This is an announcement to inform RSPO Members regarding an update to the Trace Function in prisma

RSPO is pleased to announce that prisma has been updated with an interim process that allows for the Trace function to be extended to non-members of the RSPO by application for a prisma Registration ID. This interim process addresses RSPO Members’ concerns regarding the limitation of the Trace function to RSPO Members only in the current system build of prisma.

RSPO acknowledges that Tracing to non-members was available in the previous RSPO IT platform, PalmTrace, and recognises that Tracing to non-members has developed into an established business and industry practice since 2020. 

RSPO also acknowledges that the current Supply Chain Certification (SCC) Standard 2020 is unclear on the scope of the Trace function, specifically, whether it is limited to RSPO Members only or also permitted for non-RSPO members. Clarity is required to avoid any interpretation risk and compliance issues during SCCS audits and the scope of the Trace function shall be addressed through the ongoing revision of the SCC Standard. This interim process is designed to provide RSPO Members who have been Tracing to non-members with an immediate option to continue with such business practices, supported by a data format that allows for structured monitoring and trend analysis.

The general steps of the interim process are detailed below. The interim process includes a rapid due diligence check to be conducted by RSPO, because non-members are beyond the jurisdiction of RSPO. There are potential legal, reputational, fraudulent claims or other significant risks to consider when Tracing to non-members, to which RSPO and/or RSPO Members may be liable for, to be assessed at this step.

Approval for a prisma Registration ID is granted on a case-by-case basis based on justifications submitted for each application. 

Steps to apply for a prisma Registration ID:

Step 1: Complete and submit the prisma Registration ID application form* here. The application can be initiated by the RSPO Member (seller) or the non-member (buyer).

  1. If initiated by an RSPO Member, the application form is completed by the RSPO member on behalf of the non-member.
  2. If the application is to be initiated by the non-member, the RSPO Member who sells to that non-member should forward the application form link to the non-member.

Step 2: RSPO checks applications for completeness; then issues an application reference number for complete submissions.

Step 3: RSPO assesses applications for approval and conducts rapid due diligence checks for each application. RSPO aims to respond to applicants within five (5) working days on the outcome of their application. 

Step 4: If an application is successful, a prisma Registration ID will be created in prisma for the non–member. Both parties will receive a formal confirmation letter via email. Note: a prisma Registration ID does not grant access to prisma for non-members of the RSPO; access to prisma remains strictly only for RSPO Members.

Step 5: RSPO Member(s) may begin to use the Trace function for Tracing to the non-member via its prisma Registration ID.

Step 5: If an application is not successful, RSPO will inform the applicant on the status and rationale for decision. If required, RSPO will assist the applicant for re-submission.

Guidance for the prisma Registration ID Application Form

The details required for the prisma Registration ID application form are:

Details requiredGuidelines for submission
Name of RSPO Member applying on behalf of a non-memberAppears only if the application is submitted by an RSPO Member on behalf of a non-member it is selling to. Please use the same name registered under your RSPO membership.  
Membership ID of RSPO Member applying on behalf of a non-memberAppears only if the application is submitted by an RSPO Member on behalf of a non-member it is selling to. The RSPO Membership ID is an 11-digit unique ID in the following format: X-XXXX-XX-XXX-XX
Name of RSPO Member that provided this application form linkAppears only if the application is submitted by a non-member by the request of an RSPO Member that it sources from. Please use the same name registered by the RSPO Member for its RSPO membership.
Membership ID  of RSPO Member that provided this application form linkAppears only if the application is submitted by a non-member at the request of an RSPO Member that it sources from. The RSPO Membership ID is an 11-digit unique ID in the following format: X-XXXX-XX-XXX-XX
Name of Legal EntityName of the non-member’s business, organisation, association, etc. as legally registered or recognised. This should be the name associated with the Registration Number (see below).
Registration NumberBusiness Registration Number or equivalent business ID. Other permissible registration numbers include Tax ID, National Organisation ID, or any equivalent identification to denote that the non-member is legally recognised in the country(ies) of its jurisdiction.
Address of Legal EntityIf the non-member operates multiple sites or facilities under the same Legal Entity, the non-member’s headquarters or main operating site/facility should be used as the address.
Zipcode Zipcode or postcode of the Legal Entity’s address
Country where Legal Entity is registeredCountry of the Legal Entity’s address
JustificationWritten explanation to justify why Trace is required for the non-member. Each application will be considered on a case-by-case basis on the merits of the justification, particularly in cases where the non-member is in a position to apply for RSPO membership. General flexibility will be applied as part of the approval process, as RSPO does not wish to disrupt the existing commercial business practices of RSPO Members, unless significant and material risks are identified. 
Non-expiring prisma Registration IDs may be granted for applications where the non-member is unable to become an RSPO Member for legal, corporate structure, entity structure or any other justifiable circumstances.Expiring prisma Registration IDs (with a fixed expiry date) may be granted for applications where the non-member is able to become an RSPO Member but has justifiable reasons or circumstances constraining the non-member from applying for RSPO membership.Applications for a prisma Registration ID may be rejected if significant legal, reputational, fraud or any other relevant risk to RSPO or RSPO Members is identified through the rapid due diligence check. Rejected applications may be re-submitted for consideration, e.g., in cases where the RSPO Member is able to confirm in writing that it will bear any legal liability risk incurred by its Tracing to the specific non-member, as well as any subsequent actions/operations on its Traced volumes by the non-member or in the non-member’s subsequent non-certified supply chain.
Supporting DocumentsRelevant document(s) to support and/or justify the application, if applicable. If multiple documents are submitted, please consolidate the documents into a single zipped file for upload.
Other RemarksAny other remarks or information to support and/or justify the application.

Procedural notes of the prisma Registration ID interim process:

  • A Trace function is carried out by RSPO Certified refineries and RSPO-licensed traders when RSPO Certified products are sold as RSPO Certified in the supply chain beyond the refinery, unless an optional post-refinery Announcement has been carried out for the sale. Note: a prisma system update to enable optional post-refinery Announcements is being finalised for release in Q3 2025. 
  • Tracing to non-members is governed by the same requirements that apply for Tracing to RSPO Members, as set out in Clause 5.7.2 (e) of the RSPO Supply Chain Certification Standard 2020. 
  • Tracing will generate a Trace document with a unique traceability number. 
  • Traced volumes sold by the RSPO Member shall be traced within three (3) months after physical delivery to the non-member.
  • Traced volumes sold by the RSPO Member can be claimed to be sourced as RSPO Certified by the non-member. But such Traced volumes, or any products processed or manufactured from such Traced volumes, cannot be sold onwards as RSPO Certified or claimed as such by the non-member. A disclaimer noting this is published in all Trace documents generated within prisma. 
  • This interim process shall remain in force and effective until the RSPO Supply Chain Certification Standard is revised for clarity on this business practice, and the revised Standard has been endorsed by the RSPO Board of Governors and becomes effective for implementation.

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