Jiansheng Li
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Hi everyone,
This is Jiansheng Li from China. I am an organic inspector and FairTSA auditor. I recently completed the ProTerra MRV Training Course and gained valuable knowledge. Thank you to the ProTerra Foundation team for your support.
I look forward to deepening my understanding of the ProTerra V5.0 Standard and continuing to enhance my auditing skills.
A1:
High Risk
Square(67)≈8.18=9(round up)
Medium Risk
49*0.2*(1-0.15)≈8.33=9(round up)
Low Risk
Square(144)*(1-0.3)≈8.4=9(round up)A2:
The contracts of the entire supplier list are checked for sustainability obligations and compared with public lists or official information:
1.environmental embargoes or crimes;
2.slave and child labour;
3.conflicts with indigenous or traditional communities; and
4.deforestation. When assessing deforestation, auditors shall use satellite imagery of adequate resolution. In those areas where context-specific data is available, it should be used (e.g. PRODES Amazon, PRODES Cerrado).A3:
1.To ensure that the operations within the economic operator’s purchasing system are in accordance with the management system-related procedures, objective evidence must be obtained from a number of cases.
Supplier sampling is a cornerstone of the ProTerra MRV Standard’s verification process, enabling efficient assessment of supply chain sustainability. It adopts a risk-based approach to focus resources on higher-risk elements—such as suppliers in deforestation-prone regions or those with limited traceability—while ensuring representation across geographical areas and biomes. This method verifies the effectiveness of the economic operator’s management system (e.g., risk assessments, monitoring procedures) and confirms no systemic non-compliances among suppliers, such as undetected deforestation or human rights issues. By using minimum sample sizes (e.g., 20% for under 50 suppliers or the square root for larger numbers, adjusted by risk level), sampling promotes due diligence aligned with regulations like the EU Deforestation Regulation (EUDR), balancing cost, coverage, and compliance.
2.Concrete Case: Base on the risk assessment and sampling of suppliers, an on-site audit is carried out to a soybean farm in Brazil’s Amazon biome, satellite imagery and public data (e.g., PRODES Amazon) reveal that the farm cleared 200HA nature forests in 2024 to expansion of agriculture production—after the December 31, 2020, cut-off date—violating Section 4.2.1 on environmental responsibility.
The auditor issued a major non-compliance in a close meeting, which triggers immediate purchase-blocking of the farm’s soybean in to supply chain, the respective lots and quantity of soybean is also clear identified and notified to the downstream buyers.
Expected Root Cause Analysis and Corrective Action Plan:
Root Cause Analysis:
In 2023, the outdated cultivated and tillage measures lead the decrease of soybean harvest quantity but higher prices in market. Due to the supply requirements and pressures, the farmers in farm decide to deforestation in 2024, expansion for agriculture area for higher quantity.
Corrective Action Plan:
1.Immediately block non-compliant lot of soybean, notified to the downstream buyers. Then shifting to certified low-risk sources. Provide emergency support, such as technical assistance to help farm suspend cultivation.
2.The Economic operator conduct independent farm-level surveys, to map and geolocate the 200HA expansion polygons in satellite image within 60 days. Cooperate with local government to implement a restoration initiative, such as reforesting the cleared areas with native species under ProTerra’s forest-positive guidelines. This part should be finished in next 6 months and monitored via annual satellite checks.
3.Economic operator contact the farm to provide training and financing plan to farms, offer technical support for precision agriculture (such as mechanized tillage, rotation plan, drip irrigation, and soil fertility management measures), reduce land demand, and ensure stable yields, in case the repeat of NC. This part should be finished before next cultivated seasons.
The economic operator appointment a responsible person and schedule a monitoring plan for progress.
In the end, submit the Root Cause Analysis and Corrective Action Plan together with the evidence (such as notification to downstream buyers of the non-compliance lot of soybean, the 200HA expansion polygons in satellite image, the agreement of reforesting with local government etc) within 60 days to the verification body.In Proterra MRV Standard 4.1.1, Children under the age of 15 (or any higher age set by national law) shall not work.
In some Fair Standard, the youths younger then 15 years old can work on the farms own by their family (Smallholder), when the work light and age-appropriate, closely supervised and does not occur after dark.
In ProTerra MRV Standard, there also have smallholders, how is ProTerra Foundation consider the situation above?A1:
Document Review: Checking farm map, farm records (harvest records, inputs records and invoices) in last 6 years till 31/12/2020, check if the farm map’s boundary have been changed after 31/12/2020, any quantity significant increase after 31/12/2020.
Geographic Analysis: Reviewing satellite imagery in 31/12/2020 and now. Comparing the farm’s acreage changed. And check the public datasets for evidence of post-cut-off deforestation from 31/12/2020 till now.
Interviews and Site Checks: Interview with the farm staff if their farm have extent since 31/12/2020, if yes, which boundary have been changed , analysis and compare if it involved with deforestation activity.
A2:
1.Review the supply chain map and try to collect the trace and geographic map information, like lot number, commodity volume, geographical sourcing area or region from 2020 to 2025. The lot number may indicate the harvest year, commodity volume and harvest quantity’s increase or decrease may indicate the farms acreage change , the geographical area may lead to different risks about deforestation and human rights etc.
2.Conduct a risk assessment, check in the public lists for environmental embargoes, conflicts with indigenous communities, or human rights issues, and check if the suppliers are listed. According the geographic area or region, category the suppliers in low, medium or high risk area. For European operators or exports, check if the suppliers keep any declaration or approve documents that they comply with EUDR Article 10 requirements.
3.Conduct an on-site audit for the suppliers with no traceability information, interview with the workers who had worked many years in the farm, interview with them about the farms
4.Issue an NC and let the economic operator to develop a action plan. Comprehensively analysis the risk and communicate the the economic operator, they need to traceability upgrade, enhance the monitoring to make the suppliers sustainable, the economic operator may providing resource or technical help for the suppliers to developing their traceability and fix the gaps with standard, make the suppliers chain sustainable. Block purchases from non-compliant lots until resolved within 60 days.
5.Annually review and update plans, escalating systemic issues to ProTerra Foundation.
A3:
1.Soil Conservation and Management. In China, agricultural practices involve frequent tillage, and knowledge about reduced-till and no-till farming methods and soil health has yet to become widespread. In northern China, the cold climate makes it difficult to maintain cover crops during winter.
2.Water Management. In China, only a small portion of agricultural land has undergone organic or GAP certification. In conventional agricultural practices, few measures are implemented for water conservation or controlling water pollution.
3.Pesticides Use and Management. Conventional agriculture relies heavily on herbicides and chemical pesticides for pest, disease, and weed control, while making limited use of integrated agricultural practices such as crop rotation and selecting appropriate varieties.
4.Greenhouse Gas (GHG) Emission. Rice is a traditional native crop in East Asia, cultivated by farmers and farms in traditional method for thousands of years, resulting in significant methane production.A1:
1.Total suppliers: 6374, the extracted square root is 79.8, up to round is 80.
2.Risk-based allocation: From the situation we known, Cerrado have known traceability information, and after investigation on internet, we can define that Cerrado is Low Risk(risk coefficient 1.0), Caatinga and Atlantic forest are medium risk(risk coefficient 1.2), and Transition Cerrado/Atlantic Forest and Amazon are high risk (risk coefficient 1.5).
H risk:
Square(86)*1.5≈13.9=14
Square(145)*1.5≈18.06=19
M Risk:
7*0.2*1.2≈1.68=2
Square(205)*1.2≈17.18=18
L Risk:
80-14-19-2-18=27A2:
1.Check the SAP system if every suppliers and commodities have unique identification code, search the codes back and confirm if the supplier code is unique, and search the high risk products like soybean and its suppliers in SAP, compare the consistent with the formal List of Suppliers submitted by the Economic Operator.
2.Do trace back check of the transaction records (supply chain maps, invoices, products lots, quantities, Bill of Ladings, delivery records, farm geography maps) for the selected suppliers in Answer1.
3.Check the internal controls system of SAP, how the operator prevent the same lot of commodity being recorded twice.
4.Distinguish the commodities has different suppliers but have same trader or broker by supply chain map, and trace back to the same trader or broker, do a mass balance check of the trader or broker to prevent the fraud risk.
5.Check the SAP recorded commodities quantities and compare them with the actual storage quantities.A3:
1.Check for sudden volume increase change of specific suppliers or regions, which might indicate triangulation.
2.Check suppliers documentations for discrepancies like the company registered in Cerrado but the farms located in Amazon.
3.Verify the supply chains which are selected in Answer 1, trace back to the farms origin geography location in indeed in the declared region.
4.Check the invoices and transportation documents (bill of ladings, waybills, etc.) to see if the route from the farm to the facility is consistent.
5.Check the geography location map, and cross-check the official region boundaries to confirm the origin.
6.Check the whole supply chain’s invoices and contracts, if the origin of the commodity is consistent from farm to the final buyer.A1: My verification process of ProTerra MRV standard Item 3—Management System Requirements for Economic Operators would involve:
1. Document Review, which include if the Economic Operators have a defined and documented scope of the supply management system (policies and procedures for deforestation and supply chain policy, supply chain map, legal compliance, record keeping, appeal, non-conformity and segregation etc.), if the supply management system comply with ProTerra standard, the management system implementation result and the continuous improvement measures, collective the objective evidence like invoices, Bill of Lading, training records etc.
2. Interviews with workers, talking with Top management, workers, and suppliers to confirm understanding and implement of the standard.
3. Sampling, selecting a representative samples of suppliers (20% for fewer than 50 suppliers, Square root of the total number of for more than 50 suppliers) based on risk evaluation, and examination the traceability and segregation from transactions records.
4. On-Site/Remote Checks, inspecting facilities, check the geographical map, trace back the raw materials if from high-risk areas (e.g., South America) and ensuring compliance with regulations like the EU Deforestation Regulation (EUDR).
5. Non-conformities, if NC raised after the close meeting, must be corrected within 60 working days, and all records are retained for at least 5 years.
In summary, the audit would emphasize verifiable implementation over mere documentation, using a risk-based sampling to cover diverse suppliers and regions. If gaps are found (e.g., incomplete risk assessments), I’d issue non-conformities requiring evidence of correction before issuing a verification statement.
A2: The expect evidence when suppliers with no traceability information:
1. Immediately distinguish the commodities and suppliers with no traceability information, collect the formal list of suppliers, then distinguish the specific suppliers and commodities have no traceability information, calculation the volume percent of commodities have no traceability information, and check if the commodities have segregated and sold as ProTerra products or exported to EU.
2. Risk Assessment, implement a comprehensive risk assessment for the no traceable commodities and suppliers, e.g. risk of country origin, deforestation-free and legal status, local human and indigenous peoples rights situation etc, then identify the problem is a temporary gap or a systemic issue of the Management System.
3. Issued non-conformities, and let Economic Operators to define an action plan to work with these suppliers to bring them to a traceable level in the medium term.
