Better Cotton producers are not required to implement climate or emissions management plans – while climate considerations may be part of the Continuous Improvement Plan, there is no threshold to meet in implementation and review only takes place once every 5 years.

While general monitoring is an important aspect of the Better Cotton management system, the current principles do not require producers to conduct emission monitoring. Better Cotton is however demonstrating actions towards introducing GHG emission monitoring and strategy through the Delta Framework for scope 1, 2 and 3 emissions. In addition, the program management plans respond to the monitoring results and set clear climate targets.

Emission reduction targets are one of the five core prioritized impact targets for Better Cotton. A continuous improvement plan against set targets is required and measured against.

Climate Change Mitigation practices are demonstrated as key principles for Better Cotton. Producers are required to demonstrate climate mitigation practices through improving fertilizer management and managing soil carbon.

Climate Change Adaptation practices are demonstrated as key principles for Better Cotton. Producers are required to demonstrate climate adaptation practices through soil practices.

Better Cotton requires producers to use an HCV assessment to identify, and maintain such values on the production unit – below-ground carbon stocks qualify as they are a focal point of HCV II and III: Landscape-level ecosystem mosaics and Ecosystems and Habitats [respectively].

Better Cotton requires producers to use an HCV assessment to identify, maintain and monitor those values relating to above-ground carbon stocks.

Better Cotton requires producers to conduct soil type and texture determinations to evidence soil carbon sequestration measures.

The Higg MSI does not hold LCA data for Better Cotton.

The Higg MSI does not hold LCA data for Better Cotton.

Better Cotton producers are required to adopt a Water Management Plan to optimize water use for both irrigated and rain-fed crops. The plan must show an understanding of water resources, soil moisture management, irrigation methods, and the quality of surface and groundwater.

Better Cotton producers are required to uphold good water stewardship practices; understanding their own water use, the catchment context and the shared risk in terms of water governance, water balance and important water-related areas.

Better Cotton producers are required to uphold good water stewardship practices; understanding the catchment context and the shared risk in terms of water governance, water quality and important water-related areas.

Water health is named as a prioritized outcome for Better Cotton. Producers are required to develop and implement a Continuous Improvement Plan [CIP]. Although the CIP does not require specific water-related measures, the Water Management Plan does demonstrate collective, sustainable decisions and improvements on water quantity.

Water health is named as a prioritized outcome for Better Cotton. Producers are required to develop and implement a Continuous Improvement Plan [CIP]. Although the CIP does not require specific water related measures, the Water Management Plan does demonstrate collective, sustainable decisions and improvements on water quality.

Better Cotton producers are required to understand water availability to better manage water resources. Surface/groundwater is outlined as a priority in this context.

Better Cotton producers are required to understand water quality to better manage water resources. Surface/groundwater quality is outlined as a priority with salinity test as corresponding criteria.

Cotton feedstock is 100% biobased, however, Better Cotton currently do not have any commitments to renewable energy sources to be utilized by the producer, therefore contributing to oil and gas extraction.

The Higg MSI does not hold LCA data for Better Cotton.

The Higg MSI does not hold LCA data for Better Cotton.

The Higg MSI does not hold LCA data for Better Cotton.

Better Cotton requires producers to adopt an IPM [Integrated Pest Management] with an emphasis on avoiding pesticide application at all costs. Better Cotton also requires producers to adhere to the restricted chemicals list, along with category 1 and category 2 of phased-out chemicals.

Better Cotton mandates that appropriate PPE is used when handling pesticides. Better Cotton’s Prohibited Pesticide List aligns with the Stockholm Convention, Rotterdam Convention and Montreal Protocol. In addition, Producer Units are required to hold an effective management system in place to measure against indicators and continuous improvement. An Integrated Pest Management [IPM] strategy is required and includes training, awareness-raising and monitoring. Evidence should be available on qualified handlers of pesticides, training and how the requirements are met.

Although Better Cotton producers are not required to conduct chemical monitoring actions, chemical restrictions align with the Stockholm Convention on Persistent Organic Pollutants and substances listed in the annexes of the Montreal Protocol on Substances that Deplete the Ozone Layer [a protocol of the Vienna Convention for the Protection of the Ozone Layer].

Better Cotton demonstrates continuous improvement methods by ongoing reviews of chemical restriction lists, adding new criteria when appropriate.

Better Cotton names chemical discharge as a prioritized outcome, eliminating the use of high-toxicity pesticides and increasing the use of natural pest control – prioritizing organic pesticides [such as neem oil] with low toxicity and high efficacy against multiple target pests.

The Higg MSI does not hold LCA data for Better Cotton.

Better Cotton requires the development and implementation of a soil management plan. Good soil management practices are required to maintain and enhance soil structure and fertility, in order to achieve optimal conditions for plant growth.

The soil management plan required for Better Cotton producers defines the quantity and timing of available nutrients and should be based on a combination of soil and plant analyses.

Soil health is named as a prioritized outcome for Better Cotton producers and demonstrated continuous improvement plan.

Better Cotton demonstrates prioritized outcomes for soil microbial health, soil carbon cycle, soil structural health, soil water cycle and soil nutrient cycle. Although chemical use is considered, soil chemical balance is not evidenced as a prioritized outcome.

Beneficial Soil health practices are required for Better Cotton producers, namely, crop rotation.

Better Cotton requires land management practices through the Better Cotton Biodiversity Enhancement & Land Use principles. Producers must identify degraded areas and define ways to restore and enhance them. Additionally, in the case of any proposed conversion from non-agricultural land to agricultural land, Better Cotton High Conservation Value risk-based simplified approach must be implemented.

Better Cotton names land health in the form of HCV’s and their continued enhancement as a priority outcome in the certification.

Better Cotton requires producers to identify risks due to expansion. In addition, Better Cotton requires the use of the HCV assessment to identify,
maintain and monitor those values over time.

The cutoff date for land conversion held by Better Cotton is January 1, 2016. Land conversion occurring prior to 2016 shall be considered for the BCI license, subject to compliance with local legal requirements for land use change in existence at the time of conversion. This allowance is consistent with the requirement of the Better Cotton Standard at that time.

Better Cotton requires producers to adopt a Biodiversity Management Plan that conserves and enhances biodiversity on and surrounding the farm, including: Identifying and mapping biodiversity resources, identifying and restoring degraded areas, enhancing populations of beneficial insects as per the Integrated Pest Management plan, ensuring crop rotation and protecting riparian areas.

Biodiversity identification and mapping is required for all Better Cotton producers through local or national collaboration. In the case of conversion of non-agricultural land to agricultural land, identifying and mapping biodiversity can be combined with the HCV assessment, which also includes resources identification to maximize efficiency.

Biodiversity is named as a prioritized outcome for Better Cotton producers, considering the impact of expansion and restoration practices. A Continuous Improvement Planning process is required by all Better Cotton producers, identifying priority areas for the producer to adapt the Biodiversity Management Plan.

Better Cotton producers must have plans in place for the protection and recovery of buffer zones, riparian areas, native species and corridors.

Better Cotton is exploring landscape approaches through Adaptation to Landscape Approach [ATLA] project. The purpose of the ATLA project is to help Better Cotton identify opportunities to evolve its approach and systems to support work at landscape or jurisdictional level in areas where this can deliver the most value. Despite this, there seem to be no commitments made to set-aside a proportion of production land.

Better Cotton requires produces to foster positive human-wildlife coexistence through encouraging chemical control by ensuring chemicals utilized at farm level do not contribute to degraded areas. However, in some case certain levels of chemicals are allowed by law.

There is no evidence that Better Cotton requires producers to take precautions to restrict the spread of invasive species onsite.

For cotton production, it is important to avoid contamination of fiber during harvest, storage, transport, ginning and baling [pressing]. Better Cotton producers are required to adopt good management practices to maximize fiber quality. These could include harvest management and general hygiene, choice of materials, how and where cotton is stored, and how cotton is transported – though no requirements on reducing waste during production are present in the certification.

Better Cotton producers are required to adopt good management practices for crop protection and waste management – evidence of tracking waste streams for reuse is present in Better Cotton certification

Cotton is a perennial plant and a renewable feedstock. However, Better Cotton makes no commitment to using recycled feedstock.

Better Cotton requires: adherence to minimum wages, as per the statutory national, regional minimum applicable, or the collectively agreed upon wage, and that steps are taken to improve wages over time; compliance with laws and regulations regarding breaks, collective bargaining and access to water; sharing contract details with workers, appropriate to the language and communication necessary; and that civil or temporary contracts are not exploited. MFs and LFs are expected to keep records of working hours and wages; as well as records of any accidents.

Better Cotton requires adherence to ILO Convention 29: to prohibit forced labor and ensure freely employed workers; to employ a monitoring system to identify and address risks; provide secure channels to report rights violations, receive protection, and remediation; provide training and awareness programs to enhance workers’ understanding of their rights; and collaborate with local organizations including the Gender Committee. Furthermore, data collection, validation, and reporting are supported by capacity-strengthening activities such as training.

Better Cotton requires adherence to ILO Conventions 138 and 182: to not employ or benefit from child labor or employ young workers to perform hazardous work; to employ a monitoring system to identify and address risks, provide secure channels to report rights violations; receive protection and remediation, provide training and awareness programs to enhance workers’ understanding of their rights; and collaborate with local organizations including the Gender Committee. Furthermore, data collection, validation, and reporting are supported by capacity-strengthening activities such as training.

Better Cotton requires adherence to ILO Conventions 187 and 111, prohibiting labor discrimination in hiring, tasks, compensation, training, promotion, termination, and retirement. It employs a monitoring system to address risks and offers secure channels for reporting rights violations and obtaining protection and remediation. Training and awareness programs enhance workers’ rights awareness. Collaboration with local organizations, including the Gender Committee, is encouraged. Data collection, validation, and reporting are supported by capacity-strengthening activities.

Better Cotton requires adherence to ILO Conventions 87 and 98, protecting workers’ rights to form organizations and negotiate collectively. It employs a monitoring system to address risks and offers secure channels for reporting violations and receiving protection. Training and awareness programs enhance workers’ rights understanding. Collaboration with local organizations, including the Gender Committee, is encouraged. Data collection, validation, and reporting are supported by capacity-strengthening activities.

Better Cotton requires adherence to ILO Convention 155: ensure a safe environment with risk identification and mitigation; provide PPE; ensure that verifiers engage with workers; medical attention is provided; steps are taken to prevent re-occurrence; workers or representatives are informed and consulted on OSH rights, including gender sensitivity; secure channels are provided to report rights violations and receive protection and remediation; training and awareness programs enhance workers’ rights understanding and collaborate with local organizations including the Gender Committee; data collection, validation, and reporting are supported by capacity-strengthening activities.

Better Cotton includes a core theory of change. Producers are required to: provide an effective program to implement, which aims to strengthen the capacities of workers through training and related activities; support workers to receive a living wage; and take steps to strengthen knowledge and awareness on workers’ rights and minimum wages, supporting income-generating and livelihood projects including gender-sensitive approaches.

Better Cotton requires adherence to respecting legal and customary land rights of Indigenous peoples in accordance with free, prior, and informed consent [FPIC] and engagement with Indigenous groups and local communities affected by operations.

Better Cotton requires adherence to applicable laws and regulations relating to land rights, taking measures to identify and mitigate any social and/or environmental risks that the farm operation poses to surrounding communities and land. Producers should inform and consult with concerned and affected stakeholders to obtain free, prior, and informed consent, and provide a safe and trusted space.

Better Cotton requires producers to: develop and implement a clear and locally relevant community consultation and engagement activity plan; carry out annual inclusive field-level planning and needs and priority-setting; take measures to identify and mitigate any social and/or environmental risks that the farm operation poses to surrounding communities and land; and develop and implement a monitoring plan with a feedback structure including representation from women, youth and people in vulnerable situations and/ or facing exclusion.

Better Cotton requires producers to strengthen the capacity of individuals, identify key livelihood focus areas, and monitor risks. In addition, Better Cotton has demonstrated that where a weak enabling environment was identified, activities are suspended.

Better Cotton requires producers to provide workers with access to impartial, effective, and secure channels to raise concerns about rights violations and grievance mechanisms and includes the ability for workers to raise complaints anonymously. Where labor rights violations occur and grievances are raised, access to protection and remediation is available. A complaints monitoring team is in practice and for any gender-related labor rights violations or gender-related grievances, the Gender Lead or Gender Committee should be involved.

Better Cotton requires producers to ensure: that there is no gender-based discrimination or violence in labor practices; that there is equality in hiring, tasks, compensation, training, promotion, termination, and retirement; a Gender Lead or Committee supports women’s participation and recognition; a monitoring plan identifies risks, and a grievance mechanism is established; data, collected through consultations, is validated and shared for learning purposes.

Better Cotton’s 2030 Strategy mentions the desired sustainability impacts and strategies undertaken to achieve these impacts. Measurable and time-bound Impact Targets are defined, and part of Better Cotton’s strategy is to more actively embrade their leadership position. There is an explicit link made to the Theory of Change and the position of the standard in the Theory of Change in the introduction to the Better Cotton Principles & Criteria.

Better Cotton has a separate standard-setting and revision process. Its latest Principles & Criteria [v3.0] were released in 2023, to be reviewed in 2028. Non-substantive changes can be made, while substantive changes require the revision procedure. Public consultation is required for new standards [two rounds] and revisions [at least one round]. There is no mention of research going into the effectiveness of indicators in the standard.

Better Cotton has a Multistakeholder Council consisting of elected members, and a Secretariat which implements the Council’s decisions. The roles and responsibilities of Secretariat members are clearly distinguished. Better Cotton is open to membership for various stakeholder types. They have a Member Code of Practice including a business integrity section, anti-trust policy, safeguarding policy, and whistleblowing policy.

Better Cotton has a separate claims policy called the Better Cotton Claims Framework. It uses a mass balance system, making physical traceability of Better Cotton to end products impossible. Claims must include the definition of mass balance and the organization’s sustainable sourcing percentage. Misleading claims can lead to warnings, corrective actions, suspension, or expulsion. Better Cotton allows advanced outcome-based claims, providing a methodology for calculating impact.

Better Cotton employs an assurance model that combines third-party verifier assessments with other assessments for credibility and cost-effectiveness. The model includes visits, licensing assessments, support visits, and self-assessments. Third-party verifiers undergo training. Better Cotton does not collaborate with Accreditation Bodies. Surveillance audits are conducted once within the 3-year license period, and claims management is separate from verifiers’ responsibilities.

Better Cotton’s Assurance Manual outlines conformity assessments, differentiating between incidental and systemic non-conformities. Systemic non-conformities can result in certification denial or cancellation. There is no evidence of denial or cancellation of verification parties’ accreditation. Producers are motivated to comply with the standard through various mechanisms based on organization size. Certification bodies are motivated to share assessment outcomes with Better Cotton.

Better Cotton requires assurance parties to conduct additional verification activities in identified risk areas. It publishes a Risk Policy that aims to identify, register, and manage risks. However, no risk map or overview was found. Risks are determined by the likelihood and impact of a threat occurring, categorized as high or low.

Better Cotton has a ‘Complaints’ web page for easy filing via a form or email. The ‘Contact’ page allows stakeholders to provide feedback using a form. Better Cotton handles licensing decisions and complaints internally, and complaints related to assessors are directed to them. Stakeholders are informed of consultation moments for significant updates to the assurance system.

Better Cotton’s Impact Report outlines the MEL system framework and its approach to evaluating impact. Evaluation occurs annually, comparing the results of Better Cotton Farmers to non-participating farmers. They have a Policy on Communicating Data, specifying data availability for stakeholders for what purpose. The Impact Report highlights organization activities and their contribution to the Theory of Change impacts. It serves as a progress report on sustainability goals.

CmiA requires producers to conduct an environmental assessment. Fuel and land use data are required in the environmental assessments.

CmiA requires producers to implement a management plan. The corresponding monitoring process is reviewed annually – verified by a 3rd-party. The results are also used for remediation actions by the managing unit. The scope of the environmental assessment only extends to scope I emissions.

CmiA requires producers to record measures taken by managing entities to reduce greenhouse gas emissions.

CmiA recognizes that the changing climate will affect agricultural production and trains farmers on practices to reduce the impact of climate change: soil health practices, soil monitoring and climate resiliency training for cotton production.

CmiA recognizes that the changing climate will affect agricultural production and trains farmers on practices to support against extreme weather events through: soil health practices, and rainfall storage.

CmiA requires managing entities to map and identify HCV areas in and around production zones. The monitoring is for HCV’s 1-6, meaning below-ground carbon stocks qualify as they are a focal point of HCV II and III: Landscape-level ecosystem mosaics and Ecosystems and Habitats [respectively].

CmiA requires managing entities to map and identify HCV areas in and around production zones. The monitoring is for HCV’s 1-6, meaning above-ground carbon stocks qualify as they are the focal point of HCV II and III: Landscape-level ecosystem mosaics and Ecosystems and Habitats [respectively].

Evidence for soil carbon is most likely to be presented in the form of proxy measurements such as: soil structure and fertility as outlined in the components of a soil health management plan.

The Higg MSI holds LCA data for Cotton Made in Africa.

The Higg MSI holds LCA data for Cotton Made in Africa.

CmiA requires a water stewardship plan that is time-bound and must have site-specific considerations such as the mapping and identification of production zone water resources.

CmiA mandates the monitoring of water pressure through identifying water resources in production zones and prohibiting the extraction of surface or groundwater for production.

CmiA mandates the monitoring of water pressure through identifying water resources in production zones and prohibiting the extraction of surface or groundwater for production.

No use of surface or groundwater in production is mandated by CmiA in order to reduce water pressures associated from withdrawing from critical water resources.

Water quality is named as a prioritized outcome in the CmiA certification. The program provides documents and training on the importance of water quality in cotton production.

Surface and groundwater use are prioritized outcomes in the CmiA certification.

Water quality is a prioritized outcome in the CmiA certification – with a particular focus on maintaining surface and groundwater quality despite the use of chemicals/pesticides.

As a biobased feedstock, cotton doesn’t run risks of oil and gas extraction, though as no commitments to renewable energy are made in CmiA, risks of extraction contaminating water still exist.

The Higg MSI holds LCA data for Cotton Made in Africa.

The Higg MSI holds LCA data for Cotton Made in Africa.

The Higg MSI holds LCA data for Cotton Made in Africa.

CmiA takes steps toward an explicit chemical management plan with its required implementation of Integrated Production and Pest Management plans [IPPMs]. The IPPM takes site-specific factors such as pesticide and application techniques into account. CmiA IPPMs are reviewed for conformance annually.

CmiA outlines requirements for producers to store, handle, clean, and dispose of chemicals used in production in an appropriate manner. The standard provides training in regard to the use and care of PPE, though it is unclear if this training extends beyond PPE in focus. There is a responsible person[s] to oversee implementation of best practice in chemical handling and application. The environmental management plan, which encompasses chemical management practices, is reviewed regularly.

CmiA requires managing entities to monitor the sources of the chemicals used in production, representative of measuring the state of chemical use. CmiA also requires producers to follow a widely accepted chemical ban list such as the Stockholm, Rotterdam and Montreal Conventions.

CmiA requires managing entities to implement an Integrated Production and Pest Management plan [IPPM] to grow a healthy crop without the impacts of negligent chemical use. The IPPM aims to continually reduce such impacts through monitoring pests, and chemicals used and optimizing processes based on results.

CmiA employs input chemical bans and prioritizes avoidance of water quality detriment through training in chemical application, with discharge into water as a focus point.

The Higg MSI holds LCA data for Cotton Made in Africa.

CmiA requires a soil health management plan that is time-bound and must have site-specific considerations such as the mapping and identification of production zone water resources.

CmiA producers are required to monitor soil for outlined soil health outcomes: structure, nutrient cycling and water retention.

Soil health is named as a prioritized outcome under the CmiA certification. Continuous improvement on soil fertility, structure and water retention is required for managing entities.

Soil nutrient health is outlined as a priority, measured with soil fertility testing. Additionally, soil structure is a prioritized outcome with soil erosion as the corresponding metric.

CmiA requires managing entities to improve soil health through all of the outlined soil health practices: Crop Rotation, Inter and Cover-Cropping, Crop Residues and Organic Amendments, and Low-Till.

CmiA requires managing entities to identify and map critical land features on/around production zones. It puts in place remediation and restoration actions, and is reviewed by 3rd-party for verification every 1-2 years.

CmiA follows national legislation for actions on land use and doesn’t allow producers to grow cotton on land that is not intended for agricultural use. However, no frameworks for deforestation or land conversion cut-off dates are supplied or mandated.

CmiA follows national legislation for actions on land use and doesn’t allow producers to grow cotton on land that is not intended for agricultural use. However, no frameworks for deforestation or land conversion cut-off dates are supplied or mandated.

CmiA follows national legislation for actions on land use and doesn’t allow producers to grow cotton on land that is not intended for agricultural use. However, no frameworks for deforestation or land conversion cut-off dates are supplied or mandated.

CmiA requires a biodiversity management plan that is time-bound and must have site-specific considerations such as the mapping and identification of production zone High Conservation Values and enhancing buffer and riparian zones.

CmiA requires managing entities to identify and map HCV areas on and near the production zone, where HCVs are found, biodiversity figures for those areas must be maintained.

CMiA outlines key biodiversity outcomes in the statement of the management plan; the continued identification, protection, and restoration [if necessary] of HCV, riparian and buffer zones are required. Additionally, biodiversity values in HCVs must be maintained in the face of production.

CmiA outlines key area’s for managing entities to protect and maintain or restore if degraded: habitat corridors, buffer and riparian zones.

As CmiA is made up of around 95% smallholder farmers, [below 20 hectares, no year-round workers, etc.] set-asides are not relevant or required.

CmiA mandates species and genetic diversity protections in the form of restoring habitat corridors/migration pathways, restricting the use of chemicals in pest control, and identifying threatened or endangered species in the production zone.

CmiA uses biological controls to prevent the spread and build-up of pests/invasive species in the production zone.

Waste management plans are categorized as continuous improvement criteria in the CmiA program – meaning non-conformance doesn’t disqualify from certification. It does require identifying waste streams and actions to reduce and reuse waste on a site-specific level, however, there isn’t evidence that supports precision planning and production taking place. Documentation of waste reduction actions is supported, though not tied to management responses or specified waste reduction goals.

Waste at the field level for cotton production is minimal, and many by-products such as the seed are reused in a variety of ways. For CmiA, waste is required to be separated and disposed of according to local requirements.

Cotton is a perennial plant and a renewable feedstock. However, CMiA makes no commitment to using recycled feedstocks.

CmiA requires adherence to a 48-hour weekly limit and ensures breaks, leave, sick days, and the right to collective bargaining. It guarantees wages meeting regional or national minimums, irrespective of gender, and maintains mandatory records for wage and hour verification. Clear contracts must outline wages, responsibilities, time off, and social security benefits in easily comprehensible terms. Verifiers must engage with workers and possess expertise in relevant worker rights legislation.

CmiA requires producers to adhere to ILO Conventions 29 and 105 on forced labor. The standard outlines specific actions that qualify relating to the cotton fiber growing and ginning production processes. Additionally, the standard provides a secure channel for grievances and remediation—allowing workers to raise concerns about forced labor in an anonymous manner.

CmiA requires adherence to ILO Conventions 138 and 182 through a time-bound plan to eliminate child labor at the field and gin levels. This includes child labor awareness and risk assessments at the producer level; a complaint and compensation mechanism is in place and spot checks are conducted by the managing entity to check the age of workers; and a secure channel for grievance and remedy that is equally accessible to employees, children, and the local community. 

CmiA requires producers to put a non-discrimination policy in place that aligns with ILO Convention 100, a time-bound plan for improving the position of identified minority groups and a code of conduct that is communicated to employees and contracted workers.

CmiA requires that producers respect the right to collective bargaining in line with the ILO Conventions 87 and 89. CmiA raises awareness for workers on their right to collective bargaining and provides a secure channel for workers to raise concerns on freedom of association. Additionally, worker and union representatives meet with verifiers as part of the verification and stakeholder engagement processes.

CmiA requires producers to implement a set of health and safety procedures that includes: personal protective equipment[PPE]; a training program; access to clean drinking water/sanitation; and a designated health and safety focal person who engages with management and verifiers. Verifiers should have competencies in health and safety as it relates to regional fiber production. Furthermore, CmiA implements measures on the safe handling of chemicals and provides a secure channel for health and safety-related grievances.

CmiA requires producers to commit to improving farmer income and quality of living—this is outlined in the standard’s Theory of Change. CmiA also takes a gender-based approach in addressing livelihood concerns; wages are to be paid to women farmers when relevant, and training and financing opportunities are to be equally applied. CmiA promotes stronger relationships between producers and customers, and a Monitoring and Evaluation process is in place that shows evidence of positive outcomes with regards to worker incomes.

CmiA requires producers to respect Indigenous land through the HCV values, though it is only stipulated in cases of proposed expansion/conversion. The standard has a grievance and remedy procedure in place to raise points on Indigenous land and customary rights, to identify and implement a solution.

CmiA requires adherence to legal and customary land and water tenure in accordance with both national law and the HCV Network. CmiA also requires a secure channel for grievances regarding land rights.

CmiA requires producers to conduct risk assessments in addition to external verification—the risk assessment must include community risks resulting from production. Additionally, a required component of verification is verifier engagement with the local community.

There is no evidence that CmiA requires producers to address risks related to enabling the environment for human rights. In particular, there is no evidence that CmiA has requirements for a process to periodically evaluate and test whether there is a sufficient enabling environment for the program’s Theory of Change in the countries or regions in which the program operates or is seeking to operate.

CmiA requires producers to provide a process that allows for grievances to be made anonymously and without fear of discrimination, termination or reduction in pay, etc. The process must also have dedicated resources for complaints of gender-based discrimination and sexual harassment. However, while the producers must assist verifiers in interviewing workers as part of the verification process, it is unclear whether these interviews would be essential to the grievance mechanism.

CmiA requires producers to take steps to prevent gender-based discrimination and address corresponding risks. This takes the form of a gender-based focal person with a direct line of communication to management, as well as raising worker awareness of gender-based violence and discrimination. Additionally, there is a requirement in place that verification must be done, in part, by women.

The organization released a Theory of Change document detailing its sustainability goals and strategies. The standard document clarifies the purpose of the standard in relation to the Aid by Trade Foundation’s overall objectives. The goals outlined in the Theory of Change are measurable, but do not have specific timeframes. The organization does not actively socialize its theory of change.

The organization has a standard development and revision procedure. Reviews should not exceed five years from the adoption of the former standard. Non-substantive changes can be made outside the formal revision process, but there is no mechanism for urgent substantive changes. Drafts require at least one round of public consultations. For developing a new standard, a demand assessment is conducted, along with a risk assessment of factors that may hinder the standard from achieving its objectives.

The organization’s governance comprises a Management Board, Board of Trustees, and an Advisory Board representing stakeholders. A Code of Conduct establishes essential guidelines, including anti-bribery and anti-corruption policies. The website specifies the roles and responsibilities of the Management Board. The Advisory Board includes several companies and offers partnership opportunities, including strategic partnerships.

The organization provides a separate document on its claims framework. It also has a separate document specifically dedicated to Chain of Custody (CoC) guidelines, which distinguish between Mass Balance and Hard Identity Preserved. The CoC guidelines outline the process for making claims based on the chosen model. The claims framework establishes procedures for non-compliance related to the improper use of claims.

The standard organization documents its approach to overseeing assurance activities and providers. While a third party provides verification, it is not clear whether the organization works with an independent accreditation body. Not all roles and responsibilities for certification and accreditation bodies are clear. The verification cycle spans two years and involves two verification missions at different levels. The standard document offers guidance on the content and practices of assurance.

The assurance manual outlines conformity assessment procedures, distinguishing between incidental and systemic non-conformities. Sustained systemic non-conformities result in certificate cancellation or accreditation termination. The standard organization covers verification fees, including travel and accommodation expenses, if audit data is shared promptly. There are no motivation mechanisms for certified organizations to adhere to the standard with zero non-conformities.

Certification Bodies use a risk-based approach in their sampling decision. The organization does not have a risk management plan on how to identify and manage risks to the sector and organization, nor a risk map or overview to help certified organizations and assurance actors identify main current sector risks.

The organization’s website features a complaints form with accompanying instructions. Contact details are publicly available, including an email address for stakeholders to provide feedback. Furthermore, a separate document outlines the organization’s complaints policy and procedures, detailing the various roles and responsibilities involved. Stakeholders are not actively informed about opportunities to provide input.

The organization has a separate document dedicated to the monitoring, evaluation, and learning (MEL) framework of the standard. An annual publication provides the performance results for the year, based on the MEL framework. However, these do not measure the specific outcomes or impacts of the standard. No policy or procedure regarding data communication was found. The MEL framework is designed to align with the objectives and activities outlined in the Theory of Change.

Fairtrade encourages a site-specific, regularly reviewed emission management plan in development criteria to identify climate risks and GHG-reducing activities.

Fairtrade encourages producers to take measures to reduce GHG emissions during production. Producers monitor scope I emissions – aligned with international standards.

Fairtrade encourages cotton producers to take measures to reduce greenhouse gas emissions during production.

Fairtrade encourages producers to implement climate mitigation actions through the use of energy efficiency and replace non-renewable sources with renewables where possible.

Fairtrade promotes climate adaptation actions through development criteria on: capturing rainwater and practices to improve soil health and prevent erosion.

Carbon sequestration as a more general outcome is required of Fairtrade producers. However, there is no evidence that peat soils are identified and/or protected to achieve this goal.

Carbon sequestration as a more general outcome is encouraged of Fairtrade producers. However, there is no evidence that high above-ground carbon stocks are identified and/or protected to achieve this goal.

Fairtrade requires producers to increase carbon sequestration in production. The program also requires producers to increase soil fertility and prevent erosion – both proxy measurements for soil carbon.

The Higg MSI does not hold LCA data for Fairtrade Cotton.

The Higg MSI does not hold LCA data for Fairtrade Cotton.

Fairtrade producers are supported in developing a regional-level water management plan that focuses on continual improvement of water use in production. This plan is audited every 3 years and is responsive to the changes suggested in this audit.

Fairtrade requires producers to monitor the pressures and state of water withdrawal by identifying water sources for irrigation and measuring how much water is used for production. Training members on monitoring practices specifically in regard to the state of water use in the production unit takes place gradually, and like the management plan, is assessed every 3 years.

Fairtrade supports producers to monitor the quality of water used for irrigation and drinking on the production unit over time with producer-developed water monitoring plans that promote baseline knowledge of monitoring techniques.

Fairtrade supports producers in continually improving their water usage during production through non-pass-fail criteria assessed every 3 years.

Water quality for irrigation and drinking is named as a priority outcome under the Fairtrade certification.

Water use efficiency and improvement are to be developed by Fairtrade producers. While producers must list the sources they draw water from, no mention of specific water sources to accompany best water use practices is given.

Fairtrade specifies groundwater and surface water as prominent water sources to avoid contamination.

Fairtrade cotton is a 100% biobased feedstock. While the program doesn’t mandate a certain level of renewable energy, it is required for producers to implement it where possible.

The Higg MSI does not hold LCA data for Fairtrade Cotton.

The Higg MSI does not hold LCA data for Fairtrade Cotton.

The Higg MSI does not hold LCA data for Fairtrade Cotton.

Fairtrade requires producers to develop a chemical management plan as part of the certification. This plan is for the improvement of chemical use and management. It is reviewed and updated every three years.

Fairtrade requires producers to implement a chemical management plan that centers around handling, application, cleaning, labeling, and disposal of chemicals used in the production process.

Fairtrade producers must compile and update a list of pesticides used on Fairtrade crops. Producers are prohibited from using chemicals found in the Fairtrade International Hazardous Materials Red List. Chemicals found in this list are those that are; outlined in international conventions, and are known to cause acute, long-term toxic effects.

Fairtrade requires continual improvement/phasing out of harmful chemicals for safer and more sustainable alternatives.

Fairtrade names air and water discharge a priority outcome. It also mandates producers to follow a restricted chemistry list.

The Higg MSI does not hold LCA data for Fairtrade Cotton.

Fairtrade requires producers to implement procedures to identify, mitigate and prevent degradations to soil health through erosion.

Fairtrade requires the monitoring of the state of soil health in identifying soils at risk of erosion as well as the pressures to soil health in the identification of soils that have already eroded.

Fairtrade supports producers to continually improve soil health through the identification and prevention of erosion.

Fairtrade supports producers in developing specific soil health outcomes such as soil fertility, structure and carbon sequestration.

Fairtrade doesn’t require the implementation of soil health practices but does highlight several in order to reduce the impacts from pests. These practices are not required but can be implemented by Fairtrade producers.

Fairtrade requires producers to implement procedures to ensure deforestation and degradation of land do not occur. These procedures are reviewed at least every three years.

Preventative and restorative steps are taken by Fairtrade producers in regard to deforestation and land conversion. Additionally, pilot projects are being launched to incorporate satellite images of forest landscapes in production zones for visualizing land conversion/deforestation over time.

Preventative and restorative steps are taken by Fairtrade producers in regard to deforestation and land conversion. Additionally, pilot projects are being launched to incorporate satellite images of forest landscapes in production zones for visualizing land conversion/deforestation over time.

Land use health is named a priority outcome through the continual improvement of carbon storage ecosystems.

Fairtrade supports producers in developing a plan to protect and enhance key biodiversity features such as water bodies, high conservation value areas, and buffer zones. Fairtrade highlights communicating this plan and biodiversity awareness to all levels of the production unit.

Fairtrade supports producers in developing capabilities to monitor the pressures on biodiversity health via pests and plant diseases.

Biodiversity is named as a priority in the Fairtrade certification – producers are supported in maintaining and enhancing biodiversity values. This is not a required criterion, but a development one under the Fairtrade certification and is assessed every 3 years.

Fairtrade outlines maintaining, developing or creating buffer zones, especially around waterbodies on the production unit. Though these criteria are not required as core criteria, producers are supported in developing these practices.

There is no evidence that Fairtrade producers are required to set aside a portion of the production unit for conservation.

Fairtrade producers demonstrate consideration for species and genetic diversity by prohibiting hunting or over-collecting of endangered and native species.

Fairtrade outlines specific steps for dealing with invasive species: action to prevent their introduction, build-up, and resistance in the production unit.

The main risks associated with waste are linked to improper management of chemicals at the farm level. Fairtrade therefore requires producers to be aware of waste-reducing concepts and practices. In addition, Fairtrade highlights that burning of organic waste is prohibited unless under special circumstances.

Fairtrade encourages producers to develop a plan that is communicated to all members on using waste as a nutrient stream. Further, it only allows burning if legally required or on other exceptional occasions.

Fairtrade requires producers to acquire non-GMO seeds, which are a renewable feedstock.

Fairtrade requires adherence to ILO Conventions 98, 100, and 110 on collective bargaining, equal pay, and employment conditions. It mandates the following a national minimum wage and well-defined contracts stating employee duties, schedules, and rights. With regard to working hours, it aligns with the 48-hour limit and provides paid sick and maternity leave, overtime compensation, and gradual salary increments surpassing official minimums and regional averages.

Fairtrade requires adherence to ILO Conventions 29 and 105 to eliminate forced labor conditions and not benefit directly or indirectly from forced labor. There is a component of assessing risks of forced labor in operational areas with a grievance and remedy process in place to process and provide solutions for complaints.

Fairtrade requires producers to prevent and eliminate the worst forms of Child Labor in line with provisions in ILO Conventions 182 and 138 at both the field and gin levels. At the gin level, there is a procedure in place to handle grievances and provide remedies for any Child Labor-related issues.

Fairtrade requires producers to ban and prevent discrimination in the workplace in line with provisions listed in ILO Conventions 100 and 111. This includes discrimination based on age, race, sexual orientation, disability, or social origin. Requirements to raise awareness of discrimination among workers and management are also present in the standard, as well as procedures, to handle grievances and provide remedies for any discrimination-related issues.

Fairtrade requires producers to follow provisions set out in ILO Conventions 87 and 98 on the Freedom of Association and the Right to Organize and Collective Bargaining. This includes criteria on verifiers engaging with worker representatives, the program raising awareness for workers on their rights to organize and collective bargaining, and a grievance and remedy procedure in place to process complaints relating to freedom of association.

Fairtrade requires producers to implement an Occupational Health and Safety program that is in line with provisions set out in ILO Convention 155. This includes specific requirements on PPE and relevant training, on-site first-aid and sanitation, and the nomination of a health and safety representative. Fairtrade also requires that verification be contingent upon an assessment of the producers’ health and safety procedures.

Fairtrade includes a core Theory of Change that outlines commitments to improving workers’ wages and overall livelihoods. The standard provides technical training opportunities to increase yields and facilitates access to credit and inputs for workers to sustainably purchase materials.

Fairtrade requires producers to outline requirements for upholding land and water tenure in line with provisions set out in ILO Convention 169 on Indigenous and Tribal Peoples. Fairtrade’s criteria do not reference the UN Declaration on the Rights of Indigenous Peoples. These groups are only engaged if there is an evident land or water tenure dispute.

Fairtrade requires producers to maintain land and water tenure according to national law and in line with ILO Convention 169 on Governance of Tenure. However, no assessment of tenure risk is required, nor is it compulsory for verifiers to conduct assessments outside the production unit or communicate with communities and Indigenous groups.

Fairtrade requires producers to provide a Development Plan to engage in community development. However, it is unclear if the community is consulted as part of the standard-setting process, or if risks to communities are required to be assessed as part of the production plan.

There is no evidence that Fairtrade has requirements in place to address risks related to enabling the environment for human rights. In particular, there is no evidence that Fairtrade has requirements for a process to periodically evaluate and test whether there is a sufficient enabling environment for the program’s Theory of Change in the countries or regions in which the program operates or is seeking to operate.

Fairtrade requires producers to implement a set of comprehensive grievance and remedy procedures that are: clearly communicated to all relevant parties; completely anonymous; focused on providing remedy; and tailored to the complaint/grievance being filed. Specifically, this means that grievances regarding sexual harassment are sent to specially appointed women or women’s committees.

Fairtrade requires producers to take steps to eliminate discrimination on the basis of sex and to address risks of Gender-Based Violence and Harassment [GBVH]. Furthermore, requirements placed on verifiers engaging with female workers, and a GBV-specific grievance mechanism, are outlined. Risks of GBVH issues are still present, as monitoring of gender issues, specialized training for verifiers, and raising awareness of gender-related issues to relevant parties are not included as part of certification.

Fairtrade has a publicly accessible Theory of Change that explains the interventions, intermediate outcomes, long-term outcomes, and impact. It provides a basis for measuring results and progress. The Standards & Certification intervention is explained, including tools and outputs. Fairtrade does not define measurable or time-bound indicators at the organizational level but has time-bound goals for the textile standard. Fairtrade does not actively communicate its ToC.

Fairtrade has a document called “Standard Operating Procedure for the Development of Fairtrade Standards” that provides information on its procedures for setting standards. The standard’s full revision exceeds five years. The document includes a chapter on monitoring changes, representing [non-]substantive changes. Fairtrade follows a process that involves seeking public feedback, conducting research with experts and stakeholders, and obtaining approval before the research phase begins.

The international Fairtrade system is governed by the General Assembly and the Board of Directors. Fairtrade has a comprehensive document called the “Fairtrade Organization Code” that covers topics such as accountability, integrity, and respect. However, there is no specific mention of a secretariat or similar day-to-day functions in the document. The constitution includes a separate chapter that outlines membership requirements, obligations, and rights within the organization.

Fairtrade has detailed guidelines for claims management in its textile standards, covering both content-based and outcome-based claims. Fairtrade Cotton can be used either fully traceable or as the Fairtrade Sourced Cotton model, a mass balance chain of custody. Fairtrade has procedures with consequences for misuse of claims.

Fairtrade’s assurance method varies depending on the company’s role in the supply chain. Fairtrade works with independent certification bodies and accreditation bodies to ensure compliance. Surveillance audits are conducted annually or more frequently to monitor compliance, with specific requirements varying based on the certificate holder. Fairtrade provides guidance to auditors, outlining content and assurance requirements.

The organization-level document includes a chapter on conformity procedures for standards. Non-conformities must be closed within agreed timeframes, or a non-conformity recommendation is made. Non-conformities are categorized as minor, major, or critical, with observations recorded. Sanctions for assurance providers include denial, suspension, de-certification, or financial penalties. Organizations are motivated to obtain zero non-conformities, as this leads to less intense and frequent audits.

The assurance provider conducts risk-based surveillance audits. The scope of surveillance audits may be reduced based on the provider’s risk policy but must include follow-up on previous non-conformities. The organization has a separate interactive website for a risk map, aiming to assess human rights and environmental risks. The risk map methodology explains the definition and quantification of threats. The organization does not have a risk management plan to identify risks to the organization.

The website’s “contact us” tab offers extensive information with guiding questions for reporting on various topics. Providing feedback on the webpage is possible. The “contact us” page effectively categorizes different topics and guides users to the appropriate page. It intuitively redirects users to relevant certification and accreditation bodies when needed. The stakeholders are informed about providing feedback and giving input.

Fairtrade has an MEL system. Fairtrade publishes annual monitoring data, commissioned evaluation research, and commodity briefings for transparency and learning. The document mentions the annual frequency of re-evaluations and includes a chapter on data and information, explaining data communication procedures. Fairtrade has made significant efforts since 2011 to define their ToC and align their tailored MEL system accordingly, showcasing this alignment in their impact monitoring tool and page.

ISCC EU requires that producers have a management plan in place to reduce GHG emissions through fossil fuel use efficiency and increased renewable energy generation, recording site-specific metrics related to fuel usage and fuel volume per hectare or per unit of product. ISCC EU also requires a risk assessment that is supported by a multistakeholder process in the context of GHG emissions.

ISCC EU requires that the reduction of multiple pollutants at the farm level—including nitrogen oxides, particulate matter, sulfur compounds, and more—is recorded and monitored. Emissions are monitored across Scopes 1, 2, and 3 and measurements are tracked against the program’s climate targets. Remediation actions are undertaken when monitoring inputs yield negative environmental, social, and/or cultural impacts.

ISCC EU requires that GHG emission reductions are named as a prioritized outcome, and that continuous improvement towards this outcome is demonstrated. It also has a 2008 cutoff date for changing the status of areas with high biodiversity or carbon stock values, which further helps to prohibit the expansion or intensification of GHG emissions at the farm level.

ISCC EU requires that organic and mineral fertilizers are applied appropriately, soil health practices that minimize erosion risk are utilized, renewable energy usage is increased, energy efficiency is increased through lighter machinery, and that measures are taken to support the long-term economic viability of the production unit.

ISCC EU requires that riparian buffer zones are protected and maintained, efficient irrigation techniques such as rainwater harvesting are implemented, and that soil health practices (such as cover cropping and intercropping) are utilized.

ISCC EU requires that biomass is not produced on peatland as of January 2008 or thereafter and prohibits any intensification related to the drainage of peatland. Practices such as drainage of peatlands are explained and discouraged, and producers are required to show evidence that any operations concerning peatland are not negatively impacting the health of peat soils. Monitoring impacts on soil quality and carbon is also required alongside peatland water management practices.

ISCC EU requires that biomass is not produced on above-ground carbon stocks as of January 2008 or thereafter. Practices such as degrading above-ground carbon stocks are explained and discouraged, and producers are required to show evidence that operations are not negatively impacting the health of above-ground carbon stocks.

ISCC requires that specific soil health practices and measurements are taken into account to determine soil carbon sequestration. These include indirect measurements such as proven soil health practices, as well as direct evidence of soil carbon sequestration through field testing.

The Higg MSI does not hold LCA data for ISSC EU.

The Higg MSI does not hold LCA data for ISSC EU.

ISCC EU requires a water management plan that considers risks associated with withdrawals and the contamination of water resources. As well as being continuously updated, the management plan needs to have annual documentation of efficient water usage during irrigation, the responsible use of organic fertilizers and agrochemicals, and waste discharge. The management plan also considers stakeholders and impacts downstream of the management unit.

ISCC EU requires producers to assess and evaluate the use and recharge rates of their water source and set up a water use plan to optimize the use of water resources.

ISCC EU requires producers to monitor for water contamination, to ensure that the practices in place are effective. They are also required to report direct evidence of water contamination to local authorities and ensure that management responses are adaptive to monitoring inputs.

ISCC EU requires that water health, as it relates to withdrawals, is named as a prioritized outcome and that continuous improvement is demonstrated. The required environmental impact assessment also helps to prohibit the expansion or intensification of new cultivation that results in water availability loss.

ISCC EU requires that water health, as it relates to contamination, is named as a prioritized outcome and that continuous improvement is demonstrated. The required environmental impact assessment also prevents the expansion or intensification of new cultivation that results in water contamination.

ISCC EU requires that groundwater and rainwater consumption are named as prioritized metrics for water use.

ISCC EU requires groundwater and surface water contamination to be reported to local authorities if direct evidence is found.

Cotton is a 100% biobased feedstock. While there are requirements in place for the responsible use of organic fertilizers and agrochemicals, there is no prohibition of synthetic chemicals used in production. Increasing renewable energy usage is required as a part of the ISCC EU management plan, but the degree to which producers are expected to increase their renewable energy usage is unclear.

The Higg MSI does not hold data for ISSC EU.

The Higg MSI does not hold data for ISSC EU.

Conventional cotton scores 25% better than Cotton Made in Africa on the likelihood of eutrophication during production. As there is no LCA data in the Higg MSI available for ISCC EU, conventional figures are used.

ISCC EU has requirements in place for integrated pest and fertilizer management with an established recording system that is kept up to date and works towards continuous improvement. Producers are also required to seize on opportunities to minimize chemical usage as often as possible.

ISCC EU requires that labeling instructions and all requirements (protective clothing, storage, handling, maximum amount, etc.) are followed. In addition, any workers who are involved in the chemical handling or application process must have certificates of competence or other records of qualification. Producers are required to review opportunities for continuous improvement.

ISCC EU requires that monitoring takes place for causes of chemical-induced degradation (specifically heavy metals and other contaminants) and that chemicals from the following lists will not be applied: WHO classes 1a and 1b, Stockholm Convention on Persistent Organic Pollutants, and Annex III of the Rotterdam Convention. Remediation actions are undertaken when monitoring inputs yield negative environmental, social, and/or cultural impacts.

ISCC EU requires that chemical management is named as a prioritized outcome, and that continuous improvement is demonstrated insofar as chemical discharge into waterways is monitored. The responsible use of fertilizers and agrochemicals is also required, as is the general reduction of the of chemical usage wherever possible.

ISCC EU requires that chemical discharge into water and air, and the management of chemical inputs (through restricted chemistry lists) are both prioritized metrics within standard system documentation. There are also requirements in place for the discharge of solid waste to be prioritized.

The Higg MSI does not hold data for ISSC EU.

ISCC EU requires a soil health management plan that is site-attuned, adaptive, updated annually, and considerate of stakeholders.

ISCC EU requires that various metrics, including soil quality, contamination, and erosion, are monitored and measured to ensure soil health is protected. Management responses are linked to monitoring inputs/outputs and periodical soil analysis is carried out to maintain and improve soil conditions.

ISCC EU requires that soil health is named as a prioritized outcome and continuous improvement is demonstrated through management actions. The required environmental impact assessment also prevents the expansion or intensification of new cultivation that would result in soil health degradation. Positive outcomes for soil health are also identified in documentation.

ISCC EU requires producers to prioritize the following metrics: the prevention and control of erosion, maintaining and improving soil nutrient balance, maintaining and improving soil organic matter, maintaining and improving soil pH, maintaining and improving soil structure, maintaining and improving soil biodiversity, and the prevention of salinization.

ISCC EU requires the use of appropriate management measures, including crop rotation, cover cropping, crop residues, low till, and intercropping.

While individual producers may have procedures in place, there is no evidence of requirements for a land management plan within ISCC EU documentation.

ISCC EU requires that land-use (health) is named as a prioritized outcome through the protection of areas with high carbon stock or biodiversity values.

While ISCC EU requires a January 1, 2008 deforestation cutoff date, this requirement focuses more broadly on changing the status of areas with high biodiversity or high carbon stock, which includes forested areas. There is also evidence that ISCC EU requirements have resulted in risk reduction for deforestation.

While ISCC EU requires a January 1, 2008 land conversion cutoff date, this requirement focuses more broadly on changing the status of areas with high biodiversity or high carbon stock. There is also evidence that ISCC EU requirements have resulted in risk reduction for land-use change outcomes.

ISCC EU requires an annually updated biodiversity action plan that is adapted to local conditions, considerate of stakeholders, and focused on the protection of biodiversity and pollinators. ISCC EU also requires the use of integrated pest management, which can complement the biodiversity action plan.

ISCC EU requires the identification of areas with high biodiversity values and an integrated pest management plan, which indicate some monitoring of the causes of biodiversity loss (such as land-use change and fertilizer application) and the state of biodiversity health (including soil fertility).

ISCC EU requires that biodiversity is named as a prioritized outcome, and that continuous improvement is demonstrated through the protection of key biodiversity areas and accompanying assessments alongside integrated pest management. Activities of expansion or intensification are prohibited through a January 1, 2008 cutoff date for biomass produced on land with a high biodiversity value.

ISCC EU requires native species to be used as a part of the production system. It also requires that riparian areas, buffer zones, and habitat corridors are maintained and documented.

ISCC EU requires that at least 5% of the farm is established to protect biodiversity and pollinators.

ISCC EU requires an integrated pest management plan to protect the local environment and species within it. In addition, producers are not allowed to hunt or collect any native wildlife or plants inside the management unit, unless a monitoring program is in place to ensure sustainable levels of use.

ISCC EU requirements prohibit the introduction of invasive species.

ISCC EU has requirements in place for a waste management plan that focuses on preventing the following: waste, burning certain waste materials on-site, contaminating on-site landfill disposal, contamination associated with the disposal of ash, and gray water runoff and disposal.

ISCC requires that recycling takes place to reduce waste. In addition, traceability and chain of custody are clearly linked to the separation and organization of certified waste streams in production.

Cotton is a 100% biobased feedstock and inherently renewable.

ISCC EU requires that producers adhere to a living wage that meets the statutory minimum wage/collectively bargained wage, maintain daily worker records, prohibit successive temporary work contracts for permanent work, provide remuneration no less than that wage, comply with a stated reasonable time limit of no less than 48 hours, provide all entitlements guaranteed, clearly define expectations related to terms and conditions, and provide quality accommodation, water, and sanitation facilities.

ISCC EU requires that forced labor is prohibited in keeping with ILO Conventions 29 and 105, and that there are periodic risk assessments looking at risk factors including forced labor for migrant workers. There are also sector-specific requirements in place related to identity card ownership and handling.

ISCC EU requires that producers do not to employ child labor/young workers to perform hazardous work (as defined in ILO Conventions 138 and 182), and that steps are taken to prevent the worst forms of child labor. ISCC EU requires that periodic risk assessments take place, but it is unclear if this extends to assessing for child labor among migrant workers. It is also required that negative social impacts are identified and that a participatory social and legal compliance assessment takes place.

ISCC EU requires producers to take steps to prevent and address discrimination as defined in ILO Convention 111, as well as discrimination on other grounds such as age, sexual orientation, disability, or caste. ISCC EU also bases its requirements on ILO Standard 100, whereby all workers should receive equal remuneration for work of equal value. ISCC EU requires that periodic risk assessments take place, but it is unclear if they extend to assessing non-discrimination for migrant workers.

ISCC EU requires that producers to respect the right to freedom of association and collective bargaining as defined in ILO Conventions 87 and 98, that the program raises awareness for workers regarding their rights to freedom of association and collective bargaining, and that the program takes a gender-sensitive approach in implementing freedom of association.

ISCC EU requires that workers are provided with PPE, receive adequate health and safety training, and that young workers (15-18), pregnant workers, disabled workers, or workers who suffer from chronic or respiratory diseases should not undertake hazardous work that jeopardizes their health, safety, or morals. It is also required that designated responsibility is in place for the health and safety of workers.

While ISCC EU does not have a theory of change that includes explicit mentions of increasing farmer income, enhancing livelihoods, or improving predictability and stability for producers and own-account workers, there are requirements for working towards a living wage and creating a business plan that reflects a commitment to the long-term economic viability of the farm.

ISCC EU requires that legal and customary land rights of Indigenous peoples are respected and that free, prior, and informed consent (FPIC) is applied in cases of new land acquisitions. Indigenous groups are engaged when a negative impact is identified and a participatory social impact and legal compliance assessment must be conducted. It is also specified that women should be engaged in stakeholder consultation.

ISCC EU requires producers to show that land is being used legitimately and traditional land rights have been secured. This includes the producer being able to identify and respect existing land rights and show all necessary documentation related to the legal use of the land. However, there is no elaboration on whether these requirements extend to water as well.

ISCC EU requires that a participatory consultation takes place within local communities to identify, mitigate, or address potential conflicts, concerns, or impacts. It is also required that producers disclose risks and impacts as well as taking a gender-sensitive approach to promoting democratic participation and community consultation.

There is no evidence in its documentation that ISCC EU requires producers to periodically evaluate and test whether there is a sufficient enabling environment for the program’s theory of change in the countries or regions in which the program operates or is seeking to operate.

ISCC EU requires producers to have procedures in place to receive complaints from workers or the surrounding community. It also stipulates that an independent mediator should be assigned and addressed by the elected person of trust. ISCC EU also requires that complaints are dealt with in a timely manner.

ISCC EU requires that certified producers take steps to prevent and address discrimination on the basis of sex within the certified operation.

The organization presents a Theory of Change in its impact report, outlining desired impacts and pathways. The standard’s objective is to promote sustainable biomass practices. Theory of Change goals are measurable but lack time frames. It does not mention active stakeholder engagement in socializing its Theory of Change.

The organization defines clear procedures for standard development and revisions. It specifies that all standards are revised every five years, per ISCC quality guidelines. Non-fundamental adjustments are directly communicated, while public consultations are held for new or strategic changes. The standard-setting procedure does not include analyzing critical sustainability issues or assessing indicator effectiveness.

ISCC’s governance composition includes a management team for the operational business and a board that provides strategic oversight. The organization is open to membership. No clear roles or responsibilities are defined for the management team. The organization has documented several impartiality and inclusive policies.

ISCC defines a clear claims policy to ensure consistency. The policy differentiates between mass balance accounting and physical segregation. For mass balance, on-product logos are allowed if over 90% certified materials are used; less than 90% requires a proportion statement. The consequences of misuse of claims include legal action. The policy distinguishes product- and outcome-based claims, offering guidance on greenhouse gas emissions reduction claims.

The organization provides a clear procedure detailing assurance provider requirements. Certification bodies and auditors must be impartial, independent, and free from conflicts of interest. Accreditation should come from recognized bodies. Roles, responsibilities, and training modules for auditors are described. Audits must be conducted annually, promoting timely recertification.

ISCC defines clear procedures for conformity assessment. Corrective measures for non-conformities, especially major or critical cases, are detailed. Violations can lead to certificate suspension or withdrawal. Sanctions against certification bodies are possible, depending on the type and degree of non-compliance. Risk assessment shapes audit intensity and sample size, which in turn motivates certified organizations to fully comply with the standard.

Assurance policies require auditors to conduct risk evaluations during certification audits, which influence audit intensity and sample size. The organization has a separate risk management policy covering the identification, evaluation, and mitigation of risk. It identifies and provides examples of general, land-related, and waste/residue risks, assessing and classifying them into regular, medium, and high levels.

The organization’s website offers separate contact forms for complaints, grievances, or fraud allegations, and general feedback or inquiries. Instructions for submitting complaints are clearly detailed. A procedure with clear roles and responsibilities is defined for the handling of feedback and conflict resolution. New or strategic document changes undergo public consultation with stakeholders.

ISCC reports on key evaluation findings in their Impact Report. The report discloses outcomes, like waste management and renewable energy improvements, based on auditor feedback. The system is evaluated every five years. ISCC’s reports to the European Commission, along with certificates and related data, are published on the ISCC website. The monitoring and evaluation system is linked to the Theory of Change, and progress towards those goals is reported.

MyBMP requires producers to consider site-specific energy use and efficiency practices, focusing on energy sources, irrigation techniques, and fuel efficiency on machinery.

Emission reduction is a prioritized module of MyBMP producers, covering both scope 1 and scope 2 emissions through energy use and efficiency at farm level, monitoring energy inputs, and efficiency of irrigation and machinery.

Emission reduction is a prioritized outcome for MyBMP producers, assessing and improving machinery performance along with assessing and improving irrigation pump performance and efficiency, however, there is no evidence to demonstrate actions are taken following monitoring into continuous improvement.

MyBMP producers are required to consider lower carbon production methods through the adoption of process innovations in soil health, transitions to renewable energy sources, and energy efficiency procedures in machinery and irrigation pump performance.

MyBMP producers are required to demonstrate climate adaptation practices to prevent and minimize climate change disruption through the use of irrigation techniques, rainfall storage, protection of riparian areas, and weather warning systems.

The MyBMP producers are required to adhere to the sustainable Natural Landscape module to map and identify natural resources whilst maximizing ground cover to prevent erosion and improve soil health and stabilizing riverbanks and waterways to reduce erosion.

The MyBMP producers are required to adhere to the sustainable Natural Landscape module to map and identify natural resources whilst maintaining a vegetation structure and re-vegetation techniques.

Soil carbon sequestration and emissions are required to be identified across MyBMP producers’ farms. Soil structure assessments are likely to demonstrate soil carbon sequestration.

The Higg MSI does not hold LCA data for MyBMP.

The Higg MSI does not hold LCA data for MyBMP.

MyBMP producers are required to implement site-specific water management practices, including surface irrigation, center pivot and lateral moves, drip irrigation as well as dryland water usage.

MyBMP requires producers to maintain efficient water management and storage practices, including metering and monitoring, irrigation scheduling, legislative compliance, and managing storage to minimize seepage and evaporation. MyBMP focuses on the minimization and mitigation of negative impacts of direct operations on water quantity.

MyBMP requires producers to maintain efficient water management and practices to prevent run-off, including testing water quality, and monitoring of water use, maintenance of systems and managing of storage. MyBMP focuses on the minimization and mitigation of negative impacts of direct operations on water quality.

MyBMP producers are required to understand water use and efficiency whilst conducting performance evaluation and benchmarking.

MyBMP producers are required to understand water quality and participate in water quality sampling programs.

MyBMP requires producers to consider groundwater, surface water and rainwater catchments.

MyBMP requires producers to consider groundwater and surface water along with saltwater movements within the water contamination strategy.

Cotton feedstock is 100% biobased. While MyBMP requires producers to consider alternative energy sources on farms, petrochemicals are still utilized.

The Higg MSI does not hold data for MyBMP.

The Higg MSI does not hold data for MyBMP.

Cotton with no standard system scores 25% better than Cotton Made in Africa in the likelihood of eutrophication during production – as no LCA data in the MSI is available for MyBMP, cotton with no standard system figures are used.

MyBMP producers are required to use only locally registered or permitted products on farms. The grower ensures pesticide application takes place only during appropriate weather conditions [i.e. field-specific weather parameters are established] and follows the application method as stated on the label.

MyBMP outlines requirements for producers to store chemicals in a safe way, with proper separation and ventilation in the storage process. Additionally, the standard includes provisions for the safe cleaning and disposal of chemicals—while training is provided in regard to the use of PPE, it is unclear whether or not this training extends to include other chemical management considerations.

MyBMP producers are required to adhere to safety monitoring of petrochemicals, conduct weather monitoring activities to avoid spray drift, restrict hazardous chemicals and monitor limits of chemical waste.

MyBMP demonstrate practices to reduce hazardous chemicals through phasing out and aligning to BCI for closed loop transfer systems.

MyBMP requires producers to consider the impact of chemical discharge into waterways, with focus on spraying parameters and water quality.

The Higg MSI does not hold data for MyBMP.

MyBMP requires producers to implement a soil health management plan, including adapting fertilization to soil conditions, maintaining or improving soil quality, and avoiding or minimizing soil erosion risks.

MyBMP requires producers to monitor impacts and adapt management as necessary. The monitoring focuses on identifying pressure and state of soil health, a fertilizer plan focused on recording trends, and in-crop monitoring used to assess nutrient levels.

MyBMP requires producers to identify soil health as a prioritized outcome and demonstrate continuous improvement, however, there is no evidence to suggest soil health is considered around the management unit.

MyBMP requires producers to demonstrate prioritized outcomes for soil carbon cycle, soil structural health, soil water cycle and soil nutrient cycle, and chemical balance.

Beneficial soil health practices are required for MyBMP producers, including crop rotation, intercropping and crop residues.

MyBMP requires land management practices through the Sustainable Natural Landscape MyBMP module. Producers must identify natural resources, preserve, and enhance habitat for beneficials.

While individual producers may have procedures in place, no evidence suggests that MyBMP-certified producers are required to demonstrate priority toward land use health outcomes.

MyBMP producers take steps to reduce the risk of deforestation on the production unit. Evidence of this is found in criteria to maintain and improve native plant species diversity and minimize removal of fallen trees for habitat considerations. No commitments to cut-off dates are found in the certification.

MyBMP producers take steps to reduce the risk of land conversion on the production unit. Evidence of this is found in criteria to maintain and improve native plant species diversity and obtain approval before the modification or removal of native flora and fauna species on the production unit. No commitments to cut-off dates are found in the certification.

Although the Sustainable Natural Landscape module does consider biodiversity through re-vegetation techniques, there is no evidence that MyBMP requires producers to implement a biodiversity management plan.

There is no evidence that MyBMP requires biodiversity monitoring to be carried out by producers.

There is no evidence that MyBMP requires a biodiversity strategy to be carried out by producers.

MyBMP requires producers to maintain native vegetation diversity and connectivity, record natural features such as riparian areas in farm plans, and maintain awareness of corridors, patches and single trees and how they link across the farm.

There is no evidence that MyBMP requires producers to set aside a portion of the production unit for naturalization.

There is no evidence that MyBMP requires producers to protect against human-wildlife conflict and foster positive human-wildlife coexistence.

MyBMP aligns with the national legislation requirements associated with clearing native vegetation, modifying riverine areas, and controlling invasive plants and animal.

The main risks associated with waste are linked to improper management of chemicals at the farm level. While MyBMP require producers to dispose of waste of in an appropriate manner, there is no evidence of MyBMP requiring producers to demonstrate a waste reduction plan.

Although waste is disposed of in an appropriate manner, there is no evidence of MyBMP requiring producers to monitor waste streams for reuse and recycling, either across chemical use and/or fiber.

Cotton is a perennial plant and a renewable feedstock. There is no evidence that MyBMP requires producers to source from organic or recycled sources.

MyBMP requires adherence to wages specified in the Modern Award; including 38 hours per week, reasonable extra hours, and wages through cash or transfer. Pieceworkers align with the National Employment Standards, including bargaining obligations and arrangements for hours, rostering, notice periods, breaks, and variations in working hours. Employment terms, including the Fair Work Information, are adhered to and communicated. Casual employees have the right to request conversion within 12 months. Accommodation is provided for overnight stays, and working hours are recorded.

There is no evidence that MyBMP has requirements that account for forced labor risks. In particular, there are no requirements that require producers to not employ or benefit from forced labor as defined in ILO Conventions 29 and 105, and ILO Protocol 29. Furthermore, there are no requirements for large producers and managed productions to prevent or eliminate forced and compulsory labor as defined in ILO Conventions 29 and ILO 105.

There is no evidence that MyBMP has requirements that account for child labor risks. In particular, there are no requirements that require producers to not employ or benefit from child labor or employ young workers to perform hazardous work, as defined in ILO Conventions 138 and 182. Furthermore, there are no requirements for large producers and managed productions to prevent or eliminate the worst forms of child labor.

MyBMP requires adherence to ILO Convention 111, providing a workplace that does not discriminate, including discrimination on other grounds. In addition, MyBMP provides an anti-discrimination policy and requires equal remuneration for men and women workers for work of equal or comparable value.

MyBMP requires adherence to the Modern Award, Entries Agreement and National Employment Standards [Fair Work Act 2009] for requirements relating to freedom of association. While there is evidence that rights to freedom of association and collective bargaining are required, there is no requirement to align with ILO Conventions 87 and 98, and to this end risks are not adequately addressed.

MyBMP requires producers to provide a safe working environment, committing to Work Health and Safety obligations with a formal system in place; a process to manage the risk of hazardous chemicals and risks from machinery and equipment; providing personal protective equipment [PPE]; and responsibility to enforce health and safety policies along with monitoring of activities.

There is no evidence that MyBMP has requirements in place to address risks related to livelihoods, specifically relating to predictability and stability of income. In particular, there are no requirements to ensure a theory of change is in place to increase farmer income, enhance livelihoods, or improve predictability and stability.

There is evidence that MyBMP has requirements in place relating to Indigenous peoples and customary land rights. In particular, there are no requirements in relation to respecting legal and customary land rights of Indigenous peoples in accordance with the UN Declaration on the Rights of Indigenous Peoples, or engagement with Indigenous groups affected by operations.

There is no evidence that MyBMP has requirements in place relating to land rights. In particular, there is no evidence that MyBMP requires producers to respect legal and customary land and water tenure arrangements in accordance with national law.

There is no evidence that MyBMP has requirements in place for community consultation and engagement [right to participation]. In particular, there are no requirements for participation in community consultation to identify, mitigate or address potential conflicts, or requirements for disclosure of information on risks and impacts.

There is no evidence that MyBMP has requirements in place to address risks related to enabling the environment for human rights realization. That is, there are no requirements for periodic evaluation and testing of risks relating to enabling the environment for human rights realization [such as heavy restrictions on democratic processes, civil rights, or systemic, state-supported violations of one or more human rights].

MyBMP requires producers to manage disputes in accordance with the model terms for enterprise agreements and has sufficient provisions for resolutions through the Modern Award. Furthermore, MyBMP aligns with the Australian Fair Work Act on the appointment of representation for dispute resolution and for harassment to be handled through a dedicated process.

MyBMP requires adherence to the Modern Award legislation and must not include terms that discriminate against an employee because of sex, sexual orientation, gender identity, intersex status or other factors. However, many other elements of gender-based discrimination, violence, and harassment risk are not identified or addressed.

The Strategic Plan for 2018-2023 outlines the organization’s strategic goals and initiatives to achieve its vision. The standard document explains the aim of the standard and its relation to broader goals. The Strategic Plan references annual Operational Plans that detail the implementation of key priorities, including objectives, timeframes, and performance indicators. However, these are not publicly accessible. The organization does not actively socialize its theory of change.

The organization does not clearly define its procedures for standards development.

The organization has a Board and Executive team, the latter of which has responsibilities mentioned on the website and annual report. The organization does not have governing policies in place to guarantee impartiality and inclusiveness. Membership is open to various cotton industry organizations, allowing them to nominate representatives for General Meetings. However, the process for applying for membership is unclear and not specified.

The organization does not have documented policies and procedures to ensure the claims system is implemented consistently.

The standard document describes the organization’s assurance approach. It is not mentioned what entity takes the role of accreditation body and whether this body is part of an independent organization. Not all roles and responsibilities for both certification and accreditation bodies are clear. It is not clear whether certification bodies are required to conduct audits at least annually. There is no clear guidance available to auditors on the standard’s content and assurance requirements.

The organization gives only a very basic overview of the procedures for assessing conformity. It refers to a separate Audit Procedures and Guidelines document, but this does not seem to be publicly available.

The organization does not require assurance partners to conduct risk-based auditing.

The website contains a contact form for general questions, comments and feedback, as well as contact details. These are complemented by basic instructions. There a no clear roles and responsibilities defined for handling feedback, disputes, complaints and grievances. Stakeholders are not actively informed about opportunities to provide input.

The organization does not define a guiding framework for its monitoring, evaluation, and learning system.

The inherent production practices of mechanically recycled cotton reduce GHG emissions relating to farm level. In addition, GRS requires producers to demonstrate emission and environmental management plans at production sites addressing overall GHG emissions relating to energy use and emissions to air.

The inherent production practices of mechanically recycled cotton reduce GHG emissions relating to material sourcing. However, emissions are still commonly created during production due to collection, processing, and shipping. GRS does, however, require producers to monitor energy use at production level, meeting legal requirements, record keeping, and reviewing annually to set meaningful targets.

As a recycled cotton, significant climate impact is reduced at the material sourcing level. In addition, GRS requires producers to demonstrate environmental management as a prioritized outcome at the production level, demonstrating ambition to set emission-related targets and improvements.

The inherent production practices of mechanically recycled cotton reduce the overall impact to climate at material sourcing. In addition, GRS requires producers to adopt lower carbon practices for climate mitigation through setting and meeting targets for meaningful improvements in energy use and emissions.

The inherent production practices of mechanically recycled cotton reduce the overall impact to climate at material sourcing. While best practices may be executed, GRS does not require producers to implement climate resiliency methods to protect against extreme weather events.

Not in scope

Not in scope

Not in scope

The Higg MSI holds LCA data for recycled cotton and this data is used in the potential impact analysis of the fiber being sourced from this standard system.

The Higg MSI holds LCA data for recycled cotton and this data is used in the potential impact analysis of the fiber being sourced from this standard system.

Water-related risks in mechanically recycled cotton are significantly low due to the little water used and wasted in recycling. In addition, GRS requires producers to comply with relevant legislation relating to water use and wastewater, demonstrate water management practices, and conduct annual reviews on and offsite.

Water use for mechanically recycled cotton is significantly lower than virgin cotton. In addition, GRS requires producers to demonstrate water monitoring practices, measure and record outputs, and set meaningful improvements that are reviewed annually.

Wastewater or effluent for mechanically recycled cotton is low. Generally recycled cotton is mechanically recycled and uses low amounts of water, but some chemicals may remain from the original inputs. Therefore, it is important to ensure harmful and restricted substances are not found in the recycled product. In addition, GRS requires producers to demonstrate water monitoring practices through record keeping, permits, drainage, wastewater identification and management, on and off-site.

As a recycled cotton, significant water impact is reduced at the farm level. In addition, GRS requires producers to set water use as a prioritized outcome, setting meaningful targets which are reviewed targets for improvements.

As a recycled cotton, significant water impact is reduced at the farm level. In addition, GRS requires producers to set water disposal as a prioritized outcome, identifying and treating wastewater, conducting tests and up-to-date compliance.

There is no evidence that GRS producers are required to outline a water source consumption list. Therefore, coverage cannot be defined.

There is no evidence that GRS producers are required to outline a comprehensive water strategy for water contamination. Therefore, coverage cannot be defined.

GRS requires producers to input a recycled feedstock. In addition, cotton and recycled cotton are biobased feedstocks and do not require oil and gas extraction. As such, surface and groundwater risks do not exist. GRS does not, however, require producers to utilize renewable energy sources, therefore some risk remains.

The Higg MSI holds LCA data for recycled cotton and this data is used in the potential impact analysis of the fiber being sourced from this standard system.

The Higg MSI holds LCA data for recycled cotton and this data is used in the potential impact analysis of the fiber being sourced from this standard system.

The Higg MSI holds LCA data for recycled cotton and this data is used in the potential impact analysis of the fiber being sourced from this standard system.

Generally, mechanically recycled cotton poses less risks than cotton with no standard system due to its inherent production practices. Any toxic substances often exist from the original inputs, meaning that it is important to ensure harmful and restricted substances are not found in the recycled product. In addition, GRS requires producers to demonstrate a chemical management system with accurate lists and data sheets, and annual reviews.

GRS criteria require producers to handle, separate, dispose, and label chemicals used in accordance with the FAO ICCPM. The standard also outlines provisions for a chemical-responsible person and training to maintain the above practices where necessary.

Generally, mechanically recycled cotton poses less risks than cotton with no standard system due to its inherent production practices. In addition, GRS requires producers to monitor and meet legal requirements related to chemical management. This also includes restrictions of chemical substances and alignment to the ZDHC Manufacturing Restricted Substance List.

For recycled cotton, chemical impact is significantly reduced at the farm level. In addition, GRS requires producers to demonstrate continuous improvement methods with ongoing reviews of chemical restriction lists and annual progress reviews, demonstrating chemical strategy as a prioritized outcome.

Generally, mechanically recycled cotton poses less risks than cotton with no standard system due to its inherent production practices. GRS producers are required to prioritize chemical discharge into air and water. They are also required to ensure sludge receives proper treatment and disposal and that the Restricted Substance List is followed for input and output chemicals.

The Higg MSI holds LCA data for recycled cotton and this data is used in the potential impact analysis of the fiber being sourced from this standard system.

Not in scope

Not in scope

Not in scope

Not in scope

Not in scope

Not in scope

Not in scope

Not in scope

Not in scope

Not in scope

Not in scope

Not in scope

Not in scope

Not in scope

Not in scope

Not in scope

Mechanically recycled cotton utilizes pre and post-consumer feedstock, reducing feedstock that would otherwise be sent to landfill or incineration. In addition, GRS requires producers to set meaningful reductions in waste production, improvements in waste management, and review progress annually.

Mechanically recycled cotton utilizes pre and post-consumer feedstock, reducing feedstock that would otherwise be sent to landfill or incineration. In addition, GRS requires producers to monitor and take actions to reuse and recycle waste streams.

GRS requires producers to input recycled feedstock for production. Mechanically recycled cotton is sourced from pre and post-consumer waste.

GRS requires adherence to legal minimums, industry benchmarks, or collective agreements for wages and working conditions. Work weeks should not exceed 48 hours and breaks, time off, and holidays should be respected. Alternative forms of workers’ representation and negotiation should not be hindered. Workers must receive written information on their employment conditions. Non-permanent work should not be exploited to evade labor obligations. Access to clean facilities and drinkable water is mandatory. Employment relationships must comply with national legislation and international labor standards.

GRS requires adherence to ILO Convention 29, prohibiting forced or compulsory labor, bonded labor, and indentured labor. While there are some requirements, there is no evidence of requirements aligning with ILO Convention 105 or ILO Protocol 29, or provisions to prevent forced labor.

GRS requires adherence to ILO Convention 138: Producers shall not recruit child labor or exploit children in any way and shall not employ young workers under 18 years of age at night. While there are some requirements, there is no evidence of requirements aligning with ILO Convention 182, or provisions to prevent child labor.

GRS requires that producers do not engage in, support or tolerate discrimination on the basis of gender, age, religion, marital status, race, caste, social background, diseases, disability, pregnancy, ethnic and national origin, nationality, membership in worker organizations including unions, political affiliation, sexual orientation, or any other personal characteristics. There are no requirements relating to ILO Convention 111.

GRS requires producers to provide workers with the right to join or form trade unions or workers’ associations and the right to bargain collectively; producers shall not interfere with, obstruct or prevent such legitimate activities. While there is evidence that rights to freedom of association and collective bargaining are required, there are no requirements to align with ILO Conventions 87 and 98. To this end, risks are not adequately addressed.

GRS requires producers to provide safe and clean working conditions, train workers and management in waste management, handling and disposing of chemicals and dangerous materials, and prevention of accidents and injury, provide sanitation and drinking water facilities, assign a health and safety representative, and provide and record health and safety training.

There is no evidence that GRS requires producers to address risks related to livelihoods, specifically regarding predictability and stability of income. In particular, there are no requirements to ensure a theory of change is in place to increase farmer income, enhance livelihoods or improve predictability and stability.

There is no evidence that GRS requires adherence to Indigenous peoples and customary land rights. In particular, there are no requirements in relation to respecting legal and customary land rights of Indigenous peoples in accordance with the UN Declaration on the Rights of Indigenous Peoples, or engagement with Indigenous groups affected by operations.

There is no evidence that GRS has requirements in place relating to land rights. In particular, there is no evidence that GRS requires producers to respect legal and customary land and water tenure arrangements in accordance with national law.

There is no evidence that GRS requires producers to address community consultation and engagement [right to participation]. In particular, there are no requirements for participation in community consultation to identify, mitigate or address potential conflicts, or requirements for disclosure of information on risks and impacts.

There is no evidence that GRS requires producers to address risks related to enabling the environment for human rights realization—that is, there are no requirements for periodic evaluation and testing of risks relating to enabling the environment for human rights realization.

There is no evidence that GRS requires producers to address risks related to grievances and remedies. In particular, there is no evidence that GRS has requirements for certified producers to provide for or participate in a mechanism to receive and respond to grievances received in relation to production-level operations; for certified producers to provide for or participate in remediation of key risks identified through the grievance mechanism; and that the grievance mechanism should include the ability for workers to raise complaints anonymously.

GRS requires producers to not engage in, support or tolerate discrimination in employment due to gender. However, many other elements of gender-based discrimination, violence, and harassment risk are not identified or addressed.

The organization provides a theory of change that highlights the current state of the sector, desired sustainability impacts, and strategies to achieve its goals. The introduction of the standard document mentions both the aim of the standard and the organization’s overarching goal. The theory of change sets a measurable and time-bound end goal of a 45% reduction in GHGs from fiber and raw material production by 2030. The organization does not actively socialize its theory of change.

There are procedures for developing and revising all standards. The standard document includes a revision history with updates occurring within a maximum of five years. Non-substantive changes may be made directly, while major revisions can be initiated if the standard criteria lead to unintended consequences that compromise the goals. The secretary actively seeks public feedback during the development and revision stages. It is not clear what research has gone into the development process.

The website presents the governance board and executive team. However, there is a lack of policies regarding the inclusion of under-represented or disadvantaged stakeholders. The website provides limited information about the key roles and responsibilities of two team members, although a comprehensive overview of the team can be found in the annual reports. The website also lists current members who align with the organization’s objectives. Interested stakeholders can request membership.

The organization has a separate document outlining its standards claims policy, including guidelines for making claims and communication. The Chains of Custody model in the policy specifies requirements for making product-related claims. The policy addresses the misuse of claims and provides a 30-day window for correction before taking action. It differentiates between content-based and outcome-based claims, with guidelines for substantiating the latter using publicly available information.

A separate document outlines accreditation and certification procedures. The organization works with independent certification and accreditation bodies. Not all roles and responsibilities for certification and accreditation bodies are clear. Annual audits are required for certified organizations. Auditors need ongoing training to stay updated on relevant requirements to maintain their qualifications.

The accreditation and certification procedures document outlines the levels of non-conformity: Critical, Major, and Minor. Each level has specific procedures and consequences. Critical and Major non-conformities result in certificate suspension if not addressed promptly. There are no motivation mechanisms for certified organizations to adhere to the standard with zero non-conformities, nor for certification bodies to share audit data with the standard organization in due time.

There is a risk assessment procedure in the accreditation and certification procedures document. Certification bodies must adjust their procedures to address higher risks in specific situations. The organization does not provide a risk management plan. The organization publishes reports that outline current and future sector risks, such as the Material Change Insights 2022 report. However, explanatory documentation for the identification and quantification of these risks is not available.

The organization provides clear instructions for providing feedback, including complaints, through a designated contact form. General feedback and feedback on specific standards and policies can be submitted continuously. A separate document details its complaints and feedback policy, outlining the process for receiving, managing, and addressing such feedback. Stakeholders are encouraged to share their input during upcoming revisions of standards and policies, using the established channels.

The organization has separate documents on monitoring and evaluation procedures, unintended consequences, and data policy. They use impact areas and indicators aligned with their objectives to assess goal achievement. The majority of indicators are at the outcome and impact level. The frequency by which system components are evaluated is not mentioned. The organization publishes reports and has impact dashboards tracking industry progress towards set targets.

The inherent production practices of mechanically recycled cotton reduce GHG emissions relating to farm level. While best practices may be executed, RCS does not require producers to demonstrate emission management at the production level, therefore emissions may still commonly be created

The inherent production practices of mechanically recycled cotton reduce GHG emissions relating to material sourcing. However, emissions are still commonly created during production due to collection, processing, and shipping. While best practices may be executed, RCS do not require producers to demonstrate emission monitoring at production sites.

While RCS do not require producers to implement an emission strategy, the ambition of RCS aims to reduce the impacts of farm level. Emissions are still commonly created during the cutting/shredding process, however, the overall emission impact is reduced and therefore recognized as a prioritized outcome.

The inherent production practices of mechanically recycled cotton reduce the overall impact to climate at material sourcing. While RCS does demonstrate reduced impact to climate, producers are not required to adopt lower carbon practices.

The inherent production practices of mechanically recycled cotton reduce the overall impact to climate. While best practices may be executed, RCS does not require producers to implement climate resiliency methods to protect against extreme weather events.

Not in scope

Not in scope

Not in scope

The Higg MSI holds LCA data for recycled cotton and this data is used in the potential impact analysis of the fiber being sourced from this standard system.

The Higg MSI holds LCA data for recycled cotton and this data is used in the potential impact analysis of the fiber being sourced from this standard system.

Water-related risks in mechanically recycled cotton are significantly low due to the little water used and wasted in the recycling process and the removal of water usage at farm level. While best practices may be executed, RCS does not require producers to demonstrate water risk management.

Water use for mechanically recycled cotton is significantly lower than virgin cotton. While best practices may be executed, RCS does not require producers to demonstrate water withdrawal monitoring at production sites, which poses risks to the environment and local community.

Wastewater or effluent for mechanically recycled cotton is low. Generally, the process of recycling uses little water, but some chemicals may remain from the original inputs. It is therefore important to ensure harmful and restricted substances are not found in the recycled product. Furthermore, while best practices may be executed, RCS does not require producers to demonstrate water contamination monitoring at production sites and as such, risk still remains.

While RCS does not require producers to implement a water strategy, the ambition of RCS aims to reduce the impact of material sourcing, therefore reducing the overall water use. In addition, little water is utilized in the process of recycling therefore demonstrating water as a prioritized outcome.

While RCS does not require producers to implement a water strategy, the ambition of RCS aims to reduce the impact of material sourcing, therefore reducing the potential of contaminated water. In addition, little wastewater is produced in the process of recycling therefore demonstrating water as a prioritized outcome.

There is no evidence that RCS producers are required to outline a water source consumption list.

There is no evidence that RCS producers are required to outline a potential water source contamination list.

RCS requires producers to input a recycled feedstock. In addition, cotton and recycled cotton are biobased feedstocks and do not require oil and gas extraction. As such, surface and groundwater risks do not exist. RCS does not, however, require producers to utilize renewable energy sources, therefore some risk remains.

The Higg MSI holds LCA data for recycled cotton and this data is used in the potential impact analysis of the fiber being sourced from this standard system.

The Higg MSI holds LCA data for recycled cotton and this data is used in the potential impact analysis of the fiber being sourced from this standard system.

The Higg MSI holds LCA data for recycled cotton and this data is used in the potential impact analysis of the fiber being sourced from this standard system.

The inherent production practices of mechanically recycled cotton reduce chemical risks at the material sourcing level due to the removal of fertilizer. However, minimal risks at production still exist from the original inputs. While best practices may be executed, RCS does not require producers to demonstrate a chemical management system at the production site.

There is no evidence to suggest that chemical management practices are utilized at scale to address risks for recycled cottonl at cleaning/reprocessing, even if individual producers have some practices in place.

The inherent production practices of mechanically recycled cotton reduce chemical risks at the material sourcing level, but minimal risks still exist at production sites. While best practices may be executed, RCS does not require producers to monitor and meet legal requirements related to chemical management.

For recycled cotton, chemical impact is significantly reduced at the farm level. While RCS does not require producers to implement a chemical strategy, the little use of chemicals reduces risks associated with chemical discharge, demonstrating chemistry as a prioritized outcome.

While the inherent production practices of mechanically recycled cotton reduce chemical risks at the farm level, minimal risks still exist at production sites. While RCS does not require producers to prioritize a chemical strategy, chemical discharge and the manufacturing inputs are prioritized metrics.

The Higg MSI holds LCA data for recycled cotton and this data is used in the potential impact analysis of the fiber being sourced from this standard system.

Not in scope

Not in scope

Not in scope

Not in scope

Not in scope

Not in scope

Not in scope

Not in scope

Not in scope

Not in scope

Not in scope

Not in scope

Not in scope

Not in scope

Not in scope

Not in scope

Mechanically recycled cotton utilizes pre and post-consumer feedstock, reducing feedstock that would otherwise be sent to landfill or incineration. While best practices may be executed and waste is minimal, RCS does not require producers to reduce waste in production and conduct waste management, tracking and separation.

Mechanically recycled cotton utilizes pre and post-consumer feedstock, reducing feedstock that would otherwise be sent to landfill or incineration. While best practices may be executed and waste is minimal, RCS does not require producers to conduct waste stream utilization efficiency.

RCS requires producers to input recycled feedstock for production. Mechanically recycled cotton is sourced from pre and post-consumer waste.

There is no evidence that RCS has requirements in place to address risks related to wages and working conditions. In particular, there is no evidence that RCS has requirements for minimum wage/collectively bargained wage, remuneration, entitlements, and time limits.

There is no evidence that RCS has requirements that account for forced labor risks. In particular, there are no requirements that require producers to not employ or benefit from forced labor as defined in ILO Conventions 29 abd 105 and ILO Protocol 29. Additionally, there are no requirements for large producers and managed productions to prevent or eliminate forced and compulsory labor as defined in ILO Conventions 29 and 105.

There is no evidence that RCS has requirements that account for child labor risks. In particular, there are no requirements that require producers to not employ or benefit from child labor or employ young workers to perform hazardous work, as defined in ILO Conventions 138 and 182. There are no requirements for large producers and managed productions to prevent or eliminate the worst forms of child labor.

There is no evidence that RCS has requirements in place to address risks related to discrimination. In particular, there is no evidence that RCS has requirements for taking steps to prevent and address discrimination as defined in ILO Convention 111 and for taking steps to ensure equal remuneration for work of equal value as defined in ILO Convention 100.

There is no evidence that RCS has requirements in place to address risks related to freedom of association. In particular, there is no evidence that RCS has requirements for certified producers to respect the right to freedom of association and collective bargaining, as defined in ILO Conventions 87 and 98.

There is no evidence that RCS has requirements in place to address risks related to occupational health and safety. In particular, there is no evidence that RCS has requirements for certified producers to implement a health and safety management procedure or system; for certified producers to provide adequate protective clothing and personal protective equipment [PPE] to workers performing hazardous work; and for designated responsibility and accountability for enforcement of health and safety policies and/or plans/procedures.

There is no evidence that RCS has requirements in place to address risks related to livelihoods, specifically relating to predictability and stability of income. In particular, there are no requirements to ensure a theory of change is in place to increase farmer income, enhance livelihoods or improve predictability and stability.

There is evidence that RCS has requirements in place relating to Indigenous peoples and customary land rights. In particular, there are no requirements in relation to respecting legal and customary land rights of Indigenous peoples in accordance with UN Declaration on the Rights of Indigenous Peoples, or engagement with Indigenous groups affected by operations.

There is no evidence that RCS has requirements in place relating to land rights. In particular, there is no evidence that RCS requires producers to respect legal and customary land and water tenure arrangements in accordance with national law.

There is no evidence that RCS has requirements in place for community consultation and engagement [right to participation]. In particular, there are no requirements that require participation in community consultation to identify, mitigate or address potential conflicts, or requirements in disclosure of information on risks and impacts.

There is no evidence that RCS has requirements in place to address risks related to enabling the environment for human rights realization—that is, there are no requirements for periodic evaluation and testing of risks relating to enabling the environment for human rights realization [heavy restrictions on democratic processes, civil rights, or with systemic, state-supported violations of one or more human rights].

There is no evidence that RCS has requirements in place to address risks related to grievances and remedies. In particular, there is no evidence that RCS has requirements for certified producers to provide for or participate in a mechanism to receive and respond to grievances received in relation to production-level operations; for certified producers to provide for or participate in remediation of key risks identified through the grievance mechanism; and that the grievance mechanism should include the ability for workers to raise complaints anonymously.

There is no evidence that RCS has requirements that address risks related to the prevention of gender-based discrimination, violence, and harassment. In particular, there is no evidence that RCS has requirements for certified producers to take steps to prevent and address discrimination on the basis of sex within the certified operation, or take steps to address risks of Gender-Based Violence and Harassment [GBVH].

The organization provides a theory of change that highlights the current state of the sector, desired sustainability impacts, and strategies to achieve its goals. The introduction of the standard document mentions both the aim of the standard and the organization’s overarching goal. The theory of change sets a measurable and time-bound end goal of a 45% reduction in GHGs from fiber and raw material production by 2030. The organization does not actively socialize its theory of change.

There are procedures for developing and revising all standards. The standard document includes a revision history with updates occurring within a maximum of five years. Non-substantive changes may be made directly, while major revisions can be initiated if the standard criteria lead to unintended consequences that compromise the goals. The secretary actively seeks public feedback during the development and revision stages. It is not clear what research has gone into the development process.

The website presents the governance board and executive team. However, there is a lack of policies regarding the inclusion of under-represented or disadvantaged stakeholders. The website provides limited information about the key roles and responsibilities of two team members, although a comprehensive overview of the team can be found in the annual reports. The website also lists current members who align with the organization’s objectives. Interested stakeholders can request membership.

The organization has a separate document outlining its standards claims policy, including guidelines for making claims and communication. The Chains of Custody model in the policy specifies requirements for making product-related claims. The policy addresses the misuse of claims and provides a 30-day window for correction before taking action. It differentiates between content-based and outcome-based claims, with guidelines for substantiating the latter using publicly available information.

A separate document outlines accreditation and certification procedures. The organization works with independent certification and accreditation bodies. Not all roles and responsibilities for certification and accreditation bodies are clear. Annual audits are required for certified organizations. Auditors need ongoing training to stay updated on relevant requirements to maintain their qualifications.

The accreditation and certification procedures document outlines the levels of non-conformity: Critical, Major, and Minor. Each level has specific procedures and consequences. Critical and Major non-conformities result in certificate suspension if not addressed promptly. There are no motivation mechanisms for certified organizations to adhere to the standard with zero non-conformities, nor for certification bodies to share audit data with the standard organization in due time.

There is a risk assessment procedure in the accreditation and certification procedures document. Certification bodies must adjust their procedures to address higher risks in specific situations. The organization does not provide a risk management plan. The organization publishes reports that outline current and future sector risks, such as the Material Change Insights 2022 report. However, explanatory documentation for the identification and quantification of these risks is not available.

The organization provides clear instructions for providing feedback, including complaints, through a designated contact form. General feedback and feedback on specific standards and policies can be submitted continuously. A separate document details its complaints and feedback policy, outlining the process for receiving, managing, and addressing such feedback. Stakeholders are encouraged to share their input during upcoming revisions of standards and policies, using the established channels.

The organization has separate documents on monitoring and evaluation procedures, unintended consequences, and data policy. They use impact areas and indicators aligned with their objectives to assess goal achievement. The majority of indicators are at the outcome and impact level. The frequency by which system components are evaluated is not mentioned. The organization publishes reports and has impact dashboards tracking industry progress toward set targets.

While GHG reductions are an organization-wide goal, there is no evidence that REEL producers are required to implement a climate or emissions management plan.

REEL producers monitor the emissions generated on-site during cotton production. This monitoring is supported by specialists and measured against REEL’s climate/emissions targets.

CottonConnect has named GHG emission reductions as a priority in REEL production. Their impact report shows evidence of continuous improvement in lowering GHG emissions over time.

REEL producers demonstrate climate mitigation in requirements to enhance soil health through organic amendments and intercropping as well as through implementing restricted chemical lists.

REEL producers demonstrate climate adaptation through requirements to enhance soil health through intercropping and precision irrigation procedures. The Women in Cotton pilot project provides climate adaptation training and identifies opportunities to adapt to climate change in cotton production.

While individual producers may have procedures in place, there is no evidence to suggest that below-ground carbon stocks and peat soils have improved management protections under REEL certification.

While individual producers may have procedures in place, there is no evidence to suggest that above-ground carbon stocks have improved management protections under REEL certification.

While individual producers may have procedures in place, there is no evidence to suggest that recording soil carbon sequestration is required for REEL cotton production.

The Higg MSI does not hold LCA data for REEL CottonConnect.

The Higg MSI does not hold LCA data for REEL CottonConnect.

REEL producers are required to implement water management plans that record water use volumes and identify the water sources that will be used in production. This plan must be developed in collaboration with relevant stakeholders to ensure that water sources are conserved.

REEL producers are required to identify water sources and their stability before using them in production. Producers must also record the volumes of water used for irrigation. REEL applies a SMART approach to monitoring and management plans, and results are monitored and used to update/adapt water use procedures.

REEL has published an LCA report that highlighted a lower risk of water contamination when compared to a non-certified baseline. This can serve as a partial example of monitoring for the pressures to and state of water contamination.

Optimizing water withdrawal values and processes is a named objective of REEL certification. Evidence of progress is tracked through records of producers’ water use. Water use figures found in REEL’s annual impact report highlight continuous improvement in water use when compared to baseline values.

REEL has published an LCA report that shows a commitment to continuous improvement in water contamination, relative to baseline values.

While producers are required to keep track of water usage throughout production, there is no evidence that specific water sources are named in the tracking of water use.

Surface water quality is named as a priority metric in REEL cotton production. REEL specifically identifies water quality preservation as it pertains to chemical runoff.

REEL producers work with cotton varieties that are region-specific or recommended for the production unit. Cotton is a biobased fiber, which reduces the risks associated with oil and gas extraction during production.

The Higg MSI does not hold LCA data for REEL CottonConnect.

The Higg MSI does not hold LCA data for REEL CottonConnect.

The Higg MSI does not hold LCA data for REEL CottonConnect.

REEL cotton producers are required to ensure that all chemicals (pesticides/fertilizers) used are not listed in the REEL Code of Prohibited Chemicals. Additionally, producers must ensure that chemicals are targeted specifically to the intended use case. Producers are provided a list of acceptable chemicals to use in production.

REEL producers are required to adhere to the industry’s chemical handling best practice guidance on chemical labeling, storing, separating, and disposal.

REEL producers are prohibited from using chemicals that are banned in international agreements such as the Stockholm and Rotterdam Conventions. Remediation procedures and updates to the chemical management plan are developed using monitoring results.

REEL producers are required to reduce the volume amounts of pesticides used over time. Records of volumes used are available.

REEL producers are required to prioritize mitigation of runoff/discharge into bodies of water. There are requirements to address the possibility of sludge and solid waste discharge. Additionally, producers are required to follow a restricted chemical inputs list that aligns with the Stockholm and Rotterdam conventions.

The Higg MSI does not hold data for REEL CottonConnect.

REEL producers are required to implement soil health management plans that take into account site-specific soil considerations on soil fertility and erosion.

REEL producers are required to identify soil conditions through a soil analysis to determine levels of organic matter before the use of fertilizers. This shows producers monitor some aspects of the state of soil health.

REEL producers are required to take measures to increase soil fertility and decrease erosion, demonstrating that soil health is prioritized during production.

REEL outlines soil structure and nutrient values as priority objectives in certified production.

REEL producers engage in crop rotation, intercropping, low till (depth and frequency), and the use of organic amendments and crop residues to promote soil health.

REEL demonstrates requirements for a land management plan in its criteria to identify protected areas and primary and secondary forests, and not develop unproductive land. REEL management plans are adaptive to monitoring results and reviewed annually.

REEL producers demonstrate ambition in land strategy by actively restoring unproductive land but not converting it to produce cotton.

REEL producers are required to take steps to reduce deforestation risk and address past harms through restoration. Primary and secondary forests over ten years old must not be converted for production, and restoration procedures are in place for forests under ten years old to address any harm caused by production.

REEL producers are required to take steps to reduce land conversion risks and address past harms through restoration. Primary and secondary forests over ten years old must not be converted for production, and restoration procedures are in place for forests under ten years old to address any harm caused by production.

REEL producers are required to implement an Integrated Pest Management system which necessitates that they be aware of certain biodiversity values and pest-related risks on the production site. Additionally, procedures are put in place to maintain those low levels of pest-induced damage to crops.

REEL producers are required to be aware of the pest presence in the production unit – this is representative of monitoring for some of the causes of biodiversity loss.

REEL certification highlights biodiversity as a priority objective through the protection of biodiversity values in pest control procedures.

REEL producers are required to identify, maintain, and restore buffer zones on the production unit.

While REEL outlines that unproductive land must be restored for naturalization, it is unclear if producers are required to use a minimum amount of land for set-asides.

REEL producers implement non-lethal control measures for pests, as well as restricting the use of certain chemicals and their applications to reduce risk to the environment through runoff or leeching.

REEL producers are required to take action to mitigate the introduction of pests to the production site and prevent their spread. Mechanical controls are prioritized over the use of chemicals or lethal measures.

REEL producers are required to reintroduce organic residues of production back onto the field as fertilizer and identify hazardous waste streams with appropriate disposal techniques. This represents a general waste reduction plan.

REEL producers are required to separate organic and hazardous waste streams from others. REEL producers recycle organic residues to be reintroduced back onto the field for production.

REEL producers work to produce cotton, a renewable, bio-based resource. However, there are no commitments to use recycled inputs.

REEL Code of Conduct requires that payment and working hours are stipulated by regional and national legislation. There are additional criteria in place for equal pay for equal work regardless of gender or nature of contract (such as full-time vs temporary), and that temporary contracts are not used for work that is full-time. REEL also requires that provisions on breaks, bonuses and overtime pay are detailed in contracts provided to workers. Sanitation and hygiene stations are also provided to workers.

Forced labor as defined in ILO Conventions 29 and 105 is expressly prohibited under the REEL certification criteria, which includes sector-tailored provisions aimed at preventing forced labor on cotton farms. REEL requires that a grievance and remedy procedure is in place.

REEL requires that children under the age of 15 are not employed on producer farms, and that the worst forms of child labor do not occur. Incidences of any kind of child labor will be documented in order to support a monitoring and remediation plan for child labor.

REEL requires producers to prevent and address instances of discrimination of any kind. This extends to discrimination on the basis of race, gender, ethnicity, disability, age, etc. There is a grievance and remedy procedure in place to raise grievances on discrimination, with the aim of achieving remediation.

REEL producers are free to unionize and associate. Management cannot discriminate against individuals for joining a union, interfere with decisions to join or the activities of worker unions, or limit the scope of collective bargaining. Additionally, REEL requires that if there is no union presence on a farm, a worker committee is to be democratically elected to represent workers in management decisions. A grievance and remedy procedure is in place and workers’ unions/committees are aware of its procedures in the event that management does not obey legal rules.

REEL producers are required to implement an occupational health and safety management plan that consists of: a responsible party for implementing chemical procedures, safe chemical handling, application, and disposal protocols, adequate personal protective equipment provided to those who handle chemicals, and hygiene and sanitation stations on the production unit.

The REEL Code of Conduct has a theory of change that outlines increasing producer income as a central component. Furthermore, REEL requires producers to ensure a safe work environment, offer fair pay aligned with regional standards, and promote communal development initiatives. Producers emphasize equal pay for women and empower them in cotton projects.

There is no evidence that REEL requires producers to engage with or identify legal and customary land rights of Indigenous peoples in accordance with the UN Declaration on the Rights of Indigenous Peoples.

REEL producers must comply with land and water tenure agreements in accordance with national law. Cotton must be planted in regions suitable for production, or regions that have historically been known to grow cotton.

There is no evidence that REEL requires producers to engage with the local community to identify, address, or mitigate certain impacts resulting from production.

There is no evidence that REEL requires producers to monitor whether there is a sufficient human rights-enabling environment to operate.

A grievance mechanism is required in REEL cotton production. It has a committee in place for handling grievances relating to gender issues and women’s rights. Additionally, the grievance process is accessible to anyone who may be impacted by the activities of cotton production and is intended to provide remedy in cases of harm.

REEL producers are required to eliminate gender-based discrimination and pay gaps. These criteria take some steps to address gender-based violence and harassment in cotton production.

The organization has published a Theory of Change, stating the desired impacts of the program and strategic pathways and interventions to achieve them. The standard document describes the objective of the standard and the overarching goal of the program it is part of. The goals set in the Theory of Change are both measurable and time-bound. The Theory of Change is actively communicated to—and socialized among—relevant stakeholders.

The organization behind the standard has published a separate document describing the process through which the standard was developed. Revisions have been made no more than five years apart. There are no procedures for making urgent substantive and non-substantive changes outside the full revision process. The document states that public consultations are part of the development and revision process, and as well as the research it is based on.

The website provides an overview of the organization’s governance composition, mentioning the different roles and responsibilities of the executive management team. The organization has several policies in place that are publicly available, including safeguarding, anti-bribery and -corruption, and conflict of interest policies. There is no option for membership or similar level of participation in governance.

The organization has published a separate document containing its chain of custody and traceability framework, as well as its claims system. However, it remains unclear what the requirements are for making sure that claims are in line with the chain of custody model, or what the procedures and consequences are for the misuse of claims.

The organization has published its assurance approach. While the organization partners with third-party verifiers, it is not mentioned whether these verifiers are accredited by independent accreditation bodies. Not all of the roles and responsibilities of certification and accreditation bodies are clear. Annual audits are required. There is no clear guidance available to auditors on the standard’s content and assurance requirements.

The standard organization does not define clear procedures for conformity assessment, which would enable the consistent determination of non-conformity levels.

The organization does not require assurance partners to conduct risk-based auditing.

The website provides a contact form and basic contact details for providing feedback, as well as a special email address for grievances and complaints. These are complemented by basic instructions. A separate document provides guidance on how to submit input and the policies and procedures on how and by whom the input will be handled. Stakeholders are actively invited to provide input for the development and revision of the Theory of Change and MEL system.

The organization has published multiple reports on the organization and program’s achieved impact. The majority of indicators are at the outcome and impact level. The organization defines the frequency by which it will evaluate its system components. There is no policy or procedure for data communication. A guiding framework is provided in the latest impact report, which also defines how tracked performance is linked to goals set in the Theory of Change and how progress towards these goals is measured.

REEL Regenerative producers are required to implement a site-specific emissions management plan that outlines key climate considerations and mitigation/adaptation procedures.

REEL producers monitor the emissions generated on-site during cotton production. This monitoring is supported by specialists and measured against REEL’s climate/emissions targets.

CottonConnect has named GHG emission reductions as a priority in REEL production. Their impact report shows evidence of continuous improvement in lowering GHG emissions over time. As part of the Regenerative Code, producers must not intensify production if emissions stand to increase significantly.

REEL producers demonstrate climate mitigation in requirements to enhance soil health through organic amendments and intercropping and through implementing restricted chemical lists As part of the Regenerative code, producers must engage in practices that improve energy efficiency and use renewable sources – notably through using crop residues.

REEL producers demonstrate climate adaptation through requirements to enhance soil health through intercropping and precision irrigation procedures. The Women in Cotton pilot project provides climate adaptation training and identifies opportunities to adapt to climate change in cotton production.

As part of the Regenerative Code, producers are required to identify areas of high biodiversity and natural vegetation. Measurable increases in carbon sequestration both above and below ground are required.

REEL producers are required to identify forest types on the production unit so that they may be protected and restored correctly. These requirements stipulate that any expansion of cotton production cannot be to the detriment of the forest’s identified value. Measurable increases in carbon sequestration, both above- and below-ground, are required.

REEL Regenerative producers are required to demonstrate a measurable increase in carbon sequestration.

The Higg MSI does not hold LCA data for REEL CottonConnect.

The Higg MSI does not hold LCA data for REEL CottonConnect.

REEL producers are required to implement water management plans that identify the water sources in production and their stability, and record water use volumes. This plan must be developed in collaboration with relevant stakeholders to ensure that water sources are conserved.

REEL producers are required to identify water sources and their stability before using them in production. Producers must also record the volumes of water used for irrigation.

REEL Regenerative producers must ensure that water used for irrigation is safe for human health, and submit analytical proof if there is any doubt over this. REEL has published an LCA report that highlighted a lower risk of water contamination when compared to the baseline. This can serve as a partial example of monitoring for the pressures to and state of water contamination.

Optimizing water withdrawal values and processes is a named objective of REEL certification. Evidence of progress is tracked through records of producers’ water use. Water use figures found in REEL’s annual impact report highlight continuous improvement in water use when compared to baseline values. As part of the Regenerative Code, producers must demonstrate that there is no evidence of the depletion of water sources on the production unit (or within a 500m radius) as a result of water extraction.

As part of the Regenerative Code, REEL producers make a commitment to water quality, specifically for the water used in irrigation. Additionally, REEL has published an LCA report that demonstrates a commitment to continuous improvement in water contamination when compared to baseline values.

While producers are required to keep track of water usage throughout production, there is no evidence that specific water sources are named in the tracking of water use.

Surface water quality is named as a priority metric in REEL cotton production. REEL specifically identifies water quality preservation as it pertains to chemical runoff.

REEL producers work with cotton varieties that are region-specific or recommended for the production unit. Cotton is a biobased fiber, which reduces the risks associated with oil and gas extraction during production.

The Higg MSI does not hold LCA data for REEL CottonConnect.

The Higg MSI does not hold LCA data for REEL CottonConnect.

The Higg MSI does not hold LCA data for REEL CottonConnect.

Producers must ensure that chemicals are targeted specifically for the intended use case. Producers are provided a list of acceptable chemicals to use in production. REEL management plans are adaptive and reviewed annually, as well as being designed with a SMART approach for making goals achievable, time-bound, and reflective of monitoring input.

REEL producers are required to adhere to the industry’s chemical handling best practice guidance on chemical labeling, storing, separating, and disposal.

REEL producers are prohibited from using chemicals that are banned in international agreements such as the Stockholm and Rotterdam Conventions. Remediation procedures and updates to the chemical management plan are developed using monitoring results.

REEL producers are required to reduce the volume of pesticides used over time. Records of volumes used are available. As part of the Regenerative Code, producers must commit to phasing out herbicide use completely within five years of certification.

REEL producers are required to prioritize mitigation of runoff/discharge into bodies of water. There are requirements to address the possibility of sludge and solid waste discharge. Additionally, producers are required to follow a restricted chemical inputs list that aligns with the Stockholm and Rotterdam Conventions.

The Higg MSI does not hold LCA data for REEL CottonConnect.

REEL producers are required to implement soil health management plans that take into account site-specific soil considerations on soil fertility and erosion. As part of the Regenerative Code, training on producing and using compost is provided and community centers for the production of bio inputs have been established. This plan is adaptive and developed in collaboration with relevant stakeholders.

REEL producers are required to identify soil conditions through a soil analysis to determine levels of organic matter before the use of fertilizers. This shows producers monitor the state of soil health. As part of the Regenerative Code, producers use the results of soil analysis to tailor and adapt nutrient management plans – addressing some aspects of soil health monitoring and remediation.

REEL producers are required to take measures to increase soil fertility and decrease erosion, demonstrating that soil health is prioritized during production. As part of the Regenerative Code, producers are required to demonstrate continuous improvement in certain soil health values, such as soil biodiversity, through an annual soil health analysis.

REEL outlines soil structure and nutrient values as priority objectives in certified production.

REEL producers engage in crop rotation, intercropping, low till (depth and frequency), and the use of organic amendments and crop residues to promote soil health.

As part of the Regenerative Code, producers are required to take steps to protect and tailor production practices to the land on the production unit. Additionally, REEL management plans are adaptive to monitoring results and reviewed annually. Expert stakeholders are consulted to develop the land management plan.

REEL producers demonstrate ambition in land strategy by actively restoring unproductive land but not converting it to produce cotton.

REEL producers are required to take steps to reduce deforestation risk and address past harms through restoration. Primary and secondary forests over ten years old must not be converted for production, and restoration procedures are in place for forests under ten years old to address any harm caused by production.

REEL producers are required to take steps to reduce land conversion risks and address past harms through restoration. Primary and secondary forests over ten years old must not be converted for production, and restoration procedures are in place for forests under ten years old to address any harm caused by production.

REEL producers are required to implement an Integrated Pest Management system which necessitates an awareness of biodiversity values and risks on the production site. Procedures are additionally required to maintain those values and reduce risks to them. As part of the Regenerative Code, producers are required to map important biodiversity values on the production unit, such as native plants and threatened species.

REEL producers are required to be aware of pest presence on the production unit. This is indicative of monitoring the causes of biodiversity loss. Additionally, as part of the Regenerative Code, producers are provided a map of threatened species in the region, which is indicative of monitoring the state of biodiversity in and around the production unit. REEL Regenerative producers use the results of biodiversity monitoring to tailor and adapt management plans.

REEL certification highlights biodiversity as a priority objective through the protection of biodiversity values in pest control procedures. As part of the Regenerative Code, producers must demonstrate continuous improvement in biodiversity through increased native species counts. Additionally, the Regenerative Code requires that no expansion of production takes place if biodiversity values stand to be negatively affected.

REEL producers are required to identify, maintain, and restore buffer zones on the production unit.

While REEL outlines that unproductive land must be restored for naturalization, it is unclear if producers are required to use a minimum amount of land for set-asides.

REEL producers implement non-lethal control measures for pests, as well as restricting the use of certain chemicals and their applications to reduce risk to the environment through runoff or leeching.

REEL producers are required to take action to mitigate the introduction of pests to the production site and prevent their spread. Mechanical controls are prioritized over the use of chemicals or lethal measures.

REEL producers are required to reintroduce organic residues of production back onto the field as fertilizer and identify hazardous waste streams with appropriate disposal techniques. This represents a general waste reduction plan. The REEL Regenerative Code adds to this plan with requirements to keep fields free from inorganic waste and ensure that disposal techniques do not harm environmental or human health.

REEL producers are required to separate organic and hazardous waste streams from others. REEL producers recycle organic residues to be reintroduced back onto the field for production. As part of the Regenerative Code, producers are required to keep waste (mainly field waste) at its highest quality to turn it into compost and bio inputs.

REEL producers work to produce cotton, a renewable, bio-based resource. However, there are no commitments to use recycled inputs.

The REEL Regenerative Code requires that payment and working hours are stipulated by regional and national legislation. There are additional criteria in place for equal pay for equal work regardless of gender or nature of contract (such full-time vs temporary), and that temporary contracts are not used for work that is full-time. REEL also requires that provisions on breaks, bonuses, and overtime pay are detailed in the contracts provided to workers. Sanitation and hygiene stations are also provided to workers.

Forced labor as defined in ILO Conventions 29 and 105 is expressly prohibited under the REEL certification criteria, which includes sector-tailored provisions aimed at preventing forced labor on cotton farms. REEL requires that a grievance and remedy procedure is in place.

REEL requires that children under the age of 15 are not employed on producer farms, and that the worst forms of child labor do not occur. Incidences of any kind of child labor will be documented in order to support a monitoring and remediation plan for child labor.

REEL requires producers to prevent and address instances of discrimination of any kind. This extends to discrimination on the basis of race, gender, ethnicity, disability, age, etc. There is a grievance and remedy procedure in place to raise grievances on discrimination, with the aim of achieving remediation.

REEL producers are free to unionize and associate. Management cannot discriminate against individuals for joining a union, interfere with decisions to join or the activities of worker unions, or limit the scope of collective bargaining. Additionally, REEL requires that if there is no union presence on a farm, a worker committee is to be democratically elected to represent workers in management decisions. A grievance and remedy procedure is in place and workers’ unions/committees are aware of its procedures in the event that management does not obey legal rules.

REEL producers are required to implement an occupational health and safety management plan that consists of: a responsible party for implementing chemical procedures, safe chemical handling, application, and disposal protocols, adequate personal protective equipment provided to those who handle chemicals, and hygiene and sanitation stations on the production unit.

The REEL Code of Conduct has a theory of change that outlines increasing producer income as a central component. Furthermore, REEL requires producers to ensure a safe work environment, offer fair pay aligned with regional standards, and promote communal development initiatives. Producers emphasize equal pay for women and empower them in cotton projects. As part of the Regenerative code, producers must help farmers diversify income and reduce input costs over time.

There is no evidence that REEL requires producers to engage with or identify legal and customary land rights of Indigenous peoples in accordance with the UN Declaration on the Rights of Indigenous Peoples.

REEL Regenerative producers must comply with land and water tenure agreements in accordance with national law. Cotton must be planted in regions suitable for production, or regions that have historically been known to grow cotton.

There is no evidence that REEL requires producers to engage with the local community to identify, address, or mitigate certain impacts resulting from production.

There is no evidence that REEL requires producers to monitor whether there is a sufficient human rights-enabling environment to operate.

A grievance mechanism is required in REEL cotton production. It has a committee in place for handling grievances relating to gender issues and women’s rights. Additionally, the grievance process is accessible to anyone who may be impacted by the activities of cotton production and is intended to provide remedy in cases of harm.

REEL producers are required to eliminate gender-based discrimination and pay gaps. These criteria take some steps to address gender-based violence and harassment in cotton production.

The organization has published a Theory of Change, stating desired impacts of the program and strategic pathways and interventions to achieve them. The standard document describes the objective of the standard and the overarching goal of the program it is part of. The goals set in the Theory of Change are both measurable and time-bound. The Theory of Change is actively communicated to—and socialized among—relevant stakeholders.

The organization behind the standard has published a separate document describing the process through which the standard was developed. Revisions have been made no more than five years apart. There are no procedures for making urgent substantive and non-substantive changes outside the full revision process. The document states that public consultations are part of the development and revision process, and as well as the research it is based on.

The website provides an overview of the organization’s governance composition, mentioning the different roles and responsibilities of the executive management team. The organization has several policies in place that are publicly available, including safeguarding, anti-bribery and -corruption, and conflict of interest policies. There is no option for membership or similar level of participation in governance.

The organization has published a separate document containing its chain of custody and traceability framework, as well as its claims system. However, it remains unclear what the requirements are for making sure that claims are in line with the chain of custody model, or what the procedures and consequences are for the misuse of claims.

The organization has published its assurance approach. While the organization partners with third-party verifiers, it is not mentioned whether these verifiers are accredited by independent accreditation bodies. Not all of the roles and responsibilities of certification and accreditation bodies are clear. Annual audits are required. There is no clear guidance available to auditors on the standard’s content and assurance requirements.

The standard organization does not define clear procedures for conformity assessment, which would enable the consistent determination of non-conformity levels.

The organization does not require assurance partners to conduct risk-based auditing.

The website provides a contact form and basic contact details for providing feedback, as well as a special email address for grievances and complaints. These are complemented by basic instructions. A separate document provides guidance on how to submit input and the policies and procedures on how and by whom the input will be handled. Stakeholders are actively invited to provide input for the development and revision of the Theory of Change and MEL system.

The organization has published multiple reports on the organization and program’s achieved impact. The majority of indicators are at the outcome and impact level. The organization defines the frequency by which it will evaluate its system components. There is no policy or procedure for data communication. A guiding framework is provided in the latest impact report, which also defines how tracked performance is linked to goals set in the Theory of Change and how progress towards these goals is measured.

ABR producers demonstrate general concepts of emissions management – understanding sources and future implications of emissions in production. They also mandate procedures for navigating increasing extreme weather occurrences.

ABR requires producers to monitor scope I emissions from farm-level production such as emissions from waste.

ABR producers are required to specify the importance of environmental/climate concerns in production as well as for the larger community and future.

ABR producers are required to outline soil health practices and considerations in line with climate mitigation; soil water cycle, structure, and microbial content. It also has criteria to test that chemicals and fertilizers are applied in the correct dosage and manner to reduce overapplication and discharge.

ABR requires producers to follow national legislation in maintaining riparian areas in production zones and implements procedures to navigate extreme weather events.

No evidence suggests that ABR producers are required to outline criteria for the identification and subsequent protection of below-ground carbon stocks.

No evidence suggests that ABR outlines criteria for the identification and subsequent protection of above-ground carbon stocks.

No quantitative monitoring of soil carbon sequestration is mandated under ABR, though proxy measurements/monitoring are evidenced to take place in the form of soil structure verifications.

The Higg MSI does not hold LCA data for ABR cotton.

The Higg MSI does not hold LCA data for ABR cotton.

ABR requires producers to produce site specific water management plans, identifying and mapping of water sources. It also stipulates maintaining water sources through production, avoiding over consumption or contamination. Room for improvement exists in regular updates and development with relevant stakeholders.

ABR has requirements for monitoring the procedure and amount of water used daily at producer level, such as the identification of practices to ensure groundwater isn’t negatively impacted by production.

The program requires monitoring water contamination pressures and state, minimizing impacts on water quality from chemical residues and monitoring for water quality to maintain a safe quality for human consumption.

Monitoring daily water use is a priority requirement for ABR certification along with the stipulation that extraction can’t negatively impact waterways or sources leading to a system that can be expected to regularly minimize impacts and take steps towards more sustainable water consumption.

ABR has criteria in place to keep water on production units at high quality: Implementing practices to minimize chemical contamination and keeping drinking water at potable quality.

ABR demonstrates comprehensiveness in their water strategy by outlining key water sources to protect [in quality and quantity]: Surface water and groundwater.

ABR demonstrates comprehensiveness in its water strategy by outlining key water sources to protect [in quality and quantity]: Surface, ground and drinking water from contamination.

For cotton, the feedstock is 100% biobased. No commitments to renewable energy are applicable to cotton with no standard system production around the world.

The Higg MSI does not hold LCA data for ABR cotton.

The Higg MSI does not hold LCA data for ABR cotton.

The Higg MSI does not hold LCA data for ABR cotton.

ABR requires components of regionally-specific chemical management plans: key information must be communicated to employees regarding how and when to apply chemicals, as well as necessary equipment and how to use it during the process. Evidence for the regular reviewing and updating of chemical management plans under ABR is not supported.

ABR outlines requirements for producers to store, separate, label, and dispose of chemicals in line with national legislation. Records are kept of pesticides used, and their application methods.

A priority criterion is implementing a ban on chemicals found in the Stockholm Convention, making it certain that ABR producers are at least compliant with one widely accepted chemical ban. There is a second criterion which makes it likely that producers also follow pesticide use as dictated by WHO and Rotterdam.

ABR requires producers to understand the importance of chemical management in the production process and ensures it is communicated to all employees.

As input chemistry is outlined to be a priority criteria for ABR producers, they can reasonably be expected to implement a widely-accepted Manufacturing Restricted Substance List, such as the Stockholm and Rotterdam Conventions. Additionally, producers have an explicit criteria to recognize the potential for chemical discharge into waterways.

The Higg MSI does not hold LCA data for ABR cotton.

ABR producers are required to maintain several aspects of soil health: structural, biological, chemical, nutrient and water balance. These practices are focused on at the farm level, however, evidence doesn’t support a review and update process for soil management.

ABR requires soil health outcomes that necessitate monitoring to fulfill, such as causes of degradation and state of soil quality. Proving optimal soil structure and nutrient balance is reflective of state monitoring whereas erosion control requires pressure monitoring.

Soil health criteria are present throughout the ABR certification, and prioritized outcomes can be seen in criteria to prove soil health in terms of structure, water use and nutrient balance.

ABR requires the demonstration of soil health outcomes/metrics including structural nutrient balance, microbial health, chemical balance and water retention.

ABR mandates soil health outcomes in the form of soil structure, water retention and microbial health but doesn’t outline specific practices to produce these outcomes.

ABR outlines that land must be managed according to national legislation, specifically in regard to expansion/conversion. Though without explicit land management concerns, risks still remain.

National law prescribes percentages of set-asides to maintain permanently in production zones and requires any deforestation or land conversion to be in accordance with national legislation. However no requirements on continuous improvement to land health are identified in the certification.

National law prescribes percentages of set-asides to maintain permanently in production zones and requires any conversion of natural land to be in accordance with national legislation.

National law prescribes percentages of set-asides to maintain permanently in production zones and requires any deforestation or land conversion to be in accordance with national legislation.

ABR demonstrates concepts of biodiversity management: maintaining and restoring degraded areas and mapping areas of biodiversity importance in the production unit.

The mapping of biodiversity features like springs, water bodies, and vegetation is indicative of monitoring the state of biodiversity. Additionally, with the implementation of an IPM, it can be expected with reasonable certainty that monitoring pressures on biodiversity such as chemical use on species will take place.

ABR shows continuous improvement to biodiversity in the criteria to have plans for protecting and restoring degraded areas on the production unit.

ABR highlights that producers must have plans in place for the protection and recovery of buffer zones and riparian areas.

Producers in Brazil are required by law to set aside a percentage of their farm for naturalization. This figure stands to shift depending on the size of the farm and the ecosystems it’s on or near. For example, 20% of private farms should be conserved outside of the Amazon compared to 35% inside the region.

ABR demonstrates two concepts of Species and Genetic Diversity: forbidding hunting on reservation land and non-lethal control methods under the IPM.

ABR mandates the use of an Integrated Pest Management system [IPM] that prioritizes the use of beneficial organisms in maintaining resistance to and avoiding the introduction of invasive species.

The main risks associated with waste are linked to improper management of chemicals, waste, and waste byproducts as well as fertilizer and pesticide application at the farm level. There is no evidence to suggest that ABR aims to reduce waste produced in the cotton growing processes.

ABR outlines considerations for turning waste streams to energy at the production level — no other actions to maximize the value of waste streams are supported.

ABR mandates that producers purchase seeds from the National Seed Registry in Brazil, supporting that all feedstock is biobased, though no commitments to renewable energy are supported or required for ABR producers

ABR requires adherence to minimum salary and/or piece-rate pay in line with the national standards. In addition, ABR requires working hours and schedules in line with a 48-hour weekly limit inclusive of breaks, leave and social security considerations, and upholds the right to collective bargaining and join unions.

ABR requires adherence to ILO Conventions 29 and 105, identifying coercion—physical, psychological or financial—as top forms of forced labor. In addition, ABR does not certify producers that force workers to make purchases exclusively at establishments chosen by employer, or producers that embarrass, harass or take benefits away from workers.

ABR requires practices that address risks of child labor: children and adolescents [under 16 years old] should not be required or requested to work in cotton production—even occasionally. And while support is offered to parents to enroll kids in school, there are no provisions on child labor that are linked to ILO Conventions 138 and 182. As such, risks of compliance on child labor remain at the field level for ABR standard producers.

ABR requires producers to prevent and prohibit discrimination in the workplace on the basis of age, gender, race, religion, sexual orientation, and appearance, among others. ABR also specifies the prohibition of discrimination in the form of management-subordinate relationships and strengthens its monitoring of non-discrimination criteria through grievance and remedy channels.

ABR requires adherence to production systems that prioritize freedom of association, i.e. production systems that do not interfere with workers’ right to unionize, do not discriminate against workers’ views or activities related to unions, and do not interfere or manipulate workers’ representatives or limit the scope on collective bargaining. Additionally, ABR raises awareness of workers’ right to unionize and collective bargaining.

ABR requires producers to implement a health and safety management plan with a person responsible for overseeing the development and use of first-aid stations. ABR outlines requirements for the provision of PPE to workers free of cost, and chemical handling and restriction guidelines to further reduce the risk of chemical-related accidents.

ABR has a core Theory of Change which promotes social, economic, and environmental success for cotton production/producers. As part of its Theory of Change, requirements are in place for responsible purchasing practices and offering inputs at sustainable prices.

There is no evidence that ABR has requirements in place relating to Indigenous peoples and customary land rights. In particular, there are no requirements in relation to respecting legal and customary land rights of Indigenous peoples in accordance with UN Declaration on the Rights of Indigenous Peoples or Engagement with Indigenous groups affected by operations.

ABR requires producers respect legal and customary land and water tenure arrangements in accordance with national law.

There is no evidence that ABR has requirements in place for community consultation and engagement [right to participation]. In particular, there are no requirements that requires participation in community consultation to identify, mitigate or address potential conflicts, or requirements for disclosure of information on risks and impacts.

There is no evidence that ABR has requirements in place to address risks related to enabling the environment for human rights realization. That is, there are no requirements for periodic evaluation and testing of risks relating to enabling the environment for human rights realization [such as heavy restrictions on democratic processes or civil rights, or systemic, state-supported violations of one or more human rights].

There is no evidence that ABR has requirements in place to address risks related to grievances and remedies. In particular, there is no evidence that ABR has requirements for certified producers to provide for or participate in a mechanism to receive and respond to grievances received in relation to production-level operations, provide for or participate in remediation of key risks identified through the grievance mechanism, or that the grievance mechanism should include the ability for workers to raise complaints anonymously.

ABR requires producers to implement a transparent policy to prevent discrimination on the basis of gender and sexual orientation. However, no requirements on female worker engagement or participation in verifications are present in the standard. Furthermore, as no monitoring or remedy process is in place, risks of gender-based harassment and violence going unnoticed in production remain.

ABR’s strategy revolves around three pillars: social, environmental, and economic. It envisions a better land, life, and viable business. ABR follows the Better Cotton standard, which includes a Theory of Change in its standard. The strategy’s statements are generally broad, without specific targets or timelines. ABR conducts social projects with state associations, socializing its Theory of Change and collaborating on budgeting and activities.

No standard-setting procedure for ABR could be found. The website states it is the result of the development and union of two programs—Instituto Algodão Social [IAS] in Mato Grosso, and the Socio-Environmental Program for Cotton Production [Psoal]—and the standard is benchmarked against the Better Cotton standard. However, no further procedures were found.

ABR’s management structure comprises a General Assembly, Board of Directors, and Fiscal Council. There are no specific policies on impartiality and inclusiveness. Roles and responsibilities of the secretariat employees are defined on the website. ABR has been open to membership since 2014, with detailed regulations governing elections, the functioning of working groups, and admission procedures.

ABR has extensive documentation on claims management and the Chain of Custody model. The model caters to different stakeholders and emphasizes transparency. It clarifies the mass balance Chain of Custody, ensuring cotton claims align with purchase quantities. Implementing partners play a crucial role in traceability and must report any misuse of Annual Authorised Volume [AAV] codes. However, there is no information regarding content- versus outcome-based claims.

ABR has a separate document outlining policies and procedures for assurance providers, including oversight. Independent certification bodies accredited by ABR conduct external audits of farms. The roles and responsibilities of accreditation bodies are not specified. Training is provided to auditors, requiring participation in ABR program training to ensure knowledge of criteria, forms, and reporting. The training facilitates understanding of program requirements.

ABR has procedures for handling non-conforming products, distinguishing between minor and major non-conformities. Major non-conformities must be corrected within 30 days. Improper use of the certificate or seal can lead to suspension or cancellation of usage rights. No evidence was found of a motivation mechanism for certified organizations or Certification Bodies.

ABR does not take a risk-based approach to auditing. There is no explicit risk management plan, risk map, or published identification of risks specific to ABR or the cotton sector.

General contact details and a contact form are available on the ABR website, which may be used to submit feedback, complaints and grievances. However, no clear instructions are provided. No clear roles and responsibilities are defined for handling feedback, complaints and grievances and no evidence was found of stakeholders being informed about opportunities to provide their input.

ABR does not define a guiding framework for its Monitoring, Evaluation, and Learning system.

US Cotton Trust Protocol requires an emissions management plan that encompasses GHG emissions accounting and energy use monitoring, along with emissions mitigating practices, training and access to financial support for producers.

US Cotton Trust Protocol has criteria that requires the monitoring of energy use and greenhouse gas emissions resulting from production. These measurements are tracked against the US Cotton ten-year goals in annual impact reports.

As part of the ‘US Cotton Sustainability: 10 year industry goals’, producers commit to decrease their emissions by 39% by 2025. This is representative of a continuous improvement commitment to emissions reduction.

US Cotton Trust Protocol (USCTP) requires producers to implement controlled-release and stabilized fertilizers, as well as procedures to reduce the chance of nutrient overapplication. USCTP is part of the USDA’s Climate-Smart Commodities program, which provides finance and training for producers with the aim of implementing climate-mitigating procedures.

US Cotton Trust Protocol (USCTP) requires producers to protect and/or enhance riparian areas and implement soil health-building practices that increase organic content and water-holding capacity. USCTP is part of the USDA’s Climate-Smart Commodities program, which provides finance and training for producers with the aim of implementing climate-mitigating procedures.

While individual producers may have procedures in place, there is no evidence to suggest that US Cotton Trust Protocol requires the identification and protection of peat soils.

While individual producers may have procedures in place, there is no evidence to suggest that US Cotton Trust Protocol requires identification and protection of above-ground carbon stocks.

US Cotton Trust Protocol has a robust monitoring system in place that quantifies soil carbon sequestration and aggregates it into a standard-wide database. These figures are also reflected in annual impact reports.

The Higg MSI does not hold LCA data for the US Cotton Trust Protocol.

The Higg MSI does not hold LCA data for the US Cotton Trust Protocol.

US Cotton Trust Protocol producers are required to develop and implement a water management plan. This plan must be site-specific and in accordance with local legislation on water use and health values. Additionally, water management plan criteria are reviewed by US Cotton every three years.

US Cotton Trust Protocol producers are required to monitor the state and pressures of water use efficiency during production. Producers are additionally required to feed these results into the standards database for aggregation.

US Cotton Trust Protocol producers are required to monitor the state and pressures to water quality during production. Producers are additionally required to feed these results into the standards database for aggregation.

As part of the ‘US Cotton Sustainability: 10 year industry goals’, US Cotton Trust Protocol producers are expected to decrease water use by 18%. This is representative of a continuous improvement commitment to water withdrawal.

US Cotton Trust Protocol producers are required to take measures to prevent the contamination of water resources from sediment, chemicals, or fertilizers.

US Cotton Trust Protocol producers are required to take measures to increase efficiency in rainwater use.

US Cotton Trust Protocol recommends that producers consider streams, rivers, and lakes when protecting and fertilizing crops.

Cotton is a biobased feedstock, which reduces the risks associated with oil and gas extraction for production. However, US Cotton Trust Protocol does not have commitments for renewable energy use or synthetic chemical restrictions.

The Higg MSI does not hold LCA data for the US Cotton Trust Protocol.

The Higg MSI does not hold LCA data for the US Cotton Trust Protocol.

The Higg MSI does not hold LCA data for the US Cotton Trust Protocol.

Between the implementation of Integrated Pest Management and Nutrient Management plans, US Cotton Trust Protocol requires a chemical management plan that is site-specific. Additionally, the criteria in the plan are reviewed and updated by US Cotton every three years.

US Cotton Trust Protocol requires producers to handle, store and separate, clean and dispose of the chemicals used in production.

While individual producers may have procedures in place, there is no evidence that US Cotton Trust Protocol requires producers to monitor for chemical use or implement a restricted chemistry list in line with international agreements such as the Stockholm, Rotterdam or Montreal Conventions.

While individual producers may have procedures in place, there is no evidence that US Cotton Trust Protocol requires continuous improvements on chemical use.

US Cotton Trust Protocol prioritizes minimizing chemical runoff into bodies of water.

The Higg MSI does not hold LCA data for the US Cotton Trust Protocol.

US Cotton Trust Protocol producers are required to implement a nutrient management plan to optimize and maintain soil quality during production. It is site-specific and includes provisions for identifying soil health risks. Additionally, the criteria in the plan are reviewed and updated by US Cotton every three years.

US Cotton Trust Protocol producers are required to monitor the state of and pressures on soil quality. This includes measurements such as soil carbon and soil loss. Producers must also provide US Cotton Trust Protocol with soil quality data.

As part of the ‘US Cotton Sustainability: 10 year industry goals’, producers are to increase soil carbon by 30% and reduce soil loss by 50%. This is representative of a commitment to the continuous improvement of soil health.

US Cotton Trust Protocol producers are required to name microbial and structural health, carbon, water, and nutrient cycles, and chemical balance as priority objectives. This is done through monitoring, continuous improvement commitments, and soil health practices.

US Cotton Trust Protocol requires the promotion of soil health in all of its components. To increase soil carbon and reduce soil loss, producers implement low or conservation tillage, cover cropping, and crop rotation.

US Cotton Trust Protocol demonstrates the implementation of a land management plan through criteria to identify and protect (not convert) sensitive areas and wetlands. It is site-specific and includes provisions for identifying risks of land degradation. Additionally, the criteria in the plan are reviewed and updated by US Cotton every three years.

As part of the ‘US Cotton Sustainability: 10 year industry goals’, producers are required to increase land use efficiency by 13% from 2015-2025. This represents a commitment to the continuous improvement of land use health.

While US Cotton Trust Protocol prohibits the use and conversion of wetlands for production, there is no evidence that this extends to forests.

US Cotton Trust Protocol producers take steps to reduce risk of land conversion—namely with regard to the conversion of and production on wetlands.

US Cotton Trust Protocol requires the implementation of an Integrated Pest Management plan that takes into account historical pest information and monitoring to tailor practices to the production site – addressing some aspects of biodiversity management on the production unit. Additionally, the criteria in the plan are reviewed and updated by US Cotton every three years.

US Cotton Trust Protocol requires producers to monitor and identify pests on the production unit – representative of monitoring for pressures to biodiversity health. Furthermore, this information is to be reported to USCTP for aggregation in annual reports.

US Cotton Trust Protocol names biodiversity as a priority outcome of certification. This is shown through commitments to species biodiversity and land use procedures.

US Cotton Trust Protocol requires producers to maintain buffer and riparian zones on the production unit. The standard also requires the use of host plants as pest resistance.

US Cotton Trust Protocol producers are required to retire unproductive land for naturalization, though there is no size threshold noted. Furthermore, set-asides are only required if the land is unproductive.

US Cotton Trust Protocol requires precision application of chemicals and pesticides to prevent runoff and leaching into the surrounding environment.

US Cotton Trust Protocol requires producers to monitor for pests on the production unit and implement prevention practices such as host plant resistance.

US Cotton Trust Protocol producers follow procedures to preserve fiber quality in harvest and storage, and to minimize contamination from plastic and other contaminants.

While individual producers may have procedures in place, there is no evidence that US Cotton Trust Protocol mandates waste stream monitoring, separation, or reuse.

Cotton is a renewable feedstock. However, the US Cotton Trust Protocol does not require any commitments to use recycled feedstock.

US Cotton Trust Protocol requires wages to be equal to or higher than US federal minimum wage. Additionally, employers must disclose (orally or in writing) wage rates, housing, transportation, and working conditions. There is potable water and accessible hygiene stations are required on the production unit. Finally, US Cotton Trust Protocol has criteria in place to ensure equal pay for equal work, regardless of gender.

US Cotton Trust Protocol mandates that no forced, coerced, or prison labor is to be permitted on certified production units.

US Cotton Trust Protocol requires that no underage labor takes place on production units, aligning with ILO conventions on child labor.

In keeping with the US Equal Employment Opportunity Commission guidelines, there is no discrimination of any kind permitted in the workplace. This also means that equal pay for equal work must be extended to workers regardless of race, gender, or ethnicity.

US Cotton Trust Protocol producers have freedom of association. Workers/employees are free to create and join organizations of their choosing. Furthermore, management does not interfere with workers’ ability to bargain collectively.

US Cotton Trust Protocol requires the implementation of a health and safety management system with emergency procedures, first aid kits, and access to transportation and medical facilities as needed. The standard also requires chemical handling best practice, from application to storage to cleaning and disposal. PPE must be provided, as well as access to potable water and hygiene stations.

US Cotton Trust Protocol has a theory of change that aims to preserve the sustainability of producer livelihoods as a result of certification by the standard.

While individual producers may have procedures in place, there is no evidence to suggest that customary land rights are factored into US Cotton Trust Protocol cotton production.

While individual producers may have procedures in place, there is no evidence to suggest that customary land rights are factored into US Cotton Trust Protocol cotton production.

While individual producers may have procedures in place, there is no evidence to suggest that community consultations are factored into US Cotton Trust Protocol cotton production management plans.

While individual producers may have procedures in place, there is no evidence to suggest that an enabling environment for human rights realization is assessed in US Cotton Trust Protocol cotton production monitoring.

US Cotton Trust Protocol has implemented a grievance and remedy process that requires producers to provide for or participate in a mechanism to receive and respond to grievances received in relation to production level operations, to provide for or participate in remediation of key risks identified, through the grievance mechanism, and there is responsibility assigned to a person or committee (or equivalent) to manage and/or oversee a formal grievance resolution mechanism or process.

US Cotton Trust Protocol prohibits discrimination of any kind and requires that equal pay for equal work be extended to all employees regardless of race, gender, ethnicity etc.

The US Cotton Trust Protocol outlines its mission, vision, and values, detailing its operations from farm to fabric. Its goal is transparent sustainability and reduced environmental impact. The protocol focuses on principles such as soil health, water management, and worker well-being. These principles are measured through six overarching sustainability metrics and aligned with 2025 goals. The protocol actively socializes its Theory of Change and builds industry awareness of environmental impact.

The organization outlines procedures for standard development. The standard is shaped through a five-step process involving experts and growers. Revisions occur every three years, with varying levels of changes and stakeholder consultation. Public consultations are currently absent. The goals of the organization are aligned with the UN Sustainable Development Goals and the US 2025 national goals. However, research on indicators and their effectiveness is missing.

The US Cotton Trust Protocol’s governance composition includes a multi-stakeholder board of directors, advisors, and staff. Clear roles and responsibilities are delineated for staff members and their functions are mentioned on the website. The organization is open for membership among growers, brands and retailers, mills and manufacturers, merchants and cooperatives, among others. The organization does not define policies for impartiality and inclusiveness.

The US Cotton Trust Protocol defines a claims framework to ensure verified, credible protocol claims and transparent communication. The ‘Protocol Consumption Management Solution’ tracks cotton to the article level throughout the supply chain using two-level verification, and claims are aligned with this level of transparency. Misuse is monitored, and violations may lead to termination. The program allows for different types of claims, including Program Outcome Claims and On-product Content claims.

The US Cotton Trust Protocol outlines a concise verification process document. They partner with Control Union as a certification body, but lack an independent accreditation partnership. Roles and responsibilities for the certification body are unclear. Certification is valid for one year. No clear guidance for auditors has been published.

The US Cotton Trust Protocol does not define clear procedures for conformity assessment, which would enable the consistent determination of non-conformity levels.

US Cotton Trust Protocol employs risk-based assurance through the regional grouping of growers, using a square root model and previous year’s audit data to determine the verification sample. However, the organization does not share a risk management plan, map, overview, or quantification approach.

The website offers a contact form for feedback, complaints, and grievances. A documented grievance process defines clear roles and responsibilities, with the aim of ensuring Code of Conduct compliance and confidentiality. Industry feedback is gathered from meetings, events, surveys, and trends, and stakeholders are informed of how their feedback has been integrated into the program.

The standard collects extensive data from farmers and reports insights in their annual report. Six key pillars of progress are tracked and reported on: yield, water, energy, emissions, soil, and carbon. The frequency of system component evaluation is not defined, but data accessibility to stakeholders is. The guiding framework for the MEL system is linked to the goals set in the organization’s Theory of Change, and growers’ continuous improvement on key metrics based on these goals is measured.

The main climate risks associated with cotton production relate to field emissions of nitrous oxide along with fertilizer and pesticide production. Where there is no standard system, it is assumed that emission management is not addressed, even if individual producers have some procedures in place.

Where there is no standard system, it is assumed that emission monitoring is not conducted to track emissions at any scope or align with any accounting methodology, even if individual producers have some procedures in place.

Where there is no standard system, it is assumed that an emission strategy is not implemented at farm level, even if individual producers have some practices in place.

Virgin cotton generally adopts conventional tillage practices, surface irrigation, and high use of pesticides and fertilizers—processes that weaken surrounding ecosystems and can lead to high carbon dioxide emissions. Where there is no standard system, it is assumed that climate mitigation practices are not adopted at farm level, even if individual producers have some practices in place.

Virgin cotton generally adopts conventional tillage practices, surface irrigation, and high use of chemicals and water. Where there is no standard system in place, it is assumed that no climate resiliency methods to protect against extreme weather events are implemented, even if individual producers have some procedures in place.

Where there is no standard system, it is assumed that there is no participation in identifying, protecting, and restoring peat soils and/or areas of below-ground carbon stocks through producer management practices.

Where there is no standard system, it is assumed that there is no participation in identifying, protecting, and restoring areas of above-ground carbon stocks through producer management practices.

Evidence shows that cotton’s ability to sequester carbon exists. However, where there is no standard system in place, it is assumed that monitoring activities are not in place.

The Higg MSI holds LCA data for cotton with no standard system.

The Higg MSI holds LCA data for cotton with no standard system.

While cotton can be rainfed, irrigation practices and the use of fertilizers and pesticides pose risks to water sources. Where there is no standard system, it is assumed that water management risks are not addressed, even if individual producers have some procedures in place.

Where there is no standard system, it is assumed that water monitoring for withdrawal or consumption is not conducted, even if individual producers have some procedures in place.

Where there is no standard system, it is assumed that water monitoring for contamination is not conducted, even if individual producers and or countries have legislation in place.

While rain-fed systems are utilized, water withdrawal and contamination risks still exist.
Where there is no standard system, it is assumed that a water strategy is not in place, even if individual producers have some procedures in place.

The use of pesticides and fertilizers can lead to water contamination risks in the production of cotton. Where there is no standard system, it is assumed that a water strategy is not in place, even if individual producers have some procedures in place.

Where there is no standard system, it is assumed that a water strategy is not implemented, therefore water health outcomes are undisclosed.

Where there is no standard system, it is assumed that a water strategy is not in place for the use or reduction of chemical leaching, or prioritization of water health outcomes.

Cotton feedstock is 100% biobased. Where the origin of feedstock is unknown and no program is in place, it is assumed there are no commitments to renewable energy.

The Higg MSI holds LCA data for cotton with no standard system.

The Higg MSI holds LCA data for cotton with no standard system.

The Higg MSI holds LCA data for cotton with no standard system.

The main chemical risks associated with cotton production relate to the use of fertilizer and pesticides at farm level. While national or local legislation might dictate best practices, where there is no standard system, it is assumed that chemical management procedures are not implemented, even if individual producers have some procedures in place.

Where there is no standard system, it is assumed that chemical management practices are not implemented, even if individual producers have some practices in place.

Where there is no standard system, it is assumed that chemical management monitoring or restricted chemistry lists are not implemented, even if individual producers have some practices in place.

Where there is no standard system, it is assumed that chemical management outcomes are not prioritized outside of national legislation, even if individual producers have some practices in place.

Where there is no standard system, it is assumed that a chemical strategy is not a prioritized outcome outside of national legislation, even if individual producers have some procedures in place.

The Higg MSI holds LCA data for cotton with no standard system.

The main soil health risks associated with cotton production relate to the use of chemicals and soil management practices at farm level. Where there is no standard system, it is assumed that soil health management plans are not implemented, even if individual producers have some procedures in place.

Where there is no standard system, it is assumed that soil health monitoring is not implemented, even if individual producers have some practices in place.

Where there is no standard system, it is assumed that soil health is not prioritized, even if individual producers have some practices in place.

Where there is no standard system, it is assumed that soil health development, such as soil structure and nutrient and water cycles, is not a prioritized outcome, even if individual producers have some procedures in place.

Where there is no standard system, it is assumed that beneficial soil health practices are not implemented, even if individual producers have some procedures in place.

The main land use risks associated with cotton production relate to the use of chemicals and soil management practices at farm level. Where there is no standard system, it is assumed that land management plans are not implemented, even if individual producers have some procedures in place.

Where there is no standard system, it is assumed that land management is not prioritized, even if individual producers have some practices in place.

Where there is no standard system, it is assumed that practices to mitigate deforestation on or around production sites are not implemented, even if individual producers have some procedures in place.

Where there is no standard system, it is assumed that practices to mitigate land conversion on or around production sites are not implemented, even if individual producers have some procedures in place.

The main biodiversity risks associated with cotton production relate to the use of chemicals at the farm level, which can lead to leaching into the surrounding ecosystem. Where there is no standard system, it is assumed that biodiversity management plans are not implemented, even if individual producers have some procedures in place.

Where there is no standard system, it is assumed that biodiversity monitoring is not implemented, even if individual producers have some practices in place.

Where there is no standard system, it is assumed that biodiversity is not prioritized and a strategy is not in place, even if individual producers have some practices in place.

Where there is no standard system, it is assumed that producers are not required to take action to reduce impacts to habitats and ecosystems, even if individual producers have some practices in place.

Where there is no standard system, it is assumed that producers are not required to protect and/or restore habitats and ecosystems, even if individual producers have some practices in place.

Where there is no standard system, it is assumed that producers are not required to promote species and genetic diversity, even if individual producers have some practices in place.

Where there is no standard system, it is assumed that producers are not required to identify and remove invasive species, even if individual producers have some practices in place.

While cotton waste is largely evidenced to be repurposed and/or left to bio-degrade for organic amendments, the main risks associated with waste are linked to improper management of chemicals at the farm level. Where there is no standard system, it is assumed that producers are not required to reduce waste through stated plans, and the likelihood of waste risks such as discharge and pollution going unaddressed remains high.

While cotton waste is largely evidenced to be repurposed and/or left to bio-degrade for organic amendments, where there is no standard system, it is assumed that producers are not required to utilize, track or evaluate waste streams within production processes.

Cotton as a plant is a renewable feedstock. Where there is no standard system, it is assumed that cotton can be genetically modified.

Where there is no standard system, it is assumed that there are no requirements in place to address risks related to wages and working conditions. In particular, there is no evidence of minimum wage/collectively bargained wage, remuneration, entitlements, and/or working time limits.

Where there is no standard system, it is assumed that there are no requirements in place to address risks related to forced labor. In particular, there is no evidence of prohibiting direct or indirect benefiting from forced labor [in alignment with ILO 29 and 105 and ILO Protocol 29] and eliminating forced or compulsory labor from large producers and managed production networks.

Where there is no standard system, it is assumed that there are no requirements in place to address risks related to child labor. In particular, there is no evidence for prohibiting the employment of child labor or young workers to perform hazardous work; and requiring large producers and managed production networks to take steps to prevent or eliminate the worst forms of child labor. The standard content criteria are not met and subsequent more advanced criteria are also not met.

Where there is no standard system, it is assumed that there are no requirements in place to address risks related to discrimination. In particular, there is no evidence of steps taken to prevent and address discrimination as defined in ILO Convention 111 and for steps taken to ensure equal remuneration for work of equal value as defined in ILO Convention 100.

Where there is no standard system, it is assumed that there are no requirements in place to address risks related to freedom of association. In particular, there is no evidence of requirements for certified producers to respect the rights to freedom of association and collective bargaining as defined in ILO Conventions 87 and 98.

Where there is no standard system, it is assumed that there are no requirements in place to address risks related to occupational health and safety. In particular, there is no evidence of requirements for certified producers to implement a health and safety management procedure or system; for certified producers to provide adequate protective clothing and personal protective equipment [PPE] to workers performing hazardous work; and for designated responsibility and accountability for enforcement of health and safety policies and/or plans/procedures.

Where there is no standard system, it is assumed that there are no requirements in place to address risks related to livelihoods [predictability and stability of income]. In particular, there is no evidence of requirements for having a core theory of change which includes increasing farmer income, enhancing livelihoods or improving predictability and stability of producers and own-account workers in fiber supply chains

Where there is no standard system, it is assumed that there are no requirements in place to address risks related to Indigenous peoples and customary land rights. In particular, there is no evidence for certified producers to respect the legal and customary land rights of indigenous peoples where they exist, in accordance with the UN Declaration on the Rights of Indigenous Peoples.

Where there is no standard system, it is assumed that there are no requirements in place to address risks related to land rights. In particular, there is no evidence for producers to respect legal and customary land and water tenure arrangements in accordance with national law.

Where there is no standard system, it is assumed that there are no requirements in place to address risks related to community consultation and engagement. In particular, there is no evidence of requirements for participatory consultation taking place within local communities to identify, mitigate or address potential conflicts, concerns or impacts and for producers to disclose information on risks and impacts for communities arising from the operation.

Where there is no standard system, it is assumed that there are no requirements in place to address risks related to enabling the environment for human rights. In particular, there is no evidence of a process to periodically evaluate and test whether there is a sufficient enabling environment for the program’s theory of change in the countries or regions in which the program operates or is seeking to operate.

Where there is no standard system, it is assumed that there are no requirements in place to address risks related to grievances and remedies. In particular, there is no evidence for certified producers to provide for or participate in a mechanism to receive and respond to grievances received in relation to production-level operations; for certified producers to provide for or participate in remediation of key risks identified through the grievance mechanism; and that the grievance mechanism should include the ability for workers to raise complaints anonymously.

Where there is no standard system, it is assumed that there are no requirements that address risks related to the prevention of gender-based discrimination, violence, and harassment. In particular, there is no evidence for certified producers to take steps to prevent and address discrimination on the basis of sex within the certified operation and for certified producers to take steps to address risks of Gender Based Violence and Harassment [GBVH].