Frequently Asked Questions (FAQs)

    • Sourcing areas (defined at the smallest administrative unit) where PO is grown but the cumulative deforestation/conversion linked to Palm Independent Smallholders (ISH) since 2015 is minimal/negligible.​

    • Minimal smallholder deforestation areas will be used to inform company DCF claims for ISH volumes only. ISH volumes shown to be sourced from minimal smallholder deforestation areas will be considered DCF in the IRF (D/P Delivering).

    • The analysis backing up these results is not the equivalent to a detailed Land Use Change analysis and therefore when making claims for DCF we must acknowledge that there is still a risk that not all ISH deforestation has been correctly identified, and there is a higher degree of error in this analysis than for a detailed LUCA. However, we feel the level of detail is appropriate for ISH, where detailed plot-level LUCA is very time-intensive & costly for such small and scattered plots.​

    • IRF v6.0 will provide separate IRF scores for ISH and non-ISH volumes and show clearly the % of volumes from ISH classified as Delivering because they are from MSD areas Vs other pathways. This should be used for disaggregated reporting on ISH volumes, and to transparently show when the MSD smallholder “exemption” is being used.​

    • The “Minimal smallholder deforestation” layer should not be used on its own to stop sourcing from significant smallholder deforestation areas. It should however help companies prioritise the significant smallholder deforestation areas to take action to include smallholders. PPBC is also developing a plan to accelerate collective action in high-priority districts (taking into account where there is more ISH deforestation).​

  • The MSD has been developed consultatively, will not be used in isolation and will be accompanied by wider safeguards to maintain credibility:​

    1. MSD layer applies ONLY to ISH volumes​

    2. Public methodology is publicly available on POCG website. Developed in consultation with technical group over 1 year & using best available data​

    3. Public excel sheet with admin areas categorised as either Minimal Smallholder Deforestation or Significant

    4. ISH deforestation shapefile available upon request ​

    5. External validation protocol (via form on POCG website) to challenge results​

    6. Monitoring protocol – to be codeveloped with WRI and published on POCG website in 2025​

    7. Annual updates including any corrections​

    8. Reporting and checks on ISH volumes via IRF reporting, with IV to be confirmed by IVWG​

    • The threshold is a % of the total deforestation in Indonesia driven by palm ISH from 2016 to 2022. It is a value between 1 and 10% and represents a number of ha of potentially ISH driven deforestation for palm that will be considered as “minimal” ​

    • The threshold is not a representation of 1% of total deforestation within each village.​

    • After updating the layer to include 2023 & 2024 deforestation AND incorporating external feedback the results of the analysis for will be used to report on ISH volumes within IRF template 6.0 in 2025 for 2024 volumes​

    • POCG companies will also be provided an excel file with the total accumulated deforestation over the period (2021-2024) which could help with EUDR due diligence requirements. The MSD layer could be an input to EUDR deforestation risk assessment, and will be shared with EU stakeholders and the joint EU-CPOPC taskforce to discuss its uses.

    • The fact that some sourcing areas may be flagged as significant deforestation doesn’t mean that with sufficient evidence, companies cannot prove these regions as DCF ​

    • Further guidance is already being developed for the IRF, with drafts presented in November 2023 in Jakarta, to be able to prove DCF for the ISH supply sourced from non-negligible risk areas via plot level certification and traceability, via dealers and mitigating deforestation risk via landscape or jurisdictional initiatives

  • POCG will be running an external validation process which would allow informed users (e.g. companies, service providers or NGOs) to challenge the results by submitting sufficient evidence on why some specific areas should not be given either “minimal” or “significant” deforestation status

  • Given that the analysis is going to be used for DCF claims, it will be updated on a yearly basis.

  • This analysis has been performed by looking at the absolute contribution of administrative units to total deforestation in Indonesia and Malaysia. If we were to consider the size of the admin unit in the equation, we would favour units that are bigger in size and hence allow a higher degree of deforestation which should not be encouraged given this analysis is to prove DCF.

    • This is where the industry finds it more challenging to obtain full traceability and to directly monitor and engage with ISHs to evidence DCF. ​

    • By conducting this analysis, the group wants to simplify traceability requirements for ISHs in minimal deforestation areas to make sure majority of ISH in these areas that are compliant are not unfairly excluded from supply chains due simply to lack of proof, while efforts to gather full traceability and support smallholders are focused on areas more “at risk”

    • Malaysia and Indonesia were prioritized for this analysis given most ISH volumes are produced in those 2 countries. POCG might explore conducting this analysis in other PO producing countries. ​

    • The IRF AWG is currently discussing the approach to be followed in countries where an industry accepted neg risk analysis is not available, and the PPBC WG will discuss whether to expand the MSD layer to other countries next year.