Rainforest Alliance "Slippage" allowance

[CravesCoffee]

I recently wrote about a Rainforest Alliance policy which allows both producers and roaster/retailers to mix in up to 10% non-certified beans without disclosure to consumers (in other words, coffee labeled 100% Rainforest Alliance certified can actually contain as little as 81% certified beans (whole explanation here: http://www.coffeehabitat.com/2009/06/wh ... t-100.html).

RA commented on the post. They did not deny this policy, but indicated it was a "slippage allowance" and that all certifications did it. I had previously confirmed that USDA organic certification labeling rules do not allow it, nor does Smithsonian Bird-Friendly.

I would like some independent confirmation from roasters out there that handle certified coffees, especially RA, whether or not this is permitted, and if so the policy explicit? As I also pointed out in the comments of my post, I understand some inadvertent mixing of beans is probably unavoidable and understandable. But 10% is a lot of beans. If it were meant to assure handlers that slippage was allowed, is 10% realistic? It's hard for me to imagine so sloppy a process in which 100 pounds of every 1000 could accidentally be uncertified beans, but I could be wrong.

Julie
Coffee & Conservation

[JavaJ]

How many RA customers would buy the coffee if every bag read "Contains 81% Certified Coffee!" in 24pt type on the front of every bag?

[Peter G]

Hi Julie-

I've been dealing in certifications for years now, and I've never heard the term "slippage", or read it in any certification's rules. You're right, Organic generally makes no allowance for mistakes (is slippage a euphemism for mistake?).

Years ago, we sold certified coffee under RA's now-defunct ECO-OK label, and I don't remember any allowance for slippage at that time, but that was surely before the current rules were drafted.

Seems strange to me too, I don't know whether such an allowance is built into other certified products like lumber. It strikes me as disingenuous too, the idea that "all certifications allow" such a practice- can you imagine allowing 10% B positive blood type in a package marked O negative? I'm just saying.

Peter G

[Tim Dominick]

Slippage is not allowed in organic, however there are 4 different categories that allow for varying levels of organic content.

100% organic
organic 95-100%
made with organic 70-94%
contains organic <70%

Of course there are very detailed regulations relating to how these labels can be used and there is not wiggle room for "oops" Only "organic" and "100% organic" may carry the USDA organic seal.

Perhaps there is room for RA to address the shortcomings and create a more transparent labeling system?

[Wendy De Jong]

I wonder if the 10% "slippage" allowance also applies to the use of the regular Rainforest Alliance Certified logo, with only 30% RA certified content required for roasters to use the logo on packaging?

-Wendy

[Demian L]

This "slippage" as defined by the comments made in this thread and by the comments made by a representative of Rainforest Alliance mentioned elsewhere by the original poster, is not allowed with Fair Trade Certified coffees in the USA market.

If a Fair Trade Certified logo is on a package of coffee, 100% of those beans must come from a FTC co-operative and must have been purchased under FTC terms. There are allowances made for flavorings (probably not a concern to members of this board ) which comopose a miniscule amount of the final product weight. This standard for FTC coffees is backed up by inspections of licensee roasting facilities for the purpose of auditing the supply chain from finished product back to producer.

The representative of RA who made the comment on this thread: http://www.coffeehabitat.com/2009/06/when-is-100-not-100.html is wrong.

Best Regards,

Demian Luper
Coffee Account Manager
TransFair USA
1500 Broadway Suite 400
Oakland, CA 94612
http://www.fairtradecertified.org

[russprefontaine]

I also do not agree with being able to put an RFA sticker on your coffee as long as a blend contains 1/3 RFA Certified Beans.

They say you need to let your clients know what percentage is in the blend, but the fact that you can still have the RFA Logo on the bag doesn't seem right to me.

[CravesCoffee]

Bob Rice from Smithsonian Migratory Bird Center also responded to this post. In it he notes:

Stating up front that you're going to allow 90% purity to leave the farm and allow that to be considered 100% can only work against you in the long run. If you're expecting 10% "leakage", then you may well get that much leakage on your 90% rule--and perhaps even more, given that those at origin know you're not expecting 100%. It simply puts you in a difficult position from the start....In discussing this issue with many people, I've found that those who are concerned about environmental and/or social issues and look for such seals expect nothing short of 100% purity.

His whole reply is here: http://www.coffeehabitat.com/2009/07/more-on-the-purity-of-certified-coffees.html

[Tim Dominick]

Perhaps the fair trade slippage relation made by RA is rooted in non-coffee products such as sugar and cocoa? It does not excuse the shortcoming but it does explain the rationalization.

More specifically, the truth that a significant percentage of the sugar and cocoa you buy labeled as FT may not actually be 100% FT by weight. Here is how I understand the idea, if I am missing something I am sure someone can correct me:

Farmer A brings in 1 ton of FT cocoa or sugar. The mill won't process less than 4 tons at a time. It is entirely acceptable for the mill to add Farmer B's 3 tons of non-FT cocoa/sugar to the 1 ton of FT cocoa in order to justify turning on the machines and process the cocoa/sugar

There resulting pile is just under <4 tons of processed cocoa/sugar. It is legitimate under current FT policy to sell 1 ton of this as FT, even though it has been blended with 75% non-FT cocoa/sugar. The balance may not carry the label.

This is not the case with coffee, I am clear on this point. In much the same way the "slippage" happens with RA coffee it is is happening with other certified products from other certifications systems.

Going back to the discussion surrounding risk of eroding consumer confidence, indeed both of these largely unspoken realities present a challenge and potential tarnish to the brand imagery, concepts and rhetoric that compose the marketing of certified products. Bottom line, chinks in the armor for one certification cause consumers to question the validity all certifications.

Both of these instances are not corruptions and they happen above board, however neither are entirely consistent with the consumer-level messages from the organizations.

One analogy that made sense related the "slippage" to the era of payments for indulgences to the church. Not always black and white I suppose.

[Alex Morgan]

We’re sorry this thread has gotten this far. There seem to be some general misconceptions about our system and about the labeling criteria for Rainforest Alliance Certified™ coffees. First of all, coffees that are sold throughout the supply chain beginning at the farm level are 100% Rainforest Alliance Certified and there is no allowance for coffees traveling from farms to exporters to importers and to roasters to be less than 100%. Secondly, the 90% labeling threshold is based on an assumption of a 100% bean equivalent. For instance if roaster X would like to sell 100 lbs. of Rainforest Alliance Certified™ roasted coffee, then roaster X must purchase the green equivalent to 100% certified roasted coffee (due to the roasting, the weight of 100 lbs of green coffee will actually decrease as roasted coffee).

The 90% labeling threshold is based upon the fact that many large roasters do not batch roast, but rather roast with a continuous flow of coffee throughout the factory. The labeling requirements ensure that the 100% coffee equivalent is purchased, but allows such companies to use their funds to invest in certification, farmers and the environment rather than in separate roasting facilities. Because we measure our impacts on the ground with farmers, communities and the environment, we encourage this type of investment rooted in coffee growing origins and communities. The alternative is for roasters that purchase Rainforest Alliance Certified coffees to build additional roasting facilities, reduce the efficiency of their facilities or to just avoid certified coffees all together, an end result nobody on this thread should support.

I'm happy to answer any more questions you may have so feel free to contact me directly if you would like as well. Thanks very much,
Alex Morgan
Business Development Manager
Sustainable Agriculture Division
Rainforest Alliance
ph (206) 658.7613
amorgan@ra.org

[CravesCoffee]

Alex,

Thanks for replying. You wrote,

First of all, coffees that are sold throughout the supply chain beginning at the farm level are 100% Rainforest Alliance Certified and there is no allowance for coffees traveling from farms to exporters to importers and to roasters to be less than 100%.

There is some sort of problem, then, with producers (or RA reps) not understanding this rule. At the conference I attended, one of a number of producers in the room asked, "How much are we allowed to mix in without penalty?" and the RA rep answered, nearly verbatim, "I'd have to check, but probably the same amount roasters can mix in, about 10%". A big roomful of people walked away with the same impression I did. Hopefully, this was a one-time dispension of bad information -- is that what you are saying? Just to be explicit: No mixing allowed at the farm level, period?

The rest of your explanation provides your reasoning for the "slippage allowance." You said,

The 90% labeling threshold is based upon the fact that many large roasters do not batch roast, but rather roast with a continuous flow of coffee throughout the factory. The labeling requirements ensure that the 100% coffee equivalent is purchased, but allows such companies to use their funds to invest in certification, farmers and the environment rather than in separate roasting facilities.

It sounds to me that you are describing the same situation Tim did when providing an example from cocoa/sugar, only at the roaster rather than the mill and with a 90% limit. Here's Tim's description:

Farmer A brings in 1 ton of FT cocoa or sugar. The mill won't process less than 4 tons at a time. It is entirely acceptable for the mill to add Farmer B's 3 tons of non-FT cocoa/sugar to the 1 ton of FT cocoa in order to justify turning on the machines and process the cocoa/sugar

The resulting pile is just under <4 tons of processed cocoa/sugar. It is legitimate under current FT policy to sell 1 ton of this as FT, even though it has been blended with 75% non-FT cocoa/sugar. The balance may not carry the label.

Organic, FT, and Bird-Friendly do not have a slippage allowance, according to their representatives. Apparently, these coffees are processed by roasters that do not have separate facilities, as you indicated would be necessary without the rule.

I'm not a coffee professional, so perhaps I'm missing something here, but I don't know that we are any further along than where we started.

Can you point me to a link to a PDF of sample agreements between SAN/RA and producers and roasters? Maybe it would make more sense for me to see the actual rules in writing.

[Tim Dominick]

The 90% labeling threshold is based upon the fact that many large roasters do not batch roast, but rather roast with a continuous flow of coffee throughout the factory.

By the numbers, how many RA roasters use this roasting style? I suspect less than 10% of the roasters use this style as it is not commonly used for specialty coffee production (which is the bulk of RA coffee, correct?)

Secondly, the 90% labeling threshold is based on an assumption of a 100% bean equivalent. For instance if roaster X would like to sell 100 lbs. of Rainforest Alliance Certified™ roasted coffee, then roaster X must purchase the green equivalent to 100% certified roasted coffee (due to the roasting, the weight of 100 lbs of green coffee will actually decrease as roasted coffee).

So, in reality it is possible to have a bag of coffee with an RA label that actually contains 0% RA coffee because it came from the 10% at the front of the continuous flow? While I get the equivalency concept, I have to say from a purity/marketing standpoint it is a risky proposition that cannot be explained away if/when an activist consumer catches wind of what appears to be a bow to the largest roasters among the program.

As a roaster who has a rather informed/activist clientele it presents a challenge to market with a brand image (RA, TFUSA) when there are allowances that can be viewed as similar to an indulgence from the church. (not my line, but this is what an activist customer brings to the discussion) It puts us in a difficult position as we attempt to embrace the programs knowing full well that the motivation of RA/TF is to be as inclusive as possible, even if at times it means compromising to further expand the market.

Market expansion fuels innovation on the parts of nimble and smaller roasters. I cite the move towards transparent/direct trading as a natural evolution beyond FT, in organics we see groups like the Mendocino Renegades taking it beyond NOP standards. This is a net positive for everyone, however as a brand image grows from the grass roots to the mainstream it is very common for the smallest to branch out in search of the next step. In the wake it spurs discussions like this one.