WWF welcomes the newly adopted RSPO Principles and Criteria (P&C), that are the result of an extensive public multi-stakeholder consultation process and a consensus-led Task Force comprising representatives from all RSPO membership groups.  

WWF sees the new P&C as a significant step forward in addressing the weaknesses in the previous version of the P&C and believes it now represents an essential tool that can help companies achieve their commitments to palm oil that is free of deforestation, expansion on peat, exploitation and the use of fire. Meanwhile, WWF cautions that certification on its own cannot solve all the environmental and social problems caused by irresponsible palm oil production.

WWF acknowledges that there is much closer alignment with the requirements of the Palm Oil Innovation Group (POIG) than in the previous P&C and welcomes the incorporation of the High Carbon Stock Approach (HCSA) toolkit and the formation of a joint working group between RSPO and HCSA. Nevertheless, there are some issues in the Standard that deserve more detailed treatment and/or strengthening and care in implementation (see below).  In particular, WWF:

• Identifies a need to review the RSPO Remediation and Compensation Procedure (RaCP) and close any potential loophole(s) for past clearance.
• Identifies additional safeguards for the No Deforestation Joint Working Group to consider for High Forest Cover Landscapes and Countries.
• Urgently calls for the finalisation of guidelines to the highest standard and socialise these with growers, particularly for drainability assessments and the HCSA toolkit.
• Welcomes the strengthening of traceability requirements intended to ensure the legality of all Fresh Fruit Bunches (FFBs), but is disappointed with the leniency of the transition period, which falls short of POIG expectations.
• Welcomes clearer wording to ban the use of hazardous pesticides, but is disappointed that this falls short of POIG expectations for an outright ban, and calls for clear, transparent and rigorous implementation procedures to avoid misuse of the term “exceptional circumstances”.

WWF calls on RSPO members to implement the revised P&C, including doubling efforts to meet ambitious time bound plans for 100% RSPO compliance in production and procurement, and embracing “shared responsibility”
Implementation is essential to deliver against the P&C, and the RSPO must focus on ensuring robust implementation, assurance and evidenced impact. The guidance and systems governing the implementation of the P&C must be robustly and transparently adapted and enforced by the RSPO, and support provided to RSPO members, Certification Bodies, Auditors and Assessors to deliver against the expectations set out within the new Standard. National  Interpretations must be quickly yet comprehensively and inclusively undertaken to the highest standard.The inclusion of quantitative metrics is a welcome addition to the P&C and WWF calls on RSPO and its members to use these and other methods to better measure impact.

Certification is one tool  -- if used in isolation it will not deliver a responsible, sustainable palm oil industry.  All industry supply chain stakeholders including the finance sector and governments must embrace additional actions beyond certification,  including improved and enforced land use planning and legal compliance, landscape approaches, and approaches that are inclusive of smallholders and small and medium sized companies.
 
Responses from WWF to specific issues in the P&C:
Deforestation:

• WWF welcomes the full integration of the High Carbon Stock Approach (HCSA) toolkit into the new P&C. This is a vital step for the RSPO to be seen as the standard that represents the highest principles of sustainability, particularly with respect to halting deforestation. Rigorous High Conservation Value (HCV) and High Carbon Stock (HCS) assessments, and the monitoring and adaptive management of HCV and HCS areas, are vital to ensure protection of natural ecosystems.
• WWF recognises that irresponsible oil palm development places High Forest Cover Landscapes (HFCLs) at risk, and welcomes the No Deforestation Joint Steering Group (NDJSG) as an important means for RSPO-HCSA to be at the forefront of this discussion in High Forest Cover Countries (HFCCs).
• WWF recommends the following assurances in implementation:
  • Strong safeguards for local communities that ensure customary community rights to self-determination for their livelihoods and development are upheld without coercion into palm oil development.
  • Due consideration of the viability to replant abandoned and/or inactive old plantations in HFCCs.
  • RSPO members with plantations and/or undeveloped concessions in HFCL areas commit to protecting these areas.
  • Adaptation of the RSPO Remediation and Compensation Procedure (RaCP) to align with the new P&C to mitigate the potential loophole that could allow for clearance post November 2018. This should be accompanied by a thorough review of the effectiveness and impacts of all compensation plans.
  • Proactive consultation with and socialization of the HCSA toolkit among growers and smallholders operating within different regional contexts to ensure effective implementation.
  • In cases where companies have defined earlier cutoff dates for HCV-HCS, they should abide by these.

Peat:

• WWF welcomes a clear requirement for no new planting of palm oil on peatlands regardless of depth, and the incorporation of a clear and updated peat definition.
• WWF welcomes the phasing out of existing planting on peat subject to a robust drainability assessment.  This should lead to options for rehabilitation and protection of peat or changes of land use to suitable commercial alternatives other than oil palm.
• WWF welcomes the assurance that all peatlands will be managed responsibly following mandatory Best Management Practices.
• WWF calls on the RSPO and its Peatland Working Group to finalize guidelines for drainability assessments and the RSPO Manual on Best Management Practices and to make sure these tools are tested and socialized among grower members as soon as possible. The procedure must follow sound scientific assessment and be controlled for quality, working with expert stakeholders and communities.

Exploitation:

• WWF welcomes significant improvements to the RSPO P&C with respect to labour, to include improved assurances for a decent living wage, job security, no child labour and no forced or trafficked labour.

Traceability to FFB source:

• WWF welcomes the inclusion of legality requirements and assurance for all Fresh Fruit Bunches (FFB), including those from outside the unit of certification.
• Meanwhile, WWF is disappointed with the lenient transition period of three years, which falls short of the requirements of POIG. During this period, RSPO Mass Balance CSPO could be tainted with FFB from protected areas, Forest Estates and other places where oil palm is illegal, and/or contributing to deforestation and/or peatland degradation.
• To help mitigate the risks of this lenient transition period, WWF calls on companies to adopt more ambitious plans to achieve traceability of FFB to plantation (such as that required by POIG). WWF calls on the RSPO to scale-up efforts for traceability of third party and uncertified FFB, and for the audit checklist and guidelines to ensure rigorous conformance checks are in place.

Other:

• WWF welcomes a strengthening of the RSPO’s position to prohibit the use of fire for preparing land, to prevent fire in the managed area and to work with adjacent stakeholders to prevent and control fire.
• WWF welcomes clarification within the P&C that hazardous pesticides can only be used in exceptional circumstances as validated by a due diligence process, or when authorised by government authorities for pest outbreaks. However WWF believes that highly toxic, bio-accumulative and persistent pesticides (PBT) should not be used under any circumstances, and is disappointed that these are not banned outright. In addition, the proposed due diligence procedure must be overseen rigorously to avoid creating a loophole for extended use of banned pesticides.
• WWF is pleased to see contributions to local sustainable development and the global Sustainable Development Goals included within guidance, to include food and water security for SEIA and FPIC, but unfortunately not attaining existing POIG requirements.
• WWF is pleased to see smallholder inclusion explicitly addressed within Principle 5, and overall strengthening of smallholder inclusivity within the P&C.
• WWF welcomes reference to wider landscape benefits and KBAs as part of integrated HCV-HCS assessments.

Implementation:
While WWF endorses the overall wording of the P&C, the standard itself is only as strong as its implementation. RSPO must focus on ensuring robust implementation and evidenced impact. To this end:

• WWF welcomes the addition of quantitative metrics and calls on the RSPO and its members to use these and other methods to better measure the impacts of the P&C.
• WWF welcomes the introduction of “shared responsibility” between membership groups, as recognising the need for multi-stakeholder collaboration to deliver a responsible, sustainable palm oil industry.
• WWF welcomes a restructuring of the P&C and greater clarity within the document that should improve interpretation and implementation.

• Assessments and audits must be of a high quality and the RSPO must invest in systems that provide assurance and credibility. WWF expects the RSPO to increase its efforts through the Assurance Task Force, to include delinking auditors from the operations they audit.
• WWF expects the RSPO and the Board of Governors to quickly act upon , and deliver against,the newly adopted Resolution GA15-6d: ‘Discouraging RSPO members subject to complaints from avoiding their obligations by divestment or withdrawing their membership’.
• The RSPO and its members must ensure that the guidance and systems governing the implementation of the P&C are robustly and transparently adapted and enforced to reflect and support the contents and intent of the new standard. National  Interpretations must be quickly yet comprehensively and inclusively undertaken to the highest standard.
• WWF urges the RSPO to invest in tools that enable it to meet its vision of making “sustainable palm oil the norm”, such as the development of an independent smallholder standard, the training and support of members including outreach to SMEs, and the application of a jurisdictional approach.
• Support must be provided to RSPO members, Certification Bodies, Auditors and Assessors to deliver against the expectations set out within the new Standard.

 
One tool of many:

• While the revised RSPO P&C is an excellent tool to help companies achieve their sustainability commitments, certification on its own cannot solve all the environmental and social problems caused by irresponsible palm oil production. In addition to sourcing sustainable palm oil, WWF asks the RSPO and companies to engage in other efforts that complement certification and support responsible land use planning, landscape approaches and smallholder inclusivity. Governments also have an essential role to play to ensure responsible land use planning that respects rights of communities and protects the environment, and via the development and enforcement of laws that support sustainable palm oil production and use.

Other resources:

• WWF Blog : RSPO : In with the new, out with the old !
• POIG Statement,15 November : ‘The Palm Oil Innovation Group welcomes improvements in the RSPO Standard – Strengthening of underlying systems and robust implementation still needed’.
• HCSA Statement, 12 November: Critical vote for leading palm oil certification scheme ti adopt true ‘no Deforestation’ Standard