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Bonsucro Production Standard and Calculator for Smallholder Farmers Public Consultation

Smallholder Production Standard and Calculator Consultation

Thank you for your participation in the consultation on the development of the Bonsucro Production Standard for Smallholder Farmers (“Smallholder Standard”) and Bonsucro Calculator for Smallholder Farmers.  The following is a draft version of the standard for public consultation.  The Smallholder Standard follows the Principles and Criteria published in the Bonsucro Production Standard as much as possible, initially launched in 2011.  The indicators and threshold requirements for performance have been amended to improve accessibility for the smallholder context. This is a very important process for standards revision to ensure stakeholder engagement and success of the document’s uptake. We value your feedback! 

The first consultation period is open from 15th December to 15th February.

It is important to use both the Standard and Calculator for reference to complete these questions.


Suitability Criteria and Review Conclusions on the Design of the Smallholder Standard and Calculator

  1. Standard is not clear in the requirements for smallholder farmers- it is a challenge to transfer them to individual fields: Changes made captured from feedback from using the standard, introduction of farm level input data in addition to the group
  2. Inability to improve practices in the field and/or how to do so: Acknowledgement that this might remain as an issue after launch
  3. Inability to collect data: Reduced from 111 data points to 25 for individual farm, 40 for group
  4. Inability to aggregate data to one single calculator once collected: Introduce sampling for farm data collection at the group level (no requirement to aggregate farm information)
  5. Lack of indicators on governance (as seen in peer standards on cooperative clear management structure): Key performance indicators for the group within the Smallholder Calculator and introduction of Principle 7: Organisation of Farmers
  6. Footprint indicators are not meaningful for smallholder farmers: Removed data collection for footprint indicators, but maintained key contributors to inform calculations at the regional/global scale
A summary of the consultation notes will be shared on the website once the consultation is closed, and individual comments (without identifying information) will be shared with the Smallholder Steering Committee in some cases for decision making on inclusion.
This question requires a valid email address.
6. Member/stakeholder category:

Each question or set of questions is preceded by a summary of changes, which summarises the modifications from the current Bonsucro Production Standard or Bonsucro Calculator in its interpretation for the smallholder context.


Summary of Changes

  • No separate guidance document, relevant clarifications for smallholder farmers have been incorporated into the “notes” section for each individual indicator. 
  • Principle 6 has been removed and relevant Annex 3 has been removed.  The uptake of the smallholder standard is expected mostly in countries which are not exporting ethanol to Europe as biofuel, so we do not foresee that this standard will be used to certify export of bioethanol for fuel use to the European Union in the immediate future.
  • NEW: Principle 7 has been added to include governance indicators for groups of smallholder farmers. 
  • NEW: Calculator has been revised and introduces input data for the group of farmers and for the individual farms to complete.
  • The proposed definition of smallholder farmer is defined in the introduction section, (individual ownership does not exceed 25 hectares). The standard requirements and completion of the Farm and Group calculator are further defined in Principle 7.

Do you agree with this proposed definition of smallholder farmers? The standard will apply for groups of smallholder farmers where the members meet the following criteria:

Smallholder Farmer: Farm size does not exceed 25 hectares per farmer. The farmer must be the decision maker for the majority of activities on the land and not regularly hire labour.

Should a group of smallholder farmers be able to apply for certification independently of the mill?

PRINCIPLE 1- Obey the Law

Bonsucro Production Standard summary: The current Bonsucro Production Standard requires legal compliance for a broad set of topics, documented ownership of land and water rights, and demonstrating no conflict of land and water rights.

Summary of changes:

  • Indicator “1.1.1 Compliance with national laws” has been amended to remove topics of legal compliance that are captured in other indicators in order to streamline this requirement and reduce overlap with other indicators.  For example, legal compliance is a requirement to comply with indicators on land and water use rights (1.2.1), High Conservation Value area protection (4.1.2), water extraction (1.2.1), operational health & safety (2.2.2), environmental permits for land conversion (5.7.1), working hours (2.3.2), minimum wage payments (2.3.1), and contracts (2.4.1). Therefore legal compliance has been specified to the following topics: Environmental (waste, pollution & environmental protection, nature conservation, water quality, energy, soil protection), Social (labour conditions and social wellbeing), and production (agriculture production practices and transportation).  
  • Removed indicators 1.2.2 and 1.2.3 and included requirements to demonstrate no conflicts on land and water title.  The reason for this is to allow for farmers that are not able to demonstrate land or water ownership due to informal use rights, but to contain the risk of improper land use by requiring that in the absence of demonstration of use rights producers can demonstrate no conflict.   
Do you agree with the proposed topics for legal compliance and are they relevant for smallholder farmers or group managers of smallholder farmers? 
Do you agree with the change to remove indicators 1.2.2 and 1.2.3 and subsequent incorporation of allowance to allow no demonstration of conflict as sufficient evidence of land rights? 

PRINCIPLE 2 - Respect Human Rights and Labour Standards

The Bonsucro Production Standard includes requirements for supporting implementation of the ILO labour conventions on child labour, forced labour, discrimination, and freedom of association and the right to collective bargaining.  This principle also covers labour rights including minimum wage payments, working hours, and presence of contracts.

Summary of changes:

  • 2.1.1 Minimum age of workers: clarified child labour definition in notes and specified that legal requirements or the ratification of ILO C138 the ratification of ILO C138, whichever is higher, form the age requirement. Previously the indicator specified “minimum age of workers”, which is not clear for family labour as “worker” is defined as someone employed (i.e. a child on a family farm is not a worker).  Now the proposed indicator is titled “Respect minimum age of workers and children on family farms”. The indicator now also specifies examples of hazardous work.
  • Changed indicator 2.2.1 on work related injuries.  The existing metric required tracking of hours and has provided confusion in the smallholder context for temporary workers.  Therefore, now the requirement is to track accidents and implement health and safety improvements where appropriate.  
  • Changed notes of indicators 2.4.1: verbal contracts are acceptable if legally allowed by law (this was always allowed in the Bonsucro Production Standard Guidance document).
  • A statement, “This indicator applies if there is presence of hired labour (either by the individual farm or as a shared service of the group or mill).” has been added to all indicators which are relevant for hired labour. The purpose of this is to reduce confusion in application for the smallholder context.  The statement has been added to the following indicators 2.1.2 (forced labour), 2.1.3 (discrimination), 2.1.4 (unions and collective bargaining agreements), 2.2.3 (personal protective equipment), 2.2.4 (health and safety training), 2.2.5 (drinking water), 2.2.6 (first aid), 2.3.2 (maximum hours worked), 2.4.1 (contracts).
  • Removed indicator 2.3.3 on overtime payment. In the smallholder context, where the baseline might be no tracking of hours or payment, we have chosen to focus on minimum wage payments instead of overtime payments.
Do you agree with the changes made to this section? 
Do you agree that the following indicators apply only for hired labour? 2.1.2 (forced labour), 2.1.3 (discrimination), 2.1.4 (unions and collective bargaining agreements), 2.2.3 (personal protective equipment), 2.2.4 (health and safety training), 2.2.5 (drinking water), 2.2.6 (first aid), 2.3.2 (maximum hours worked), 2.4.1 (contracts).

PRINCIPLE 3 - Manage input, production and processing efficiencies to enhance sustainability


Summary of changes:

  • Removed criteria 3.2 GHG emissions per tonne of cane because this is a footprint indicator.  However, calculations for supply can be done separately based on major sources of GHG emissions in cane which are kept in the input data for other purposes (fertilizer use, cane burning, productivity, etc.).
Do you agree with the proposed changes? 

PRINCIPLE 4 - Actively manage biodiversity and ecosystem services

Summary of Changes:

  • Indicator 4.1.2, introduced requirement that no conversion of HCV areas is effective from five years prior to certification in place of the 2008 cut-off date to improve auditability/accessibility of the requirement.
  • Indicator 4.1.3, removed requirement to publish a summary and edited topics to focus on use of integrated pest management, cane burning, soil, use of artificial fertiliser and water impact. The other topics have been removed as they are covered in different indicators (e.g. ecosystem service protection can be addressed by protecting soil and water quality, and climate change can be addressed by reduction of cane burning and use of artificial fertilisers).  “Use of crop chemicals” as a topic has been replaced by “Use of integrated pest management”. 
  • Indicator 4.1.4, title changed from “Ratio of fertilizer N and P applied (expressed in equivalent phosphate) to fertilizer N and P recommended by soil or leaf analysis (expressed in equivalent phosphate)” to “Application of fertiliser is according to recommendation” to increase clarity.
  • Indicator 4.1.5, group agrochemicals into two categories (pesticides and herbicides) to align with input data requirements in the draft calculator and limited reporting on other crop chemicals (certified producers reported an average 13% below standard of overall agrochemical use).
14. Do you think land use change is a risk to the protection of land with High Conservation Value and for smallholder farmers?
15. Are there any key topics missing in indicator 4.1.3 on environmental impact and management plan requirements (use of integrated pest management, cane burning, soil, use of artificial fertiliser and water impact)?
How can fertiliser best be captured in the farm calculator?
How can agrochemical application be recorded in the farm calculator?
18. Do you agree with the remaining changes?

PRINCIPLE 5 - Continuously improve key areas of the business


Summary of changes:

  • Indicator 5.1.1 has been removed and requirements on training have been captured in Principle 7.   
  • Indicator 5.2.1 has been removed in order to focus on one indicator for water consumption in addition to the environmental impact and management plan.
  • Indicator 5.2.4 has been removed in order to focus on one soil conservation indicator (mulching) in addition to the environmental impact and management plan.
  • Removed indicator 5.4.3 on recycling.  The purpose is that this typically depends on an available service out of responsibility from the smallholder farmer (e.g. metal recycling), and the focus for environmental impact by smallholder farmers will be captured in other indicators (4.1.3, 4.1.5, 4.1.6 for example). 
  • Removed indicator 5.8.2, “percentage of projects involving multi stakeholders where agreement has been reached by consensus driven process based on Free Prior Informed Consent (FPIC)”.  The principle of FPIC has been included in indicator 5.8.1 and indicator 1.2.1 to support the use of FPIC in the implementation of these indicators.
  • Indicator 5.6.1 on research and development has been removed and requirements for extension services have been captured in Principle 7.
  • Changed indicator 5.7.1 from “Percentage of greenfield expansion or new sugarcane project covered by Environmental and Social Impact Assessment” to “Land conversion by farmers complies with local or national law”. 
What is the best approach to be included for land conversion after the group has been certified?  Do you agree with the requirements in indicator 5.7.1 where legal compliance becomes the requirement (Environmental and Social Impact Assessment)?
Do you agree with the proposed changes?

Principle 6 – Additional Mandatory Requirement for Biofuels under the EU Renewable Energy Directive (2009/29/EC) and Revised Fuel Quality Directive (2009/30/EC)


Summary of Changes:

  • This principle has been removed. The Bonsucro Production Standard and Bonsucro Calculator can be used for complying with the Renewable Energy Directive and Fuel Quality Directive

EU RED: Do you foresee that this standard will be used to certify ethanol for export to the European Union (Principle 6)?

Principle 7 – Organisation of Farmers


Summary of Changes:

  • New indicators to build confidence in group management to support the process of compliance and organisation of smallholder farmers. 
Do you agree with the approach data collection and sampling? (all farmers to complete the farm calculator/diary independently or with an extension officer, third party auditor samples the group) Data can be gathered with alternative methods other than the calculator, as long as the data points are covered.
What is an effective ratio of extension agents to individual farmers (and should be required to comply with the indicator in the standard)?
Do you agree with the stepwise requirements for training and internal inspection?