Cristobal Flores Fuentes
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Sample Size Calculation:
1. High-Risk Area – 67 Suppliers
According to Annex A (Table 1), for regions with more than 50 suppliers and high-risk classification, the square root of the total number is used.
√67 ≈ 8.18 → 9 suppliers (rounded up)2. Medium-Risk Area – 49 Suppliers
For regions with fewer than 50 suppliers and medium risk, the base is 20%, then reduced by 15%:
20% of 49 = 9.8
15% reduction: 9.8 × 0.85 = 8.33 → 9 suppliers (rounded up)3. Low-Risk Area – 144 Suppliers
For low-risk areas, the square root applies, with a 30% reduction:√144 = 12
30% reduction: 12 × 0.70 = 8.4 → 9 suppliers (rounded up)
Cross-Checks for Non-Sampled Suppliers:Even if some suppliers are not visited on-site, cross-checks are mandatory. These include:
Review of purchase contracts to verify inclusion of sustainability clauses.
Comparison against public blacklists, such as:
Environmental embargoes or deforestation alerts.
Records of slave or child labor.
Conflicts with indigenous or traditional communities.
Use of satellite imagery (e.g. PRODES Amazon, PRODES Cerrado) for deforestation detection.
These checks help confirm the supplier’s eligibility even if they are not selected for site visits.Why Sampling Is Relevant & Example of Non-Compliance:
Sampling ensures that sustainability monitoring is both risk-based and representative, while remaining cost-effective and logistically feasible. It allows auditors to draw valid conclusions without assessing every supplier, provided that the sampling logic is sound and verified.Practical Example of Non-Compliance:
A supplier in the high-risk Cerrado biome is found to have cleared native vegetation in March 2021, violating the deforestation cut-off date of 31 December 2020.
Corrective Action Expected:
The economic operator must:
Immediately exclude the supplier from their certified volume and update the traceability registry.
Initiate a review of all other suppliers in the same biome, considering possible systemic risk.
Develop and implement a corrective action plan that may include:
Training on land-use legality.
Collaboration with NGOs or technical providers to restore the affected area if feasible.
Record the non-compliance and actions taken in the management system for traceability and audit trail.
Failure to take appropriate action may prevent the economic operator from maintaining or obtaining their MRV verification status.Based on questions, here my answers for each of them:
1. When verifying compliance with the deforestation cut-off date established under the ProTerra MRV Standard v1.0, the auditor must follow a structured evidence-based approach. The cut-off date is 1 January 2020, as defined under Item 4.1 of the Standard. No deforestation or conversion must have occurred on land used to produce certified commodities after this date.
To verify compliance, the auditor must request and review documented evidence, spatial data, and monitoring records that demonstrate that the area of production was not deforested or converted after the cut-off date. The following types of information and documentation are required:
– Geolocation and Polygon Data
According to Indicator 4.1.1, all direct suppliers must provide the location of the farm through geolocation coordinates. This includes:
Latitude and longitude of production plots.
Polygon boundaries of the productive area (shapefiles or equivalent geospatial files).
Auditors should request:
Maps in GIS-compatible formats (e.g., .shp, .kml, .geojson).
Documentation of how polygons were generated (e.g., field GPS survey, satellite-derived mapping).
Evidence of date of collection and responsible personnel.– Historical Land Use Analysis
To determine whether deforestation or conversion occurred after the cut-off date, auditors must request:
Historical satellite imagery from multiple years, including 2019 and 2020.
A Land Use Change or geospatial assessment conducted by the economic operator or a third party.
Verification that land in use was already converted before 1 January 2020.
Annex A of the MRV Standard recommends using satellite imagery with adequate spatial resolution (e.g., 10m or better), and records should include:– Deforestation Risk Assessment
Under Indicator 3.3.h), the operator must conduct a risk assessment for deforestation, especially in sensitive biomes such as the Amazon or Cerrado. The audit team should request:
Risk categorization documentation by region or biome.
Internal policies or protocols for monitoring conversion risk.
Justifications for classifying areas as low, medium, or high risk.2. When suppliers lack traceability information related to the deforestation cut-off date (1 January 2020), the ProTerra MRV Standard mandates a risk-based and corrective approach. As an auditor, the first step would be to assess whether the supplier is classified as a core supplier and whether they are located in a high-risk biome such as the Amazon, Cerrado, or transition zones (see 3.10).
For such suppliers, the economic operator must present a medium-term action plan (as per Item 3.10) aimed at achieving traceability.
In the meantime, no claims of verified volumes can be made for commodities linked to non-traceable suppliers, and those volumes must be excluded from the MRV balance sheet. The auditor would also verify that the operator maintains a supplier engagement strategy, with documented efforts to build supplier capacity and phase out non-compliant sources where needed.
If traceability remains unresolved, these suppliers may be considered a blocking factor under the verification process, especially if they are in high-risk zones.3.
– Soil Degradation and Erosion
Soil degradation—including loss of topsoil, compaction, and erosion—is a widespread concern in crop production. The guidelines recommend implementing soil conservation practices, such as contour planting, reduced tillage, and maintenance of ground cover, to minimize runoff and retain soil fertility.– Water Resource Contamination
Excessive use of fertilizers and pesticides leads to leaching and runoff, contaminating surface and groundwater. The document highlights the risk of eutrophication, disruption of aquatic ecosystems, and human health exposure. Recommended practices include nutrient budgeting, Integrated Pest Management (IPM), and buffer zones between fields and water bodies.– Biodiversity Loss and Habitat Conversion
Expansion of cropland into natural ecosystems results in habitat fragmentation and biodiversity decline. The guidelines stress the need to avoid land conversion in ecologically sensitive areas and promote landscape-level planning and corridor conservation to preserve wildlife habitats..– Agrochemical Misuse and Persistent Residues
The improper use of pesticides can lead to long-lasting environmental contamination and affect non-target organisms. The guidelines recommend using FAO-classified and WHO-approved substances, adopting calibrated application technologies, and ensuring safe storage and disposal of agrochemicals..To organize the sampling of verification activities for this client, I would apply a risk-based and biome-sensitive approach, in line with ProTerra MRV Standard v1.0, Item 3. Specifically, I would prioritize biomes with greater risk of non-compliance, namely the Amazon, Atlantic Forest, and Transition zones. While 5,931 suppliers in the Cerrado have known traceability, only 86 (Transition Cerrado/Atlantic), 145 (Amazon), and 205 (Atlantic Forest) are likely to pose higher environmental and social risk.
1) Accordingly, sampling would focus proportionally more on these high-risk zones, ensuring that geo-coordinates, land-use history, and deforestation data (e.g. via PRODES, MapBiomas) are validated. I would include:
– At least √n direct suppliers per biome (rounded up), following good sampling practice,
– Additional purposeful samples where prior non-compliances or data inconsistencies have been flagged.2) To guarantee the avoidance of double counting, especially for volumes linked to certified outputs or traceability declarations, I would:
– Cross-check purchase orders, volume declarations, and SAP records with delivery notes and invoices per supplier and per period,
– Validate that unique supplier IDs in the SAP system are consistently used and traceable across documents,
– Review the organization’s volume reconciliation reports and ensure that declared input volumes match output volumes (adjusted for conversion factors),
– Confirm that the same lot or volume has not been claimed under multiple certification or reporting frameworks, a frequent risk with overlapping schemes.3) To detect and prevent triangulation (e.g., commodities from Amazon being sold as Cerrado origin), I would:
– Perform geolocation spot-checks on declared supplier farms, comparing SAP-registered locations against field data or remote sensing imagery,
– Analyze transport routes, storage facilities, and aggregation points to detect discrepancies between source and delivery points,
– Request proof of origin certificates, contracts, or field-level declarations,
– Interview logistics personnel and randomly selected suppliers to confirm that no rerouting or relabeling occurs.As an auditor conducting a ProTerra MRV audit and verifying compliance with Item 3, I would like to evidence for a robust and clearly documented supply chain management system, supported by top management. I would expect to review the organization’s deforestation and supply chain policy, verifying that it is appropriate to the scale and risk of their operations (Indicator 3.2), that it is publicly available, and that it has been effectively communicated to internal and external stakeholders.
Key evidence would include:
1. Documented procedures for supply chain mapping and risk assessment (Indicators 3.3a–g), including maps, sourcing lists, and geolocation data for raw material origins.
2. Deforestation risk assessments, with references to tools such as satellite imagery (e.g. PRODES Amazon or Cerrado) and context-specific data (3.3b).
3. Human rights risk assessments and a mechanism to distinguish between risks the operator can control versus those they can only influence (3.3e).
4. Mitigation plans, risk prevention strategies, and support mechanisms for suppliers (3.3g–i).
5. Evidence of legal compliance (3.4), training and resourcing (3.5), grievance mechanisms (3.9), and a functional traceability and chain of custody system (3.10–3.11).
6. Monitoring reports, including data on performance indicators and outcomes (3.6), and procedures to address non-conformities (3.7).When dealing with suppliers lacking traceability, my approach would rely on Indicator 3.10e, which requires the economic operator to establish an action plan to bring these suppliers to a traceable level in the medium term. I would look for evidence of outreach, training, contractual requirements, and progressive targets aligned with regulatory frameworks such as the EU Deforestation Regulation (EUDR). In the absence of immediate traceability, the plan must demonstrate accountability, timelines, allocated resources, and supplier engagement efforts. This allows verification to proceed while still encouraging systemic improvement.
Hello everyone, this is Cristobal Flores, I am chilean and certification auditor since 23 years. I am certification auditor for sustainable standards such as “MarinTrust”, “ASC” and “BAP”. I am attending this course because I would like to extend the scope of my competencies . Thanks!
Based on the questions given as part of the case study, my answers are defined according to following:
1. How would the sampling of core suppliers be calculated when planning an audit as a CB?
According to the ProTerra Certification Protocol and traceability requirements (Principle 10), sampling of core suppliers (e.g., farms) must be risk-based and representative. Given the total number of suppliers (Amazon: 148, Caatinga: 12, Cerrado: 731), the sampling must reflect the distribution and operational relevance. Priority should be given to:
– Amazon and Cerrado biomes due to higher deforestation risk (linked to Principle 4).
– The volume or percentage of supply each farm contributes.
– Random and risk-based sampling approach is required, including remote document review and field verification of land use change, pesticide use, GMO control, and social compliance (Principles 2, 4, 5, and 6).
– A minimum sample size is often determined using the square root method but ProTerra expects risk-based justification, especially when over 890 farms are involved.2. Considering the certification cycle, how would the audits related to this economic operator be planned (sequence of audits) and when would the certification decision be made?
The ProTerra certification cycle involves:
Initial desk review, including documentation from farms, ports, and industrial site.
Onsite audits:
Level I (selected farms and volume),
Level II (ports—at least one from each Port Authority),
Level III (industrial processing site in São Paulo).
Subcontracted services (security, cleaning) must be verified for social compliance under Principle 2.
The certification decision is issued only after closing all non-conformities from all levels and confirming the effective implementation of traceability (10.1), segregation (10.3), and GMO controls (Principle 5). The entire supply chain must demonstrate compliance before issuing certification.3. What considerations would be made for the next certification cycle?
For the next cycle:High-risk farming areas (e.g., Amazon and Cerrado) should be prioritized again.
The port handling 60% of exports must be reassessed due to material relevance.
Volume sheets (Appendix 4) must be updated to reflect accurate mass balance.
New suppliers must be risk-assessed (Principle 5 and 10.1.4).
Evaluate carry-over volumes, traceability documentation (10.1.5), and any operational changes.
If any core suppliers change land use, new remote sensing or satellite imagery verification may be required (Principle 4).
GMO testing plans must align with Appendix A and sampling guidance.4. How many ProTerra certificates will be issued as a result of a positive certification audit?
Only one ProTerra certificate will be issued, covering the entire scope of operations—from farms (Level I), through transport and ports (Level II), to processing (Level III)—as long as traceability is maintained across the chain of custody and no split ownership occurs. This is aligned with the Chain of Custody brochure (p. 2–5) and Principle 10, which states that the certification is system-based and linked to the entire supply chain of the economic operator. If a separate legal entity owns one of the ports, an additional certificate may be needed.Hello everyone, this is Cristobal Flores, I am chilean and certification auditor since 23 years. I am certification auditor for sustainable standards such as “MarinTrust”, “ASC” and “BAP”. I am attending this course because I would like to extend the scope of my competencies . Thanks!
As an auditor, verifying compliance with Principle 4 of the ProTerra Standard requires a structured, evidence-based assessment across three key components: (1) land use and forest conservation (4.1), (2) biodiversity protection and management (4.2), and (3) environmental and social impact management (4.3). For each, I would triangulate documentary, geospatial, and field-level evidence.
For indicator 4.1.1, I would review satellite imagery and aerial photographs from reliable sources (e.g., Sentinel, Landsat, Global Forest Watch, or Agroideal).
These must demonstrate no land use conversion of HCV areas after 31 December 2008. I would also request geo-referenced polygon maps and legal land ownership documents. In cases of deforestation between 2009–2020, I would verify if the company followed the “Restoration and Compensation Procedure,” checking for documented action plans, third-party technical reports, stakeholder engagement (incl. FPIC), and performance indicators, as per ProTerra’s requirements
.For 4.1.2, I would confirm adherence to stricter national regulations or international conventions. This includes validating land use permits, legal conversion records, and absence of any illegal clearing through interviews and legal documentation checks.
For 4.2.1, I expect to find a biodiversity management plan developed with external experts. Site visits should confirm physical protection of riparian zones, wetlands, steep slopes, and legally preserved areas. If restoration is required, I would verify implementation via field inspection and photographic records.
For 4.2.2 and 4.2.3, I assess compliance with protections for endangered species and control of invasive species. Evidence includes wildlife monitoring logs, staff training records, and pest management procedures.
For 4.3.1, I verify that a comprehensive ESIA was conducted with expert participation, and that management plans are available online. I review public versions, interview responsible staff, and check for updates after operational changes.
Finally, for 4.3.2, I review maps showing native vegetation and confirm implementation of protection/restoration plans. Field inspections must match documented boundaries and actions.
Throughout, I require documentation, geospatial analysis, interviews, visual inspections, and cross-referencing with national law and ProTerra’s procedures. Compliance is never based on declarations alone—objective, triangulated evidence is mandatory for each core indicator.
