PROVE IT OR ELSE! Traceability – regulation and consumer demands on your data management

PROVE IT OR ELSE!
Traceability - regulation and consumer
demands on your data management
WHITE PAPER
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INTRODUCTION
The recent Trade Facilitation and Trade Enforcement
Act, for example, has tightened import controls into the
US allowing customs to detain and seize any product
thought to have been produced with child labor. The
legislation has already been used to detain a shipment
entering the US. In order to release a shipment, the
owner is required to prove that the custom’s suspicions
are incorrect. This is a good example of how a myriad of
new rules and regulations are forcing commodity firms
to pay much closer attention to traceability. Increas-
ingly, the onus is on the owner of the commodity or
product to prove compliance with standards for envi-
ronment, labor and sustainability etc.
What is traceability? The widely accepted definition
from the International Organization for Standards (ISO)
isasfollows,“Theabilitytoidentifyandtracethehistory,
distribution, location and application of products, parts
and materials, to ensure the reliability of sustainability
claims, in the areas of human rights, labour (including
health & safety), the environment and anti-corruption.”
This is a fairly broad definition, but it does not include
the additional driver of protecting brand value. Selling
food products or commodities that are substandard,
defective, or that do not live up to certain environmen-
tal claims, can have a massively detrimental impact on
brand value. Nestle is a good example of how brands
can be tarnished after being targeted by a very vocal
Greenpeace campaign regarding its use of palm oil to
make Kit Kat bars procured from producers deemed to
be destroying rainforests and habitats.
© Commodity Technology Advisory LLC, 2017, All Rights Reserved.
The commodity business has always been fraught with complexity, but under increasing scru-
tiny from legislators, regulators, consumers, and therefore auditors, that complexity is growing
steadily and inexorably. One significant challenge in which complexity is increasing, is the need
to track commodities, consumables, and fuels, from source to market. It is no longer the case
that buyers can simply pick the best price in choosing a supplier as concerns over issues like
food safety, as well as an increasingly savvy consumer that is concerned over abusive labor
practices, workers rights, and environmental issues, for example, are increasing the traceability
complexity across almost all supply chains.

Food safety is one issue driving the traceability chal-
lenge. As trade in agri-food and commodities has and
continues to increase, it has led to changes in the
global production network with increasing fragmenta-
tion and complexity across multiple enterprises with
global reach. Implementation of verifiable safety and
quality compliance programs allows these businesses
to better manage operational risks and allows faster
reaction to emergencies, recalls, and withdrawals. It
also allows for better brand protection by streamlining
withdrawals of substandard products.
Meanwhile, an increasingly savvy and environmental-
ly aware consumer is driving the development of the
branding and labeling of products as sustainable, envi-
ronmentally-friendly, produced by workers with proper
working conditions and rights, and so on. The ability
to prove these brand claims goes hand-in-hand with
the ability to attract a premium price for the goods.
Table 1 shows a number of examples of different envi-
ronmental and social traceability drivers as they relate
to different commodities.
Commodity Drivers
Beef - Preventing deforestation
- Protecting land rights for indigenous peoples
- Promoting animal welfare
Biofuels - Working to protect human and labour rights through the
supply chain
- Working to preserve the functioning of local economies
and small-scale producers
- Managing the impacts of new feedstock farming and work-
ing to protect local food security and prevent deforestation
Cocoa - Labour rights in terms of working conditions
- Human rights – following the law and respecting children’s
rights
- Sustainable livelihoods for farmers
Cotton - Environmental impacts – reduction of chemicals and water
use as well as carbon footprint
- Social impacts – workers rights, fair compensation for
smaller farmers
- Labour and children’s rights
Palm Oil - Sustainable farming without deforestation
- Prevent destruction of habitats and management of im-
pacts of farming
- Climate change issues with deforestation and water pol-
lution issues
- Respect for land rights of indigenous people and provide
incomes to small farmers
Sugar - Working conditions and prevention of child labour
- Management of environmental impacts and guarantee lo-
cal food security
Timber - Environmental – deforestation, water quality and CO2
- Prevent illegal harvesting, promote sustainable harvest
levels with replanting
- Avoid destruction of biodiversity and habitats
- Protect indigenous land rights and prevent land ownership
conflicts
PROVE IT OR ELSE! A ComTechAdvisory Whitepaper
THE ISSUES DRIVING TRACEABILITY
There are really two major groups of drivers for traceability at work in today’s commodity mar-
kets,
/ Food safety and general safety practices,
/ Social and environmental concerns.
Table 1: Traceability Drivers

TRACEABILITY IS EVERYWHERE
While it is logical to associate traceability issues and processes with food supply, traceability is
rapidly becoming an issue for almost all commodities to some degree. For example, is green
power, for which the consumer may pay a hefty premium truly generated in an environmentally
friendly way? Traceability now impacts areas like jet fuels, refined products, timber, and many
other commodities outside of food for a variety of reasons. New regulations are emerging on a
consistent basis that continue to create the need to properly track and account for commodities
and products through the supply chain.
Implementing proper traceability is an expense and
complexity for all participants involved in the supply
chain. Investment is required in technology and pro-
cesses aimed at tracking goods along the supply
chain. Despite that, there is often a premium or penal-
ty aspect to pricing associated with commodities and
products that can be shown to have been produced in
a certain way whether that is environmentally friendly,
socially acceptable, or some other criteria that con-
sumer’s value. Furthermore, there is a brand aspect
to the ability to conduct proper traceability that is ex-
tremely valuable.
According to the United Nations1
, there are three main
approaches to tracking sustainability claims and each
involves different methods of tracking a claim and as-
suring at each point in the supply chain (Table 2). The
UN also points out that further investment and work
is required in the area of traceability to improve it both
generally and for specific commodities.
Each of the three approaches involves some degree
of cost and complexity, and the more rigorous the ap-
proach, the more costly, and complex it will be.
As traceability is mandated or required by more and
more consumer groups, industry associations, regu-
lators, and governments, there are several other fac-
tors to consider. The commodities business is found-
ed upon trust and verification such that, for example,
the physical metals at a warehouse actually exist and
ownership is clear. Without this trust and verify mech-
anism, commodity finance would suffer. There would
be no confidence in trades and banks would have
issues financing companies involved in the supply
chain. In some commodities, repo financing where the
bank takes ownership of the commodity for a period
of time releasing cash to the owner with a provision to
sell the commodity back at a certain point in time, for
example, is a key aspect of this. Traceability then can
also be seen to have other uses and benefits.
1. A Guide to Traceability, United Nations, 2014

Method Description Detail Example
Product Segregation Certified materials and products are
physically separated from non-certified
materials and products at each step in the
supply chain.
Bulk Commodities – Certified and
non-certified materials are separated
but mixing from different producers of
certified materials is allowed. All pro-
ducers have to comply with certification
standards.
Identity Preservation – Certified and
non-certified products cannot be mixed
and certified products may not be mixed
either. This affords traceability to a specif-
ic producer, farm, or forest
Bananas – Fairtrade bananas have
achieved the ability to trace back to a
specific producer.
Mass Balance Certified and non-certified products may
be mixed however, the exact volumes of
certified materials are tracked such that
an equivalent volume of the product can
be sold as certified
Commonly used for products where seg-
regation is difficult such as Coffee, Cocoa,
Sugar, and Tea.
Timber – The complex nature of the
production process at paper mills makes
segregation almost impossible.
Cocoa – Complex supply chain means
that segregation is very expensive.
Book and Claim A company can obtain sustainability
certificates for the volume of certified
materials put into the system. The certif-
icates can be bought and sold meaning
that sustainability claims can be made via
the existence of a certificate even though
the actual product may not have been
certified.
In this system, certified and non-certi-
fied products are mixed and there is no
requirement to track them. Rather, the
certificates issued and traded are tracked.
CO2 Emissions and Green Power – the
trading of certificates allows retailers to of-
fer green power at a premium despite not
knowing if the electrons it supplies were
certified or not so long as it has purchased
the certificates needed to do so.
The importance of traceability has now grown to the
point that it is essential in many commodities and
products as,
/ Many shippers and/or important consumers now
have their own requirements, standards and man-
dates including for example, tire manufacturers,
/ In areas like biomass and green energy, subsidies
are only available where adherence to environmen-
tal standards can be proven,
/ Industry associations, consumer bodies and in-
tra-government organizations are developing an ar-
ray of standards and requirements,
/ Brand value protection demands it,
/ Consumers demand it and are willing to pay a pre-
mium.
Traceability is rapidly becoming a key requirement
and constraint in many industries where it is seen as
an important operational risk item that needs to be
effectively managed.
Table 2

TRACEABILITY AND CTRM/COMMODITY
MANAGEMENT SOFTWARE
In order to fully support traceability requirements, Commodity Management or CTRM software,
has to exhibit several key characteristics. These include,
/ Overall support for the supply chain for a commodity
and/or products from point of origin to point of con-
sumption. This will include a good deal of detailed
functionality from logistics through inventory man-
agement, assay or chemical analysis functionality,
and much more,
/ Ideally, the solution will also need to support multi-
ple units of measure and multiple currencies with a
seamless ability to move from one to another in the
supply chain. An example of this might be in terms of
procuring or producing volumes of a commodity but
selling products on a mass balance basis. Another
example might be where the calorific value of stock
needs to be tracked in order to quantify the volume
required to be procured and maintained,
/ It needs to have the ability to track bulk and/or pack-
aged commodities at granular levels throughout the
supply chain such as cotton bales, lots, shipments,
and so on. Furthermore, it needs to be able to track,
merge and split activities throughout the supply
chain where different lots or quantities of a commod-
ity are split or merged either in packaged form or
bulk,
/ The solution must support user definable work-flows
and track actions along the process so that transac-
tions are auditable and activities traceable from start
to finish,
/ This also requires detailed logistics tracking of items
like trucks, containers, bails, packages and so on,
/ It must also be able to track green certificates, cal-
culate and track carbon footprints and support com-
munication with registry’s to allow buyers to claim
subsidies, incentives and defend claims made re-
garding the nature of commodities or goods sold.
The ability to perform these activities is a non-trivial
exercise but brings a number of other benefits in that
supply chains can be optimized for cost and times-
cales as well as traceability. The issue in providing all
of this functionality is almost certainly in being able
to set up the solution for different commodities and
products. Many solutions on the market are designed
with a specific commodity and industry segment in
mind and extending functionality across commodi-
ties then requires significant modification and/or en-
hancement. In order to provide a viable and complete

For example, G10 Commodity Manager can be used
to track biomass from forest to generation through
the entire supply chain and any certificates generated
or traded along the way. This allows the generator to
prove the power it is generating is green as well as
to calculate and claim any subsidies it is entitled to.
In the area of cocoa, it easily tracks cocoa through a
complex supply chain, allowing tracing of beans back
to their source. The same with palm oil and rubber.
The underlying architecture caters for extensible data
collection, fluid business processes and workflows.
The traceability module handles bulk, lots, units and
all the splitting, merging, blending, reweighing, reclas-
sifying, certifying and revaluing that happens in the
real world. It’s inherently flexible - multi-unit of mea-
sure/conversion solution that allows new commod-
ities/products to be defined to the system without
enhancement or modification. Similarly, for each com-
modity, the important physical attributes can be add-
ed, utilized and valued in the solution without coding.
It was one of the first solutions available commercially
to be able to track coffee and cotton at the individual
package level, for example.
solution for the purpose of traceability, it must also be
relatively easy to set up different commodities/prod-
ucts and specify the particular physical attributes that
influence pricing and settlement.
Increasingly, users are demanding that the CM/CTRM
solution aids them in supply chain optimization, which
includes traceability. The ability to identify slower, less
reliable or more costly transporters, for example, is
one area where optimizations can be made. Addition-
ally, all three approaches described above to trace-
ability, must be supported.
Generation 10 (Gen10)
Gen10 is a company that has had traceability and supply chain optimization firmly in mind since
its inception in 2000. It provides a number of solutions on its cloud-based Commodity Manager
platform, from specific stand-alone products like its G10 Supply Chain Map to its comprehensive
CTRM suite.
Green Power Traceability

The G10 Supply Chain Map product provides users
with a due diligence platform for auditing their sup-
pliers, capturing key metrics at ground-level on sus-
tainability, environmental and socio-economic factors,
while at the same time it can capture financial, quality
and marketing data. It goes on to manage annual re-
view and renewal processes, plotting trends graphical-
ly and triggering business alarms. It can be implement-
ed as a stand-alone service with APIs that complement
an existing CTRM/IT ecosystem.
The solution captures all of the detail and information
required about suppliers and customers using an ex-
tensible supply chain survey tool. It combines site vis-
its and market intelligence data about purchases and
sales to the lowest level such that traceability (using
any of the three approaches defined above; segrega-
tion, mass balance, book and claim) can be effectively
managed and supply chains optimized. To bring all the
data and metrics together, there is an easily consumed
set of graphical tools to map the supply chain and per-
form interactive analytics, visualizations, and reports to
make this task even simpler.
One of the things about the platform is how it can com-
bine all of these aspects with the rest of the business
process to give that holistic approach to visibility and
decision-making, rather than siloed sustainability, fi-
nancial, and operational data.
And it’s all Cloud-based with Off-line capability that si-
multaneously gives instant global deployment, reach
and access while catering for those hard-to-reach plac-
es at origin where internet connectivity can be limited
or off-grid altogether.
G10 Supply Chain Map

SUMMARY
Traceability is now a critical requirement both from a
brand protection perspective as well as a legal or in-
dustry standard point of view in many commodity
supply chains. To meet these requirements demands
a different approach to commodity trading, tracking,
and management than that offered by many CTRM
solutions or indeed, CM, or ERP solutions in the mar-
ket. Traceability needs to be at the core of business
processes, culture and the systems employed in the
business. The G10 Commodity Manager platform and
targeted products like its G10 Supply Chain Map, are
one of the few solutions commercially available that
provides both the appropriate granularity and the tools
required to truly manage traceability and supply chains
for the vast majority of commodities.
A quick visit to any corporate presence on the web for
any company engaged at any step in commodity sup-
ply chains particularly in food-related areas, is already
replete with mission statements and marketing speak
regarding issues like sustainability, social responsibili-
ty, de-forestation and climate change. However, words,
no matter how many times spoken or written, will not
create nor sustain a reputable brand. Only actions
and the actual buyer experience can do that. When
it comes to protecting and promoting that brand and
being responsive to new regulations and/or quality is-
sues, you simply have to prove it, or else!

ABOUT GENERATION10
Generation 10 is a company providing data management ser-
vices and solutions throughout the commodity supply chain
with specialist domain expertise in softs/ags. With core com-
petencies in origination, through logistics supply chain track-
ing and optimization, to cost control and risk management,
they serve a diverse international client-base from producers,
brokers, traders, importers and processors to banks, insur-
ance and government institutions.
Solutions come pre-configured for a range of commodities,
enabling fast implementations on a web-based, device-friend-
ly, modular platform that is feature-rich, easy to use and highly
configurable to individual user preferences.
Their flagship CTRM platform, Commodity Manager, is the
only offering in the market to offer end-to-end transaction life-
cycle processing, integrated CRM, origination, supply chain
optimisation, embedded analytics, risk management and
compliance modules on a single, modern, affordable and scal-
able platform.
Available as a hosted Software-as-a-Service, or on-premise
solution.
generation10.net
info@generation10.net

ABOUT
Commodity
Technology
Advisory
LLC
Commodity Technology Advisory is the leading analyst organization covering the ETRM and
CTRM markets. We provide the invaluable insights into the issues and trends affecting the
users and providers of the technologies that are crucial for success in the constantly evolving
global commodities markets.
Patrick Reames and Gary Vasey head our team, whose combined 60-plus years in the energy
and commodities markets, provides depth of understanding of the market and its issues that is
unmatched and unrivaled by any analyst group.
For more information, please visit:
www.comtechadvisory.com
ComTech Advisory also hosts the CTRMCenter, your online portal with news and views about
commodity markets and technology as well as a comprehensive online directory of software
and services providers.
Please visit the CTRMCenter at:
www.ctrmcenter.com
19901 Southwest Freeway
Sugar Land TX 77479
+1 281 207 5412
Prague, Czech Republic
+420 775 718 112
ComTechAdvisory.com
Email: info@comtechadvisory.com

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PROVE IT OR ELSE! Traceability – regulation and consumer demands on your data management