Mastering CDP Scoring
ESG/Module 9: Forests performance (CDP Module 8)/Lesson 2 of 3/6 min read

Commodity disclosure for FMCG and agriculture

Lesson 8.2

Key takeaway

For companies in FMCG, food, agriculture, and personal care, the commodity-specific questions are where most of the Forests module scoring sits. CDP asks for volume, origin, traceability, certification, and risk for each priority commodity you handle. The questions repeat the same structure per commodity, so once you can answer well for one, you can answer well for all. This lesson walks through the answer pattern, the data you need to collect, and the engagement programmes that move scores meaningfully.

The commodity-by-commodity structure

For each priority commodity, CDP expects a structured set of disclosures. The same fields repeat across palm oil, soy, timber, cocoa, coffee, rubber, and cattle products.

FieldWhat goes in
DisclosedYes (with detail) or No (with reason)
Forms usedRaw material, intermediate, finished product (e.g., palm fruit, palm oil, palm derivative)
VolumeAnnual procurement in tonnes (or equivalent unit)
OriginCountry of origin breakdown (best case: regional or sub-national)
Traceability levelNone, country, regional, mill, plot
CertificationScheme used, percentage of volume covered
VerificationThird-party verification of certification claims
Deforestation risk assessmentHow you assess; tools used (Trase, Global Forest Watch, sat-monitoring)
EngagementSupplier programmes, certification investments, on-ground projects

The grader looks for completeness. A response that lists only volume and origin caps at Awareness. Adding traceability and certification reaches Management. Adding verification, risk assessment, and engagement reaches Leadership.

How FMCG companies usually approach this

Most FMCG companies have a Sustainable Sourcing function that runs commodity-by-commodity programmes. The CDP disclosure should mirror these programmes.

A typical FMCG response covers 3-5 commodities in detail:

  • Palm oil (and palm derivatives) - high priority due to deforestation history in Indonesia and Malaysia
  • Soy - relevant for animal feed in dairy and meat-containing products
  • Cocoa - chocolate confectionery
  • Paper and packaging - universal
  • Coffee - for coffee, tea, and instant beverage manufacturers

Some FMCG companies also disclose on cattle products (leather, dairy supply chain), rubber (for some specialty products), and timber (for furniture or display materials).

Analogy

Think of commodity disclosure like a school report card. Each commodity is a subject. The score is per subject. You can be strong in one subject and weak in another. CDP averages the depth of disclosure across the commodities you handle. A response that is detailed on palm oil but vague on soy gets a mid-tier overall mark. A response that is detailed on all commodities, even if not perfectly sourced, gets the higher mark.

Worked example: a personal care company on palm oil

Worked example

HomeCo India Ltd (synthetic, personal care, FMCG). Major palm oil derivative user (in soaps, detergents, lotions). Annual palm oil and derivatives consumption: approximately 8,000 tonnes (CPO equivalent).

Year 2 disclosure on palm oil:

  • Forms used: Crude palm oil (CPO) for soap base; palm kernel oil (PKO) for surfactants; palm-based fatty alcohols for emulsifiers; palm-based glycerin.

  • Volume: 8,000 tonnes CPO equivalent annually, broken down by form: 3,500 t CPO, 1,800 t PKO, 1,500 t fatty alcohols, 1,200 t derivatives.

  • Origin: 65 percent Indonesia (primarily North Sumatra and Riau), 25 percent Malaysia (Sabah, Sarawak), 10 percent other (Papua New Guinea, Thailand, Latin America). Origin determined through supplier surveys and RSPO chain-of-custody documentation.

  • Traceability level: 78 percent traceable to mill (mass balance). 32 percent traceable to plantation (segregated supply). 8 percent traceable to plot through direct cooperative relationships.

  • Certification: 100 percent RSPO certified, of which 32 percent Segregated and 68 percent Mass Balance. RSPO certification audited annually by an accredited certification body.

  • Verification: Sub-set verification by SGS (covering 4 mills); cross-checked with Trase open-source supply chain mapping for transparency.

  • Risk assessment: Identified 12 mill-suppliers in our supply chain that score above CDP Forests risk threshold using Trase data; engagement programme initiated with these mills covering 78 percent of volume.

  • Engagement: Direct programmes with 3 cooperative groups in North Sumatra (200 farmers, GPS-mapped plots, smallholder support); funding for FOREVER (independent verification platform) for our top mills; participation in POIG (Palm Oil Innovation Group) and CSPO Sustainable Palm Oil Council India.

This level of disclosure earns Leadership tier on the palm oil commodity. The disclosure has the structural completeness CDP wants: traceability levels distinguished, certification percentages broken out, risk assessment cited, engagement programmes named.

Practitioner notes.

  • The 78 percent mill traceability is realistic. Most palm-using FMCG companies operate in this range.
  • Plot-level traceability is the leading edge; achieving 8 percent is meaningful and signals direction of travel.
  • Naming POIG and Trase as engagement venues is important; the grader recognises both.
  • The cost of this disclosure infrastructure is in the range of USD 200,000-500,000 annually for a company at this volume, but it integrates with EUDR compliance for any EU exports.

Common patterns by commodity

Palm oil

Most globally-scrutinised commodity. RSPO certification is the standard, but RSPO Mass Balance (where certified and uncertified palm are mixed in supply chain) is increasingly seen as insufficient. The leading edge is RSPO Segregated or Identity Preserved supply, plus direct mill engagement.

Soy

Less developed certification ecosystem. RTRS exists but coverage is lower than RSPO. The Soy Moratorium (private agreement on the Brazilian Amazon) covers 95 percent of Brazilian soy from the Amazon biome, but the Cerrado biome (large tropical savannah) remains a deforestation risk hotspot. CDP Forests grading on soy increasingly emphasises Cerrado-specific commitments.

Cocoa and coffee

Cocoa is dominated by West African production with documented deforestation risk in Ghana and Cote d'Ivoire. The Cocoa & Forests Initiative is the major engagement venue. Coffee certification is strong (Rainforest Alliance, Fair Trade), and traceability has improved due to EU regulations and roaster pressure.

Cattle products

Both beef-and-leather and dairy-from-fed-cattle. Brazilian beef is the largest forest-risk source. Engagement is harder than for crop commodities because the supply chain is more fragmented (smallholders, cooperatives, traders, packers).

Paper and timber

The most mature certification ecosystem (FSC, PEFC). Many major paper producers are 100 percent certified. Disclosure is straightforward.

Rubber

Less-developed certification (GPSNR, the Global Platform for Sustainable Natural Rubber, is the emerging scheme). Tyre manufacturers are the largest disclosers. Most other companies have minimal direct rubber exposure.

How to handle low-volume commodities

A common situation: a company has minor exposure to one or two commodities relative to its main commodity programme. For example, a chocolate company with primary exposure to cocoa and minor exposure to palm oil derivatives in confectionery emulsifiers.

CDP allows a "below threshold" approach for genuinely small commodities, but the threshold has to be transparent. A scoring-quality approach:

  • Disclose the commodity at minimum: yes, we use it, here is the volume.
  • Indicate that detailed disclosure is below your materiality threshold.
  • State the threshold (e.g., "commodities below 5 percent of group sourcing spend are summarised but not detailed").
  • Commit to upgrade if the volume grows.

This is a more credible answer than skipping the commodity entirely.

Trase (Transparency for Sustainable Economies) is an open-source supply chain mapping tool for forest-risk commodities. It provides probabilistic traceability from importer to producer region for many countries and commodities. Companies that cannot achieve direct plot-level traceability can use Trase data to provide regional-level traceability with transparency about the methodology. CDP graders recognise Trase as a credible tool. Citing Trase in your disclosure is a Management-tier signal.

Key Takeaways

  1. The commodity questions repeat the same fields (volume, origin, traceability, certification, verification, risk, engagement) for each priority commodity
  2. FMCG and food companies typically disclose on 3-5 commodities; pharmaceuticals and personal care often have hidden palm oil exposure
  3. Mill-level traceability is Management tier; plot-level with GPS or smallholder engagement is Leadership tier
  4. RSPO Segregated supply is preferred over Mass Balance for palm oil; RTRS is less developed than RSPO; cocoa engagement happens through Cocoa & Forests Initiative
  5. Below-threshold commodities should be disclosed minimally with a stated materiality threshold, not skipped

Knowledge Check

Test what you just learned

6 questions ยท check each one as you go

0 of 6 answered

What is the structural answer pattern for each commodity in CDP's Forests module?

Select all that apply

Which commodities does an FMCG personal care company typically need to disclose on?

True or false: RSPO Mass Balance is the highest level of palm oil supply chain traceability.

What does CDP allow for low-volume commodities?

Which tool provides probabilistic supply chain mapping for forest-risk commodities?

Match each commodity to its dominant deforestation risk geography.

Match each item to its pair

Palm oil

Soy

Cocoa

Cattle products

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