ProTerra Monitoring and Verification (MRV) Standard and the European Regulation on deforestation-free commodities[1]
The ProTerra MRV Standard v1.0 has been benchmarked against the EU Regulation on deforestation-free commodities (EUDR) in February 2024, based on currently available information.
While several articles of the Regulation do not apply to voluntary standards as they relate to obligations of member states and competent authorities, administrative matters or internal responsibilities of organisations, full adherence is observed in ProTerra MRV in relation to the said Regulations for all the articles considered applicable.
ProTerra MRV is a relevant tool to support organisations in achieving and maintaining compliance with the EUDR. More than a tool, the ProTerra MRV Standard provides a systematic approach to assessing and verifying an organisation’s due diligence practices and supports reporting on supply chain due diligence and deforestation-free aspects. It is based on the implementation of a management system and its compliance with sustainability requirements associated with the organisation´s supply chain.
ProTerra MRV enables organisations to understand their supply chain risks and compliance gaps, helping them to prepare for the due diligence process. Secondly, it is a relevant risk mitigation tool and requires economic operators to map their supply chain, assess risks, minimise and/or mitigate the negative impacts of the relevant risks that the economic operator can control, define and adopt a risk management plan to strive to minimise and/or mitigate the negative impacts, and implement risk prevention measures while promoting forest-positive outcomes (refer to indicator 3.3 of ProTerra MRV).
Risk mitigation is also achieved through the requirement of preparing and implementing a Corrective Action Plan (refer to 3.7 of ProTerra MRV), for any non-compliance identified. ProTerra MRV verification audits are conducted by qualified third parties who objectively assess the organisation’s management system and supplier‘s operations, including documentation review, checks of satellite imagery for information on potential deforestation, on-site inspection, and interviews with relevant personnel and stakeholders as required. Compliance with ProTerra´s MRV requirements by suppliers serves as evidence that the economic operator´s management system is working correctly and that there is no systemic non-compliance on the part of the supplier. Lots of commodities and/or related products from a non-compliant supplier must be clearly identified. This information should be communicated to the next step of the supply chain in which the economic operator is involved (please refer to the management system requirement 3.12).
In some respects, ProTerra´s MRV requirements go beyond the requirements of the EUDR, in particular by requiring that:
- The protection of vegetated areas beyond the definition of forest, such as native grasslands, wetlands, swamps, peatlands, savannahs, steep slopes and riparian areas;
- Promotion of forest-positive outcomes, including as applicable: protecting and restoring forest ecosystems; working with farmers, cooperatives and local communities; supporting landscape and jurisdictional initiatives to help address the root causes of deforestation; and promoting and supporting international initiatives on deforestation and capacity-building.
- Establishing and maintaining an operational grievance mechanism, in consultation and collaboration with relevant stakeholders, including early warning systems for deforestation risks, human rights issues and complaints.
- Consistently using operating procedures to maintain full segregation of each lot of ProTerra MRV verified products from other materials from the point of receipt to the point of transfer to the next level in the supply chain.
- Commodity suppliers must obtain the free, prior and informed consent (FPIC) of indigenous peoples and local communities before undertaking new activities (land acquisition or development) that may affect their rights, land, resources, livelihoods and food security. That no land conversion takes place where there is an unresolved land use claim by traditional land users without the agreement of both parties.
- In the event of a dispute over land use rights, a thorough, participatory and documented assessment of the community’s rights shall be carried out and the recommendations of the assessment shall be followed.
Table 1 below details the adherence between ProTerra MRV and the applicable articles of the EUDR.
Table 1 – ProTerra MRV and EUDR
| EUDR | ProTerra MRV |
| Article 1 : Subject matter and scope | ProTerra MRV is applicable to all agricultural commodities, including several of the products listed in the Regulation with the exception of cattle and wood. ProTerra MRV also applies to “relevant products” as it covers the feed and food supply chain of agricultural commodities. |
| Article 3: Prohibition | ProTerra MRV verification covers regulatory compliance and sustainability criteria related to the key risks associated with agricultural activities, including deforestation. A certified organisation therefore meets the requirements of Article 3 in relation to the commodities and products it purchases (ProTerra MRV requirements 3.4 and 4.2.1). |
| Article 4: Obligations of operators | ProTerra MRV requires that operators maintain a chain of custody system, which is a relevant tool for communicating product/commodity compliance down the supply chain (ProTerra MRV requirement 3.10). |
| Article 5: Obligations of traders | As above. |
| Article 8: Due diligence | The implementation of the ProTerra MRV requirements helps to identify gaps and prepare for the due diligence. Additionally, the ProTerra MRV verification audit is a due diligence assessment conducted by an independent and duly qualified third party that covers regulatory compliance and sustainability criteria related to the key risks associated with agricultural activities. The audit report and the ProTerra MRV Certificate are evidence of the due diligence carried out on the commodity/product intended for commercialisation in Europe. By having a valid ProTerra MRV verification of its supply chain, an economic operator is eligible to prepare and submit a due diligence statement as required by the Regulation considering the commodity/product meets the requirements under Article 3 of the EUDR. |
| Article 9: Information requirements | Reference to plot geolocation is considered under ProTerra MRV 4.3.20, while information on production and commercialisation is included under the chain of custody requirements (ProTerra MRV requirement 3.10). ProTerra MRV also requires suppliers to be verified against a set of environmental, health and safety and social requirements. Lots of commodities and/or related products from a non-compliant supplier must be clearly identified as such and this information should be communicated to the next level of the supply chain in which the economic operator participates (please refer to the management system requirement 3.12). |
| Article 10: Risk assessment | ProTerra MRV (refer to 3.3 and its sub-indicators) explicitly provides for the need for a risk assessment and requires compliance with EUDR under this topic. |
| Article 11: Risk mitigation | ProTerra MRV explicitly requires risk mitigation under 3.3 g, h and i. |
| Article 12: Establishment and maintenance of due diligence systems, reporting and record keeping | The ProTerra MRV Standard provides a systematic approach to assessing and verifying an organisation’s due diligence practices and supports reporting on supply chain due diligence and deforestation-free aspects. It is based on the company’s management system compliance with sustainability requirements. As ProTerra MRV sets the framework for a supplier management system, it fulfils the requirements of EUDR Article 12. |