December 2020 for soy and palm oil. 

A cut-off date of 1st January 2020 would align with global goals to halt deforestation by 2020, as specified in the New York Declaration on Forests and in Target 15.2 of the United Nations Sustainable Development Goals.

Plant supply chain categorisation (5.1.2)

For Category 2 ingredients, this applies to ingredients which collectively make up the majority of the total plant ingredient volume, i.e., ≥ 50%, after Category 1 (soy and palm) have been deducted. Individual plant ingredients with the highest volumes make up the collective majority volume. See the example tables below.

Table 28: Example Plant Category 1

Raw Material IngredientRaw materialPlant Ingredient CategoryReceived Quantity (tons)% of total Category 1
Soy protein SoyCategory 170,00093%
Soy oilSoyCategory 15,0007%
Total (tons) Category 175,000

Table 29: Example Plant Categories 2 and 3

Raw Material IngredientRaw materialPlant Ingredient CategoryReceived Quantity (tons)% of total excl. Category 1
Pea ProteinPeasCategory 230,00046%
Rapeseed OilRapeseedCategory 220,00031%
Linseed OilLinseedCategory 310,00015%
Maize GlutenMaizeCategory 35,0008%
Total (tons) excl. Category 165,000

Primary plant raw material production Due Diligence (5.1.3, 5.1.4, 5.1.5 and 5.1.6)

The feed mill follows the guidance for conducting Due Diligence under Principle 2. If using pathway 2, for ‘Step 2: Assessing the Risk’, the feed mill uses the following Indicators of low risk for the risk factor.

Table 30: Indicators of low risk for environmental risk factor of plant-based primary raw material

Risk FactorIndicator of low riskSources and processes used to assess risk
The risk that primary raw material originates from areas resulted from legal deforestation/conversion.The farm is not located near or within remaining natural forest land or other natural ecosystems (e.g., savannahs, grasslands, peatlands and wetlands).Geospatial dataValidation through site based ecological mapping, document review and interviews with key stakeholders
The farm is located in an area with a low rate/incidence of legal deforestation and/or land conversionRemote sensing (e.g. satellite or radar) data,Deforestation alertsFAO Forest Resources Assessment seriesIndependent or community forest monitors.Local communities, Indigenous Peoples and civil society organisationsCountry or landscape risk assessments.Information collected through grievance mechanisms
The extension of the production of the primary raw material is unlikely to cause deforestation or land conversion.Studies of deforestation drivers and monitoring, reporting and verifying (MRV) reports

Sources: OECD-FAO Guidance for Responsible Agricultural Supply Chains (2016)

What do better practices look like?
ASC has higher requirements for higher risk ingredients. For this reason, the plant ingredients have been divided into 3 different categories. Having traceability and information down to the farm level in order to perform plant risk assessments for category 3) is in many cases not yet feasible (due to small quantities and the inclusion of smallholders). Nevertheless, where this is possible, the Feed Standard intents to motivate such risk assessments through Indicator 5.1.4. It is likely that future versions of the Feed Standard will require the category 3) risk assessments to become mandatory, after which auditing would penalize high risk outcomes.

Note that if low risk cannot be demonstrated for Category 2) plant ingredients, they are still considered an eligible ingredient if they are covered by the public commitment and action plan to achieve low risk. If they are not covered by the public commitment and action plan, they cannot be sourced.

If low risk cannot be demonstrated for Category 1) plant ingredients (i.e., soy/palm oil), they are considered a non-eligible ingredient (can be used in Mass Balance Production Model feed but do not count towards the total mass balance eligible volume) if they are covered by the public commitment and action plan to achieve low risk. If they are not covered by the public commitment and action plan, they cannot be sourced.

Public Action Plan (5.1.7)

The feed mill sets a target date by which it intends to have fully achieved or adhered to its commitment (as stated in 5.1.1) as quickly as is feasible, while also recognising the importance of inclusion (e.g., smallholders) and potential differing capacities for implementation. If implementation is to be phased across different primary raw materials within each risk category or levels of suppliers, a time-bound schedule is specified per segment.

Cut-off dates and target dates

A feed mill has a March 2021 cut-off date and a January 2025 target date for their no-deforestation/conversion commitment. This signifies the following:

  • The cut-off date indicates that the primary raw material covered by the commitment may not be produced on land that has been subject to deforestation or conversion since March 2021.
  • The target date indicates that by January 2025 the feed mill commits to have fully achieved its commitment—i.e., to have no primary raw material volume in its supply chain that was produced on land subject to deforestation or conversion since March 2021.
  • To fulfil its commitment, by no later than January 2025 the feed mill would need to manage its operations and supply chain to avoid inclusion of material produced on land subject to deforestation or conversion after March 2021.

What do better practices look like?
A target date set no later than 2025 aligns with the Accountability Framework initiative’s (AFi) consensus recommendation that companies set a target date for eliminating deforestation and ecosystem conversion from their supply chains no later than 2025. This decision reflects the urgent need for action to avoid forest and biodiversity loss and reduce emissions in support of the Paris Agreement.

Due Diligence and Pathways Report (5.1.12)

Feed mills use the template provided to annually report to ASC an overview of the outcome of the Due Diligences carried out and the respective pathways chosen. 

Participation in multi-stakeholder platforms (5.1.13)

The Tropical Forest Alliance has several suggested platforms which may be relevant to the commodities/geographies used by a feed mill.

Auditing considerations

The auditor will verify the that the feed mill has made a public commitment as per the Standard Requirements and that the reporting requirements to ASC have been completed.

The auditor refers to the Due Diligence Sampling Calculator to determine how many DD assessment reports to sample from each pathway. For each report sampled, the auditor verifies the following:

  1. That the country/region of origin (if applicable) is as determined by the feed mill as per the following process:
    1. Review all available traceability documents, for example: bills of lading, invoices, delivery notes, purchase orders, and packing list/loading records for every change of ownership;
    2. If the raw material is sourced from a certified or scheme approved farm(s), then in place of point a), the auditor verifies the validity of all certificates of certified organisations in the supply chain that legally owned the certified products from the farm(s) to the mill (i.e., verify the Chain of Custody is maintained).
  2. That the risk level determined by the feed mill is supported by the Due Diligence pathway used and the evidence provided.
  3. That for ingredients determined not to be low risk, the feed mill has developed a public action plan to achieve its commitment (not applicable at initial audit).

The auditor will also verify that the feed mill is participating in a multi-stakeholder platform.

Useful resources

AFi guidance on cut-off dates: https://accountability-framework.org/operational-guidance/cutoff-dates/