CHAIN OF CUSTODY REQUIREMENTS

7.1   >   7.2   >   7.3   >   7.4   >   7.5  > 7.6


7.1

Traceability

Each economic operator in the chain of custody is responsible for the data supplied in the product declarations submitted to the next economic operator.

 
Indicator
Standard
Notes
7.1.1. Final certified products can be traced from the dispatch area of the processor until next owner

≥ =90% traceable*
*) The auditor takes a sample of 10 and when this sample shows 0 or 1 defects this will be qualified compliant and reported >= 90 % a.. When more than 1 defect is found the criteria score will be reported < 90% and the criteria will be checked for non – compliant.

The processor keeps track of the transport until delivery to the next owner of the product
Next owner signs for reception of the product and takes over responsibility from the processor
7.1.2. Each following link in the chain keeps track of the products
≥ =90% traceable
Each economic operator can trace back 1 step and trace forward 1 step.
 

 

7.2

Identification, traceability and verfication of sustainability characteristics

The sustainability criteria are listed in the Bonsucro production standard and are in compliance with the EU RED art. 17. For each consignment at any stage of the chain of custody sustainability characteristics need to be identified and assigned to the consignment.

 
Indicator
Standard
Notes
7.2.1. Each consignment has a unique identification #

≥ 90% identified

The identification can be both physical and administrative and in that case needs to be identical
It is allowed to have only administrative control of consignments
7.2.2. Each consignment contains a specification with at a minimum the data specified in Appendix 4 of the Mass Balance Chain of Custody Standard
≥ 90% with specification
When a next owner is accepting ownership for a consignment without specification or incomplete specification he takes responsibility to supply this information by himself
BONSUCRO EU REQUIREMENT
7.2.3. Consignments clearly specify the scope of compliance:
Non compliant
Bonsucro compliant
Bonsucro EU compliant
Major
No false claims
Eg. non compliant may not show up as compliant or Bonsucro compliant may not show up as Bonsucro EU compliant
By taking ownership over consignments that are non compliant the owner takes full responsibility over the consignment and needs to provide evidence of compliance before a claim of compliance can be made
BONSUCRO EU REQUIREMENT
7.2.4. Each Bonsucro EU compliant consignment contains a specification with at a minimum the data specified in appendixes 4 and 5 of the Mass Balance Chain of Custody Standard. GHG emissions figures must be calculated according to specifications laid down in appendixes 2 and 3 of the same document.
Major
Only for option Bonsucro EU in addition to the above data for Bonsucro
 

 

7.3

Control of Mass Balance System

The mass balance system, according to article 18 of the EU RED means a system in which “sustainability characteristics” remain assigned to “consignments” and evidence showing compliance with these characteristics are required and need to be documented and recorded. See Appendix 6 of the Mass Balance Chain of Custody Standard for principles.

The mass balance system must be controlled
a) in periods of time in which the balance of Bonsucro certified sustainable product versus not sustainable product should be equal or positive at the moment of balance. Evidence of balance must be recorded and must be verifiable by periodic balance reports over that particular period, showing all inputs, mixes, conversions, stocks and outputs.

The accounting year for Mass Balance includes a full annual harvest cycle, which is not allowed to be divided over 2 accounting years.

 
Indicator
Standard
Notes
7.3.1. The accounting system for the control of the mass balance is documented and mass balance records and data are maintained on a daily base and verifiable

≥ 90 % validated within 1 week

The economic operator may collect data and records within intervals as documented in procedures on site before entering these in the accounting system; data must be updated and verifiable within one week the latest, preferably within 36 hours
7.3.2. Validation of data before official entering in the accounting system. The management representative is responsible for validation, as indicated in Bonsucro Certification Protocol.
≥ 90 % validated within 1 week
Once validated the data entered can not be changed (are fixed within the software) or are clearly marked as validated showing data and time.
The management representative has physically signed the documents or either approved though digital procedures for validation.

BONSUCRO EU REQUIREMENT
7.3.3. Mass Balance “in time periods” shows over the time period the evidence that the balance of certified sustainable product versus not certified sustainable product is at least equal or positive.

The management representative or a third party (RE the above art 7.3.2) is responsible for validation

Major
in case of absence of data or longer than 1 period (max month) no report of balance

Major
in case of negative balance and no actions taken to correct within next period

The interval for the documented periodic mass balance reports is maximum 1 month.
Each period (month) balance must be validated by the management representative. Cumulative month to date mass balance report must be recorded showing the development of the mass balance data during the harvest period and/or accounting year.

BONSUCRO EU REQUIREMENT
7.3.4. The mass balance is based on sugar or alcohol weight or volume calculation based on sampling and analysis by a qualified laboratory; using normative methods and results of measuring are validated by an accredited laboratory preferably (but not mandatory) holding an ISO IEC 17025 accreditation
(RE: to reference list ISO IEC 17025 for the accreditation of testing laboratory).

Metering and weighing equipment in the operations or used by subcontractors for volume or weight input and output of the mass balance is required calibration with a minimum frequency of 1 x year by a calibration and testing organisation preferably (but not mandatory)accredited for ISO IEC 17025.

Major
In case of total failure to calibrate

Minor
Otherwise:
too late > 1 year

Not complete

Volumes may vary because of concentrating or diluting processes.
For this reason and effective mass balance on volumes only is not possible.

The basis for the balance is the combination of weight (mass), volume, and the content of the consignment in either % of sugar (w/w) or alcohol % (v/v)

Through conversion calculations sugar may be expressed in alcohol vice versa

Permitted methods for the calculation conversions are given in the Bonsucro P&C chapter 3 and in the Mass Balance Choc Appendixes 1, 2, 3

Methods applied require documentation and validation and cannot vary within one accounting year.

7.3.5. The total mass balance in the period is reliable within a tolerance of +/- 5% calculated over the total sugar and/or alcohol content input - output
In case of losses or spillage this is counted for
By products are also counted for as these may contain sugar and/or alcohol rests that require to be reported
≥ 90 % of mass balance within tolerance
The mass balance is the result of all inputs and outputs in a period. Many data entries occur and laboratory testing takes place.
Given the fact that volumes, weight and % have tolerances the total result needs to give confidence that the whole accounting, measuring and testing system is reliable;
Exceeding the level of 5% difference in balance might indicate errors that require correction.
 

 

7.4

Control of Consignments

Key for identification and traceability of sugarcane during the production stages, logistics and trading is to keep control over the consignments and keep records of production data including, volumes, weight, products specifications, sugar % and alcohol %, density etc. (minimum set of data as specified in the criteria) together with the records about the sustainability characteristics assigned to the consignment.

 
Indicator
Standard
Notes
BONSUCRO EU REQUIREMENT
7.4.1. Consignments have a unique # for identification; the # identifies the accounting year for the harvest, the unit of operation (farm, site etc.) and the # is generated by the accounting system in sequence of time when the consignment was first entered in the system.
Each time when new consignments are created either by mixing or splitting new unique consignment # will be generated for the mixture or for each consignment that has been split off. Each new # contains references to the previous consignment # (see below mixing and splitting of consignments how to address these operations).
From the consignment #, date and time the physical location of the consignment can be retrieved

Major
System is not operational

Minor
≥ 90% compliance

 

The consignment and all attached information can be identified and traced back and forward by using the consignment #
 

 

7.5

Control of mixes of consignments

It is common and often inevitable in sugarcane production, logistics and trade that consignments are mixed. Mixing of consignments with different sustainability characteristics is allowed and also the mixing of not sustainable with sustainable consignments is permitted as long as the balance (see 7.3) of sustainable product keeps positive. A mixture can have any form where consignments would normally be in contact, such as in a container, processing or logistical facility or site (defined as geographical location with precise boundaries within which products can be mixed). There are rules to be respected in order to control the mixing of consignments that are specified in the indicators on the right.

 
Indicator
Standard
Notes
7.5.1. A new consignment # is generated for a mix; procedure is equal to the individual consignment

≥ 90% compliance

It depends on the accounting system how the mix will show up and which # is possible in terms of characters
Some systems allow for indicators identifying a mix
7.5.2. The separate sizes and sustainability characteristics of each individual consignment remain assigned to the mixture
≥ 90% compliance
See Appendix 6 of the Mass Balance Chain of Custody Standard

7.5.3. Provides the sum of all consignments withdrawn from the mixture to be described having the same sustainability characteristics in the same quantities , as the sum of all consignments added to the mixture

≥ 90% compliance

See Appendix 6 of the Mass Balance Chain of Custody Standard

7.5.4. To avoid double counting: at the moment the individual assignments are assigned to the mixture they will automatically booked off from the previous # as “sold” to the new # of the mix

≥ 90% compliance

The way this happens may be different depending on the possibilities of the accounting system

 

 

 

7.6

Control of splitting of consignments from mixtures

Once the sustainability characteristics have been assigned to consignments the values can be calculated and added to the specification of the consignment. The calculation methods, terms, definitions, tools and default values are listed and referred to in the indicators on the right.

 
Indicator
Standard
Notes

7.6.1. Any consignment split off from a mixture or split off from an individual consignment requires a new #; use procedure 7.5 new consignment

≥ 90% compliance

It depends on the accounting system how the split will show up and which # is possible in terms of characters
Some systems allow for indicators identifying a new consignment as split from previous mixes
7.6.2. The sustainability characteristics of the mixture consignment remain assigned to the consignments# that have been split off in proportion of the volume that has been split off
≥ 90% compliance

See Appendix 6 of the Mass Balance Chain of Custody Standard

NO AVERAGING

7.6.3. To avoid double counting: at the moment a new unique nr. has been assigned to the to the split this will automatically be booked off from the previous # from the mix as “sold” to the new # of the split consignment.

≥ 90% compliance

The way this happens may be different depending on the possibilities of the accounting system.

 

 

  Bonsucro is an Associate Member of the ISEAL Alliance