Public NGO Statement on FEFAC Soy Sourcing Guidelines

FEFAC , the European Feed Manufacturers’ Federation, recently has issued a first version of its Soy Sourcing Guidelines (August 11, 2015). These guidelines are communicated as a “professional
recommendation” for a minimum norm to be applied by European companies sourcing soy. The guidelines are the basis for a benchmark of certification standards to determine if these standards
comply with their voluntary minimum norm for import. These standards can be company‐owned or, for example, multi‐stakeholder standards.

As NGOs who have given detailed input in the earlier draft of the Guidelines (in May 2015) we herewith communicate the following.

We support the effort of FEFAC to align a diversity of feed manufacturing companies in Europe behind a common minimum norm. We appreciate that our comments on the draft were dealt with
transparently, and that some of our comments, for example on verification‐in‐the‐field, on aerial spraying of pesticides or waste disposal have been adopted in the final version.
We stress however that we cannot endorse this minimum level as it is now. A major criticism is that FEFAC’s guidelines are allowing legal deforestation and conversion of other valuable habitats.
Despite our advice, there has been no change in criteria 28 stating that ‘no soy is produced on land that was illegally deforested after a certain cut‐off date mentioned in national legislation (e.g. 2008 in Brazil, 2008 in USA etc.). NGOs indicated that the guidelines should go beyond illegal deforestation, and should refer to an internationally defined cut‐off date after which no
deforestation is allowed, as not all countries and regions have sufficient legislations in place.

Especially in the drier, vulnerable areas, that have a low protection status such as the Gran Chaco (Argentina, Bolivia, Paraguay), or the Brazilian Cerrado, actual (illegal and legal) expansion of soy far exceeds responsible levels. Various other key issues important to NGOs are considered beyond baseline level by FEFAC (e.g. the execution of a comprehensive, participatory and documented
community rights assessment, criterion 55). Also the essential maintenance and restoration of natural vegetation around bodies of water and steep slopes and hills (criterion 30) is still just
voluntary in the Guidelines.

We stress that the Guidelines should not be misinterpreted as a “new standard”, or as a guideline for “responsible” sourcing. FEFAC rightly states in its comments that these guidelines are not
‘responsible soy’ 1) ‘It is not FEFAC’s intention to misuse the claim ‘responsible soy‘. However, in the formal and informal communication of FEFAC (spokespersons) or its members the Guidelines have been applauded as a new “mainstream market solution”, a “game changer” or indeed as “responsible”1.   We find this use of the term “responsible” to be misleading. We stress that only a standard such as RTRS or sufficiently equivalent, such as Pro Terra, can currently carry the label “responsible.” We call upon retail, government and other important stakeholders in the game of market transformation, to clearly support and maintain this level of ambition.

We urge FEFAC to formulate clear ambitions and timelines to make explicit when all soy imported by FEFAC members should be produced according to their guidelines, and by when FEFAC members should be sourcing RTRS‐certified or equivalent responsible soy. In this process, monitoring volumes and transparently communicating progress towards these goals, are key. Without an explicit ambition to create volume, and push up the bar to a responsible level, the Guidelines will not be a “game changer”. Rather they risk legitimizing business as usual, and lowering Dutch, European and even global ambitions on responsible soy. At the global level, more and more companies and governments pledge to strive for zero (net) deforestation in their value chains. As an example, the Soy Sourcing Guidelines of the Consumer Goods Forum 2) try to guide companies which soy standards to adopt. Unfortunately, the minimum norm proposed by FEFAC’s does not come close to a level that meets the aspirations (on deforestation) of the CGF and its global companies. Our aim is to achieve truly responsible soy in our harbors, supermarkets, restaurants, and home kitchens.

FARN (Argentina)
Fundación Vida Silvestre Argentina
Natuur & Milieu (NL)

For more information:
Both ENDS – Tamara Mohr ‐
FARN – María Marta di Paola ‐
Fundación Vida Silvestre – Diego Moreno ‐
IUCN NL – Heleen van den Hombergh –
Natuur & Milieu – Ben Hermans –
WWF NL – Sandra Mulder –