Terms of Reference for the Public Consultation on the Development of the Rainforest Alliance Sustainable Agriculture Standard-Cocoa

What is this document about?

This document sets out the terms of reference for the development of the new Rainforest Alliance Sustainable Agriculture Standard-Cocoa (SAS-Cocoa). It explains the purpose, scope, justification, consultation approach, feasibility and auditability process, timelines, and key considerations for developing a streamlined, cocoa-specific standard.

When and how to use this document?

Use this document to understand the purpose, scope, consultation process, and development approach for the Rainforest Alliance Sustainable Agriculture Standard-Cocoa. It is intended for stakeholders participating in consultations or reviewing the proposed Standard and related CLMRS Module, and should be read together with the draft Standard, consultation materials, and feedback tools.

1. Introduction

The cocoa sector is of strategic importance to the Rainforest Alliance, with a strong certification footprint across key producing regions. The Rainforest Alliance Certification Program operates at significant scale in major cocoa-producing countries across West and Central Africa (e.g. Ghana and Côte d’Ivoire), Latin America and the Caribbean (e.g. Ecuador, Peru, Brazil, and Dominican Republic) and Asia-Pacific (e.g. Indonesia and Papua New Guinea). Through this global presence, the certification program generates sustainability impacts for farmers, workers, and cocoa-growing communities and landscapes across diverse geographies.

To strengthen these impacts and maintain credibility in a rapidly evolving regulatory and market environment, the Rainforest Alliance is developing the Sustainable Agriculture Standard-Cocoa (SAS-Cocoa). The Standard is designed to be globally applicable while anchored in national and regional realities, ensuring that requirements are relevant, practical, and effective across diverse cocoa-producing contexts.

1.1 Streamlining and increased clarity

A central objective of the development of the Sustainable Agriculture Standard-Cocoa is to streamline and clarify the certification framework. Currently, requirements for cocoa farmers are distributed across multiple documents, which has led to fragmentation and lack of clarity. Stakeholders, particularly companies, have indicated that this complexity often results in duplicative processes and inefficiencies in implementation.

To address this, the Sustainable Agriculture Standard-Cocoa will consolidate the Policy for Farm and Supply Chain Certification in Cocoa in West and Central Africa and all relevant cocoa-related requirements from the Sustainable Agriculture Standard (SAS) v1.4 including EUDR Alignment Policy requirements into a single, coherent document. It will also organize requirements into clear thematic categories, making them easier for farmers, companies, and auditors to understand and apply. In addition, it will provide more precise definitions and clearer guidance, reducing ambiguity and supporting more consistent implementation and verification.

1.2 Focus on cocoa-specific priorities

The Sustainable Agriculture Standard-Cocoa will place a deliberate emphasis on issues most pertinent to the cocoa sector, while reducing requirements that are not directly relevant to cocoa production, and the particular context of its production systems. This targeted approach will improve both usability and impact.

Key focus areas for contextualized requirements and data points include:

• Management improvement

• Traceability and supply chain transparency

• Geodata, deforestation prevention and monitoring

• Human Rights and Livelihoods

• Sustainable Agricultural practices

• Farmer Support

• Alignment with evolving regulatory frameworks such as EUDR, CSDDD, and EUFLR.

1.3 Stakeholder-centered development

The development of the Sustainable Agriculture Standard-Cocoa will be grounded in extensive stakeholder engagement across regions, including:

• In-country and online public consultations with farmers, companies, governments, Certification Bodies, and civil society in Africa, Latin America, and Asia to assess global applicability

• Targeted engagement with Certificate Holders (CHs) and other underrepresented groups within the sector to assess implementation practicality

• Involvement of Certification Bodies to ensure requirements are clear and auditable.

Through this process, Rainforest Alliance aims to deliver a standard that is more streamlined, clear, globally consistent, and locally relevant, while strengthening its impact on the most critical sustainability challenges in the cocoa sector.

2. Scope of the standard

The Sustainable Agriculture Standard-Cocoa is being developed as a globally applicable framework for sustainable cocoa production. It will apply across all regions where Rainforest Alliance cocoa certification is active, including Africa, Latin America and the Caribbean, and Asia-Pacific, ensuring a consistent approach to requirements, data collection and outcomes.

The scope of the Standard will align closely with the Rainforest Alliance Sustainable Agriculture Standard while covering the full range of cocoa-specific sustainability topics, including farm production, group management, traceability, and key risk areas such as deforestation and human rights. This ensures a clear focus on the sustainability issues most relevant to the cocoa sector.

The Sustainable Agriculture Standard-Cocoa is also being developed in alignment with key international regulatory frameworks, due diligence requirements, and sector standards, including the European Union Deforestation Regulation (EUDR), the Corporate Sustainability Due Diligence  Directive (CSDDD), the European Union Forced Labor Regulation (EUFLR), the African Regional Standard 1000 series for Cocoa (ARS 1000), the OECD Due Diligence Guidance for Responsible Supply Chains of Agricultural Commodities and the UN Guiding Principles on Business and Human Rights (UNGPs). This alignment is intended to support Certificate Holders and supply chain actors in meeting emerging legal and market expectations, related to environmental protection, deforestation, traceability, human rights, workers’ rights, and due diligence, while promoting globally recognized sustainable practices.

3. Justification

As is noted above, the Sustainable Agriculture Standard-Cocoa aims to improve the efficiency and effectiveness of the Rainforest Alliance Certification Program in delivering impact in the cocoa sector, while addressing key sustainability issues associated with cocoa production.

3.1 Increased clarity through streamlined requirements

Streamlining and consolidating the certification framework are critical to improving both effectiveness and impact in cocoa production. Under the current system, requirements applicable to the cocoa sector are distributed across multiple documents, creating fragmentation, overlaps and higher costs, and potential inconsistencies in quality of implementation. This has led to situations resulting in duplicative processes, parallel data collection systems, and increased administrative burden.

By consolidating our binding documents, where possible, into a single, coherent Sustainable Agriculture Standard-Cocoa, organized into clear thematic areas, the proposed framework will significantly improve clarity and usability. Clearer definitions and enhanced requirement structure will reduce ambiguity, enabling stakeholders to better understand what is required and how to implement it consistently.

Reducing duplication will allow farmers, organizations, and supporters to focus resources on the most meaningful sustainability actions rather and less on administrative compliance. Instead of spending time reconciling overlapping requirements or managing multiple reporting streams, stakeholders can invest more directly in addressing core sector challenges.

In addition, streamlining will improve the quality and consistency of verification. When requirements are clearer and non-duplicative, auditors can assess compliance more efficiently and with less interpretation variability. This strengthens the credibility and comparability of certification outcomes, while reducing the risk of confusion or inconsistent audit findings.

3.2 Management improvement

Cocoa production is dominated by millions of smallholder farmers, often operating on small plots with limited access to finance and training, and in some cases in contexts with low organizational capacity. Weak farm and group management systems contribute to low productivity, inefficient use of inputs, and limited ability to comply with requirements. Strengthening requirements that support management practices — such as record-keeping, group member registration, and internal controls — is therefore critical to improving productivity, ensuring compliance, and enabling farmers and cooperatives to participate more effectively in global markets. The Sustainable Agriculture Standard-Cocoa addresses these systemic gaps while remaining adaptable to different farm sizes and organizational capacities. By setting clear, risk-based requirements, the Standard supports continuous improvement, strengthens assurance credibility, and aligns producer practices with increasing market and regulatory expectations. Improved management systems will also support large farm structures in other regional contexts through stronger operational planning, labor management, and traceability — ultimately enhancing overall efficiency, accountability, and market access across different farm structures.

3.3 Traceability and supply chain transparency

Cocoa supply chains are highly fragmented and multi-tiered, often involving informal intermediaries, which makes it difficult to link cocoa back to its origin. This lack of transparency hampers efforts to address key sustainability risks. Strengthening requirements and increasing visibility of traceability, supported by the proper tools and farm-level data, will provide greater visibility, accountability, and opportunities to invest in sustainable cocoa production and farmer livelihoods. The Sustainable Agriculture Standard-Cocoa introduces structured requirements related to this topic, targeted at improving traceability and oversight where risks are highest. By reinforcing controls at collection centers and linking these to farm-level data, the Standard supports more reliable supply chain information, better risk identification, and alignment with increasing market and regulatory expectations.

3.4 Geodata, deforestation prevention and monitoring

Cocoa cultivation poses major deforestation risks, particularly in West Africa, where forest conversion for cocoa farming has caused widespread biodiversity loss and ecosystem degradation. As cocoa is often grown in or near forested areas, geolocation data and satellite monitoring are increasingly necessary to verify that production does not encroach on protected areas. These tools are also essential for compliance with emerging regulations and for supporting forest-positive production systems, such as agroforestry. In this context, the Sustainable Agriculture Standard-Cocoa establishes clear requirements for geodata collection, monitoring, and risk management at the farm and supply chain levels. By embedding these tools into certification requirements, the Standard strengthens the ability to prevent deforestation, improve traceability, and ensure alignment with regulatory expectations.

3.5 Human rights and livelihoods

Human rights risks, particularly child labor and forced labor, remain among the most critical challenges in the cocoa sector. The proposed Sustainable Agriculture Standard–Cocoa strengthens the Rainforest Alliance risk based Assess-and-Address system to further prevent, identify, mitigate, and remediate these risks. Addressing livelihoods and human rights, including labor rights, is fundamental to achieving ethical supply chains and long-term sector sustainability. The Standard, together with the optional Rainforest Alliance CLMRS Module and incentives linked to improved livelihoods, supports continuous improvement in human rights and livelihood outcomes. Together, these measures strengthen accountability and align with evolving regulatory and market expectations related to human rights protection.

3.6 Child labor monitoring and remediation system CLMRS Module

Also included in this consultation process is the consultation on the optional Rainforest Alliance CLMRS Module, being introduced for existing and potential Certificate Holders of the Sustainable Agriculture Standard-Cocoa and the Sustainable Agriculture Standard as an optional Module available to Certificate Holders operating in West and Central Africa. The CLMRS Module does not replace or reduce the mandatory child labor requirements in the Standards. All certified cocoa operations remain bound by the Assess-and-Address system requirements, which constitute the mandatory baseline for child labor protection. The CLMRS Module builds on that foundation by providing Certificate Holders and their supply chain partners with a structured, continuous, community-level system for monitoring, remediation, and follow-up, aligned with the International Cocoa Initiative (ICI) Core Criteria for Child Labor Monitoring and Remediation Systems. The design of the CLMRS Module reflects a proportionate approach. It enables more intensive monitoring and remediation activities where Certificate Holders and their supply chain partners have the commitment and capacity to implement and sustain them, while avoiding the imposition of a single prescriptive system across all contexts. This approach also recognizes that the implementation of a CLMRS may not be feasible or appropriate in all circumstances. The geographic scope of the CLMRS Module is currently limited to West and Central Africa for two reasons:

• The prevalence of child labor in cocoa production is heavily concentrated in this region.

• The ICI Core Criteria were initially developed and validated in West and Central African cocoa-growing regions and have not yet been broadly adapted to other producing regions.

The Rainforest Alliance commits to periodically reviewing the scope of the CLMRS Module and to defining criteria for extending its availability to other regions where evidence supports such expansion.

The Rainforest Alliance is consulting on the CLMRS Module as part of the broader cocoa stakeholder consultation, rather than through a separate process, for the following reasons:

• Methodological integrity: The CLMRS Module does not operate in isolation. It is designed to complement the child labor requirements and broader due diligence approach of the Sustainable Agriculture Standard-Cocoa. Stakeholders can therefore best assess its relevance, feasibility, and potential impact in the context of the broader instrument.

• Meaningful and balanced participation: The stakeholder groups most relevant to the CLMRS Module substantially overlap with those affected by the Sustainable Agriculture Standard-Cocoa. Conducting a separate consultation would create an unnecessary burden on the same stakeholders and could reduce participation and the quality of feedback received. Consulting on both together allows stakeholders to consider the full child labor framework in a single process.

• Alignment with the ISEAL Code of Good Practice: The ISEAL Code requires at least two rounds of stakeholder consultation during standards development but does not require separate consultations for individual components. Consulting on the CLMRS Module within the broader standard consultation is consistent with these requirements.

• Coherence and timing: The CLMRS Module is intended to be available alongside the Sustainable Agriculture Standard–Cocoa for Certificate Holders wishing to strengthen their child labor monitoring and remediation efforts. Consulting on the Module together with the Standard supports a coherent development process and allows stakeholders to provide feedback on the overall child labor framework at the same time.

3.7 Sustainable agricultural practices

Cocoa farming faces growing pressure from climate change, soil degradation, pests, and declining yields, threatening the long-term viability of production. Unsustainable practices, such as low farm rejuvenation, suboptimal varieties, and improper fertilization and pest management, contribute to biodiversity loss, soil depletion, and increased vulnerability to climate shocks. Requirements catering to sustainable cocoa production practices — such as soil management and integrated pest management — can improve resilience, increase yields, and reduce environmental impact, while supporting long-term productivity and farmer incomes. The Sustainable Agriculture Standard-Cocoa establishes clear, risk-based requirements that promote the adoption of more sustainable and climate-resilient practices across different production systems. By strengthening farm-level management and encouraging continuous improvement, the Standard supports adaptation to climate risks.

3.8 Farmer support

Cocoa farmers often lack access to training, inputs, finance, and market information, limiting their ability to improve productivity and comply with sustainability standards. Given that over 90% of cocoa is produced by smallholders, targeted farmer support is essential to enable the adoption of better practices and technologies. Effective support systems — such as extension services, cooperative strengthening, and access to data and tools — are critical to translating certification requirements into real-world impact and ensuring inclusive participation in sustainable cocoa supply chains. The Sustainable Agriculture Standard-Cocoa outlines requirements that strengthen support systems and accountability for service delivery at the group and supply chain levels. By promoting structured farmer support, improved access to knowledge and tools, and data-driven decision-making, the Standard enables more consistent adoption of sustainable practices, supports continuous improvement, and aligns with increasing expectations on responsible sourcing and inclusive value chains.

3.9 Alignment with regulations

By embedding risk-based requirements, strengthening due diligence approaches, improving data availability, and reinforcing controls at farm and first-mile levels, the Standard will support more robust identification, prevention, mitigation, and remediation of environmental, labor and human rights risks. The Sustainable Agriculture Standard-Cocoa will enhance traceability, transparency, and monitoring systems, enabling producers, supply chain actors, and assurance systems to more effectively meet evolving regulatory expectations under frameworks such as EUDR, CSDDD, and EUFLR, while strengthening the credibility and integrity of Rainforest Alliance certified cocoa.

3.10 Consideration of other standards

Across leading sustainability standards, including Rainforest Alliance, Fairtrade, company programs, and the African Regional Standard for Sustainable Cocoa, there is strong convergence around core thematic areas, broadly covering environmental, social, and economic dimensions of sustainability. Moving to a sector-specific approach will allow the Rainforest Alliance to align more closely in cases where farmers are certified against multiple standards, many of which are specific to the cocoa sector. This will enable the more than 1,000 Certificate Holders producing cocoa certified under the Rainforest Alliance Sustainable Agriculture Standard, together with the 1.2 million farmers they represent, to benefit from more streamlined and contextualized requirements.

4. Theory of Change

The Sustainable Agriculture Standard-Cocoa aims to deliver measurable outcomes that support the Rainforest Alliance’s mission to create a more sustainable and equitable agricultural sector. These outcomes include stronger human rights protection, improved livelihoods, inclusive participation of smallholder farmers, protection of the environment through deforestation prevention and biodiversity conservation, adoption of climate-resilient and sustainable farming practices, improved productivity, market access, and the long-term viability of cocoa production systems. Together, these outcomes underpin the credibility of the sustainability claims substantiated by the Standard, including responsible sourcing, deforestation-free production, respect for human rights, protection of the environment, and continuous improvement in farm performance. The development of the Sustainable Agriculture Standard-Cocoa is guided by the Rainforest Alliance Theory of Change (ToC) as a framework for identifying, assessing, and prioritizing potential changes to the Standard. The ToC helps ensure that proposed requirements address key sustainability challenges in the cocoa sector and strengthen the pathways through which certification contributes to these outcomes. Proposed changes are evaluated based on their expected contribution to the intended outcomes and impacts, while remaining practical and applicable across diverse cocoa-producing contexts.

The development of the Sustainable Agriculture Standard-Cocoa also considers how cocoa-specific requirements strengthen responsible business conduct, human rights due diligence, living income and livelihood pathways, deforestation-free production, farm productivity and profitability, and services that support continuous improvement and long-term sector transformation.

Figure 1. Long term outcomes and impact of the Sustainable Agriculture Standard-Cocoa.

5. Implementation risks

The implementation of the Sustainable Agriculture Standard–Cocoa presents several risks that may affect its ability to achieve the intended outcomes. These include uneven availability and accessibility of tools, data, and support services — particularly for smallholders — as well as potential inconsistencies in interpretation or application by assurance actors. There is also a risk of unintended consequences, such as the exclusion of vulnerable groups, increased administrative burden, or reduced market access for those unable to comply.

In particular, the effectiveness of systems intended to identify, prevent, mitigate, and remediate labor and human rights risks may be constrained by limited local capacity, inconsistent implementation, and insufficient identification, monitoring, remediation, and follow-up of cases. To mitigate these risks, the Standard incorporates a risk-based approach. The Rainforest Alliance Assess-and-Address system includes risk assessment, implementation of mitigation measures, ongoing monitoring, and remediation of confirmed cases through a defined Remediation Protocol. The optional Rainforest Alliance CLMRS Module builds on the child labor requirements of the Assess-and-Address system by increasing the intensity, scope, and duration of child labor monitoring, remediation, and follow-up activities. Together, these approaches promote awareness-raising, capacity strengthening, and the application of due diligence principles.

To ensure implementation feasibility, the development of the Sustainable Agriculture Standard–Cocoa will include testing with a selection of Certificate Holders across the relevant regions in scope. These pilots will help assess the practicality of the requirements, data collection processes, risk identification, and management systems at farm and group level. Furthermore, a phased implementation period will be established to support the transition of Rainforest Alliance Certificate Holders currently certified under the Sustainable Agriculture Standard.

Additional measures—such as clear guidance and targeted training, including implementation of the Rainforest Alliance CLMRS Module, will further support consistent implementation and minimize unintended negative impacts.

The Standard will be reviewed at least once every five (5) years to assess its continued relevance and effectiveness. Necessary revisions within this period will be managed as follows: non-substantive changes, such as clarifications to existing language, will not require a formal process. These changes will be communicated transparently to relevant stakeholders in line with the Rainforest Alliance Standard Development Procedure and/or Terms and Conditions.

Urgent substantive changes to the Standard in response to serious risks identified through feedback, audit findings, significant regulatory developments, or reputational concerns will be addressed in accordance with the Rainforest Alliance Standards Development Procedure.

6. Feasibility and auditability

In line with the ISEAL Code of Good Practice, the Rainforest Alliance will assess the feasibility and auditability of the proposed Sustainable Agriculture Standard–Cocoa as part of the standards development process. Rainforest Alliance recognizes that the proposed Sustainable Agriculture Standard–Cocoa represents a significant evolution of its cocoa certification approach. It consolidates previously separate components, including the Sustainable Agriculture Standard, the Cocoa Policy, EUDR requirements, and alignment with other relevant regulatory frameworks, into a single, streamlined, cocoa-focused standard applicable to cocoa farm Certificate Holders globally.

Rainforest Alliance also recognizes that the proposed Standard builds on elements of the existing Policy for Farm and Supply Chain Certification in Cocoa, which was applicable only in selected West and Central African countries. As a result, particular attention will be given to assessing the feasibility and auditability of the proposed requirements in cocoa-producing countries where the Policy was not previously implemented.

Through a structured development process, Rainforest Alliance will seek to ensure that the Standard:

• Reflects a significant but well-managed evolution of the existing system that delivers more value and impact for the cocoa sector

• Remains feasible for implementation, particularly for smallholder producers

• Is fully auditable and capable of delivering reliable assurance outcomes

6.1 Approach to feasibility

Rainforest Alliance is committed to ensuring that the proposed Sustainable Agriculture Standard–Cocoa is feasible, practical, and relevant across cocoa-producing contexts. The overarching objective of the standard development process is to simplify binding documents and enhance relevance by concentrating on requirements that are directly applicable to cocoa production systems.

As the proposed Sustainable Agriculture Standard–Cocoa is largely based on existing binding documents that have already been implemented by Certificate Holders, a targeted approach to feasibility assessment can be applied. To assess feasibility, testing and piloting activities will be conducted with selected Certificate Holders across diverse cocoa-producing geographies (Brazil, Côte d'Ivoire, and Indonesia).

These tests and pilots will focus on:

• The integration of requirements originating from the Sustainable Agriculture Standard, the West and Central Africa Cocoa Policy, EUDR alignment requirements, and other components of the proposed Standard.

• The feasibility and practicality of implementing the proposed optional Rainforest Alliance CLMRS Module across different contexts.

• The usability and functionality of any new digital tools supporting implementation, compliance, and monitoring.

Particular attention will be given to smallholder producer groups to ensure that the proposed requirements remain implementable given their operational realities, resource constraints, and organizational capacities.

In addition, the consultations described in Section 7 will assess the clarity, relevance, feasibility, and implementation burden of the proposed requirements.

Feedback from these consultations, tests, and pilots will be systematically documented and used to refine the proposed Sustainable Agriculture Standard–Cocoa prior to finalization.

6.2 Approach to auditability

Recognizing that a streamlined yet redesigned Sustainable Agriculture Standard-Cocoa introduces new structural and operational elements, the Rainforest Alliance will ensure that the proposed Standard is auditable and consistently interpretable by Certification Bodies (CBs).

To assess auditability, CBs will be actively engaged throughout the consultation process. CBs will be requested to:

• Review the proposed Standard requirements for clarity, measurability, and verifiability.

• Assess the auditability of key components of the proposed Standard, including new data collection requirements and digital tools supporting implementation, compliance, and monitoring.

• Provide feedback on potential challenges in audit execution, including time requirements, data availability, and evidence verification.

• Assess the clarity and auditability of the proposed optional Rainforest Alliance CLMRS Module.

Field testing and pilot audits will be conducted, where feasible, to evaluate:

• The consistency of interpretation across auditors

• The practicality of auditing new and proposed requirements in field conditions

• Any risks of subjectivity or ambiguity in audit findings

6.3 Improvement and validation

Findings from feasibility testing, auditability assessments, and stakeholder consultations will be systematically analyzed and used to improve the proposed Sustainable Agriculture Standard–Cocoa and the proposed optional Rainforest Alliance CLMRS Module.

The Rainforest Alliance will:

• Refine the proposed requirements to address identified challenges and stakeholder feedback.

• Ensure that the proposed Standard remains feasible to implement and capable of delivering reliable assurance outcomes.

• Ensure that the proposed Rainforest Alliance CLMRS Module is practical, relevant, and implementable in the contexts for which it is intended.

• Strive to balance simplification and usability with the credibility, integrity, and effectiveness of certification outcomes.

7. Consultation

The development of the Sustainable Agriculture Standard-Cocoa will be grounded in extensive stakeholder engagement across regions, including:

• In-country consultations with farmers, companies, governments, and civil society in Africa, Latin America, and Asia-Pacific.

• Involvement of Certification Bodies in the in-country consultations to ensure requirements are clear and auditable.

• Public Consultation of version 0.1 of the Sustainable Agriculture Standard for Cocoa.

• Targeted engagement with Certificate Holders to assess implementation practicality.

• Targeted engagement with under-represented and vulnerable groups (including women, youth, and marginalized communities) to ensure their perspectives, constraints, and priorities are adequately reflected in the design of the standard.

• In-person workshops with downstream stakeholders

• Public consultation of version 0.2 of the Sustainable Agriculture Standard for Cocoa.

Consultation will be global, with targeted workshops focusing on key production countries across Africa, Latin America and Asia Pacific. Consultation on the proposed optional Rainforest Alliance CLMRS Module will focus on stakeholders in West and Central Africa, reflecting the intended scope of implementation of the Module.

7.1 CLMRS Module consultation approach

The proposed optional Rainforest Alliance CLMRS Module is consulted alongside the Sustainable Agriculture Standard–Cocoa through both rounds of public consultation. Dedicated consultation questions enable stakeholders to provide specific feedback on the design, feasibility, auditability, and relevance of the Module.

It is recognized that consultation on the Module may be affected by certain risks. These risks and related mitigation measures are outlined below.

• Under-consultation of the CLMRS Module: The CLMRS Module may receive insufficient focused attention if it is absorbed into the broader consultation process. Mitigation measures include:

  • A dedicated CLMRS Module section with its own consultation questions and survey.

  • Proactive targeted outreach to key stakeholders.

  • A commitment to supplementary targeted consultation activities, if needed.

• Misinterpretation of the role of the CLMRS Module: Some stakeholders may perceive the CLMRS Module as a replacement for, or an alternative to, the mandatory child labor related requirements of the Standard. Mitigation measures include:

  • Clear and consistent communication that the CLMRS Module is an enhanced due diligence layer built on top of the mandatory Assess-and-Address system requirements.

  • Clear communication that the Module is aligned with the International Cocoa Initiative (ICI) Core Criteria for Child Labor Monitoring and Remediation Systems and supports child labor due diligence.

  • Clear communication that the Module is not intended to be the sole approach to addressing child labor but rather complements the broader child labor related requirements and due diligence approach of the Standard.

• Limitation of regional scope: Some stakeholders may interpret the current geographic focus of the Module to mean that child labor risks in other regions are being overlooked. Mitigation measures include:

  • Clearly explaining the rationale for the current focus on West and Central Africa.

  • Defining the conditions under which the geographic scope of the Module may be reviewed and expanded.

  • Considering future expansion of the Module as evidence and implementation experience become available.

7.2 Process and Methodology

The Rainforest Alliance will implement a structured consultation process comprising the following steps:

7.2.1 Stakeholder mapping

Identification of relevant stakeholders across:

• Individual farmers, workers, and representatives.

• Cocoa producer organizations (i.e. cooperatives, associations).

• Traders, processors, manufacturers, brands, retailers, and industry associations.

• Government agencies and sector regulators

• Certification Bodies

• Civil society and technical experts

Identification of appropriate mechanisms to enable participation of under-represented or vulnerable groups (i.e. women, youth and migrant workers).

7.2.2 Structured global feedback collection – first round

• Publication and communication in relevant working languages of version 0.1 of the Sustainable Agriculture Standard for Cocoa.

• Publication and communication of consultation terms of reference including consultation objectives, scope, timelines, instructions to provide feedback and decision-making process.

• Solicitation of feedback through a structured open online survey.

• Online Webinar to launch the consultation in relevant working languages.

• Provision of a dedicated Rainforest Alliance email address to receive additional feedback from interested stakeholders.

7.2.3 Structured and multistakeholder country-level consultations

• Regional in-person consultation sessions in countries: Côte d’Ivoire, Ghana, Ecuador, Brazil, Peru and Indonesia.

• Regional online consultation sessions in Nigeria and Cameron.

• Targeted thematic sessions, where required, with in-country regulatory bodies, Certification Bodies, under-represented groups identified. This will include CLMRS targeted at child labor and child rights focused stakeholders, including the International Cocoa Initiative, relevant NGOs, producer organizations to ensure informed and representative input is received.

• Targeted thematic sessions with Supply Chain actors.

• Online Webinars for specific topics such as traceability, wages and income and regulatory frameworks, as necessary.  

7.2.4 Internal technical review

• Compilation and analysis of consultation inputs.

• Internal review by Rainforest Alliance subject-matter experts.

• Developing decision logs documenting how consultation inputs are addressed or not addressed.

7.2.5 Drafting of revised Sustainable Agriculture Standard-Cocoa

• Revision of draft version 0.1 of the Sustainable Agriculture Standard for Cocoa based on consultation inputs and technical review.

• Internal review and approval processes in accordance with the Rainforest Alliance Standards Development procedure.

7.2.6 Structured global feedback collection - second round

• Publication and communication in relevant working languages of the first Draft version 0.2 of the Sustainable Agriculture Standard for Cocoa.

• A second round of consultation will be conducted through a structured open online survey on changes made to the draft standard and substantive issues which remain unresolved.

7.2.7 Standard Committee Consultation

• A sub-committee within the Standards Committee with expertise on cocoa to review and advise.

7.2.8 Internal technical review

• Compilation and analysis of consultation inputs, and delivery of actionable inputs for the standard development process

• Internal review by Rainforest Alliance subject-matter experts

• Developing decision logs documenting how consultation inputs are addressed or not addressed.

• Development of public-facing documents on the consultation process

7.2.9 Finalization and publication

• Final revisions

• Publication of the Sustainable Agriculture Standard for Cocoa version 1.0 on the Rainforest Alliance Knowledge Hub

• Publication of a consultation report describing the feedback received, key issues raised, and how these were considered in the development of the Standard.

• Publication of Consultation Documents as per ISEAL requirements

7.2.10 Stakeholders and participation

Stakeholders to be engaged may include:

• Cocoa Certificate Holders and producer organizations

• Farmer representatives, workers and under-represented an vulnerable groups.

• Certification Bodies operating in the cocoa sector

• Industry and supply chain actors

• Rainforest Alliance regional and global teams

Participation numbers and formats will be determined per country

7.2.11 Roles and Responsibilities

The Rainforest Alliance:

• Overall coordination and management of the consultation.

• Technical leadership and quality assurance.

• Final decision-making on development of the Sustainable Agriculture Standard for Cocoa.

Stakeholders:

• Provide constructive, evidence-based input

• Engage in good faith throughout the process

7.3 Timelines

7.4 Limitations and decision-making

While all feedback will be carefully reviewed, the Rainforest Alliance may not adopt all recommendations. Decisions will be based on feasibility, strategic alignment, legal consistency, and potential Impact. The Rainforest Alliance also acknowledges the accelerated development timeline of this standard, as well as practical limitations in conducting consultations and pilots across all countries and contexts. Additionally, it may not be possible to fully consult on all systems, platforms, and tooling elements at the time of standard development; to mitigate this, these components will be piloted and refined as they become available.

8. Amendments

These Terms of Reference may be amended by the Rainforest Alliance to address evolving needs during the consultation process. All amendments will be versioned and communicated accordingly.

Other information

Date of first publication of this document (v 1.0):

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