Sustainable soy sourcing: The EUDR and beyond

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Soy is a commodity which means different things to different people, due to its range of different uses. 

On the one hand, soy is one of the most prominent and widely used commodities linked to deforestation, mostly due to the large amounts of soy grown for animal feed. According to the World Resources Institute​, 8.2 million hectares of deforestation were linked to soy between 2001 and 2015. Soy is, therefore, one of the commodities covered by the European Union Deforestation Regulation (EUDR)​, which comes into force on 30 December this year. However, production is still expanding, driving down commodity prices​ in a time when many other commodities​ are getting more expensive.

On the other hand, soy for humans is a key source of plant-based protein. While a mere 6% of soy, according to Our World in Data​, is used directly for human food, this soy has a high protein content and can be used in a variety of vegetarian and vegan products, from tempeh and tofu to plant-based meat. 

In other words, soy is both linked to one of the key environmental problems driven by the meat industry – deforestation – and part of the solution.

How can manufacturers know that the soy they are sourcing is part of the solution, but not the problem? How can they ensure that they are helping consumers eat more sustainably, rather than simply contributing to unsustainable practices?

How can manufacturers guard against sourcing unsustainable soy?

It is vital for manufacturers sourcing soy to know their supply chain. According to Susanne Fromwald, general secretary of the organisation Donau Soja, which promotes alternative protein sources in Europe, country-of-origin labelling isn’t enough, as origin alone doesn’t provide enough information about quality and sustainable production. Manufacturers should, she told FoodNavigator, request information from suppliers.

A more secure way of knowing one’s soy is sustainable is through certification schemes. Certification schemes define sustainability in different ways, warned Fromwald, so manufacturers must take care with who they use, and ensure that they use those that are ‘widely and independently recognised.’

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Soy is linked to deforestation. It is also a key source of alternative protein. Image Source: Getty Images/luoman

Traceability, suggested Luiza Bruscato, global executive director of the Round Table on Responsible Soy Association (RTRS), is key.

The soy supply chain and soy sector have “been steadily developing and putting in place many technological, monitoring and traceability solutions, platforms and procedures towards providing and growing in supply chain transparency,” she told FoodNavigator.

In order to be fully traceable, soy would need to be identity preserved (IP), meaning it would be traceable throughout its entire supply chain, from the moment it grows to its final use as an ingredient.

Undertaking lifecycle assessments (LCAs) is also an important part of soy sustainability, Donau Soja’s Fromwald suggested. Databases such as GFLI or Agrifootprint are used by the agri-food industry to provide an overview of soybeans from different origins.

The RTRS also has its own certification scheme, carried out by nine independent certification bodies, which ensures that certified soy is not linked to either deforestation or the conversion of natural land into agricultural land, as well as that it is produced under responsible labour conditions, good agricultural practices and ‘environmental responsibility.’

Donau Soja’s​ is similar. “At Donau Soja, we apply a comprehensive definition that includes deforestation- and conversion-free cultivation, non-GM, low Greenhouse-Gas Emissions, traceability, protection of biodiversity and protection of human and labour rights,” Fromwald told us.

Case Study: Better Nature Tempeh

The company Better Nature produces tempeh, a traditional Indonesian food usually made with fermented soybeans.

The company sources its soybeans from Canada. “The country is known for ensuring high standards regarding anti-deforestation practices, and farmers are audited on sustainability and labour,” Christopher Kong, Better Nature Tempeh’s co-founder and CEO, told FoodNavigator.

“We only source soybeans from areas not at risk of deforestation, such as Canada, and farmers are audited annually by government agencies on the matter.”

It ensures that its soybeans are traceable, according to Kong. Every bag of soybeans has a lot code which is assigned to a production batch, meaning the tempeh can be traced back to the soybeans used to make it.

Kong is confident that Better Nature’s Canada-sourced soybeans will be compliant with the EUDR. The company is using authorities such as Campden BRI, a food consultancy, to evaluate this before the regulation comes into force.

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Temeph is based on soy. Image Source: Getty Images/alvarez

How can companies conform to the EUDR?

The EUDR requires traceability for the commodities it covers, so in order to conform to it, companies which source soy must be able to trace this soy back to its origin. Companies will even need the geolocation data of where their soy was sourced. According to Donau Soja’s Fromwald, implementing certification schemes aligned with the EUDR is an important part of this.

The RTRS’s Bruscato agreed. “Supply chain actors can utilise certification schemes to complete risk assessment, provided the certification includes the necessary information for regulatory compliance,” she told us.

However, both organisations stressed that certifications are not always enough. Operators and traders must perform due diligence, Bruscato suggested. It is also important companies keep in regular contact with their suppliers, Fromwald added, ensuring that they have the traceability data when they can get it.

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Companies must have deep knowledge of their supply chain, Fromwald suggested. Image Source: Getty Images/Brasil2

“We recommend manufacturers assess which soy raw materials are in their supply chains and engage with their suppliers. Key questions include: What risk mitigation measures have they implemented? What IT and traceability systems are in place? By doing so, manufacturers can ensure they are not only compliant with regulations but also meeting higher sustainability standards,” she said.

Different manufacturers need to undertake different levels of due diligence, RTRS’s Bruscato suggested. If the manufacturer is the first economic operator in an area, they will need to submit a due diligence statement themselves to the national competent authorities. If they’re further down the value chain, they can refer to due diligence carried out earlier on in the process. Nevertheless, they remain legally responsible for any regulatory breaches.

How prevalent is sustainable soy?

Sustainable soy, according to RTRS’s Bruscato, is growing as a proportion of the market, yet is still significantly less used than non-sustainable soy.

According to the European Soy Monitor​, consumption of soy that complies to The European Feed Manufacturers’ Federation (FEFAC) soy sourcing guidelines in Europe in 2021 was 40%, a slight decline from 2020 (44%) which had increased from 2019 (42%). The FEFAC guidelines act as a tool for the benchmarking of existing certifications, meaning certifications have to meet their requirements to be considered legitimate. 

What are the limits of the EUDR when it comes to sustainability?

The EUDR, suggested Donau Soja’s Fromwald, is limited in its aims. By focusing solely on deforestation, she suggested, regulators ignore other ways of creating agricultural land that can have a detrimental impact on the environment. For example, important grasslands and shrublands are not addressed by the regulation.

In terms of a geographical example, the Cerrado in Brazil – the world’s most biodiverse savannah, according to the World Wildlife Fund (WWF)​ home to 5% of the world’s animals and plants – is not protected by the EUDR. Such a land can still be cleared to make way for agricultural land.

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Brazil’s Cerrado contains 5% of the world’s animals and plants, and is the world’s most biodiverse savannah. The EUDR does not cover it. Image Source: Getty Images/FG Trade

“Since the Amazon Soy Moratorium was implemented with the goal of preventing deforestation of the rainforest for soy cultivation, there has been a significant increase in converting the Cerrado into agricultural land. This shift highlights that focusing solely on deforestation isn’t enough — land conversion also leads to the destruction of biodiversity, increases greenhouse gas emissions, and displaces indigenous peoples.”

Therefore, Donau Soja’s certification is stricter than the EUDR, with a cut-off date for 2008 – rather than 2020 – in regards to the latest that soy can be linked to deforestation. Furthermore, like the RTRS’s certification, it covers land conversion as well as deforestation.

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