Deforestation Policy

Our Commitment

TFSL is committed to the objective to ensure that all physical shipments of soy to the UK are deforestation and conversion free with a cut-off date of January 2020. As part of our Deforestation and Conversion Free (DCF) sourcing, direct soy purchases (e.g. Soy sauce) and indirect soy used in animal feed in our protein and Dairy ingredients must be sustainably sourced as set out below. This is part of our commitment to zero deforestation (Legal and illegal) by the end of 2025. The definitions of deforestation and conversion covered by this policy are taken from the Accountability Framework Initiative must be used https://accountability-framework.org/


Policy applies to

This policy applies to all purchases of soy or materials that contain soy as a declared ingredient or embedded within an ingredient. Direct purchases are soy or soy components and products such as soy, oil and lecithin.

Indirect purchases are soy or soy components as an ingredient in purchased goods and embedded in the feedstocks used in the supply chain of meat/dairy ingredients.

The policy also applies to purchases of paper-based packaging materials.


Departmental Accountability

Purchasing, Development, Commercial and Technical.


Policy background, Legislation

Deforestation and conversion free legal requirement for 2025, UK legislation is under development (Forest Risk Commodity Regulation). EU Deforestation Regulations (EUDR) require DFF for commodities placed on the market from 31st December 2024.

We are a Signatory to the UK Soy manifesto aligned to the French Soy manifesto and other initiatives across Europe. These policies form part of our ESG commitments in supporting the UN SDGs 3 good health and wellbeing, 12 responsible consumption, 13 climate action, L14 Life on Land.


TFSL are principally a small indirect user and as such are just a small voice. We will support Deforestation and conversion free initiatives by adding our voice to industry led mass market changes, a collective support to government, finance, civil society and other stake holders demanding change. Wherever possible, TFSL also support dietary changes to plant-based foods though it’s development teams and associated engagement with customers.


Soy reporting

Raw materials implicated include egg, meat (chicken, Pork), dairy (liquid, cheese), soy (sauce and edamame beans) – we will be mindful of any additional ingredients implicated when reviewing purchases and reporting data.

We will report annually (calendar) the amount of Soy purchased directly and indirectly and the progress made on our action plans. This will be via the 3-keel web site and on our website.


Supplier Expectations

  1. PAPER

We are committed to working with our suppliers to avoid deforestation and land conversion for paper and board packaging. All paper and board packaging must be from suppliers certified by the Forest Stewardship Council (FSC) or the Programme for the Endorsement of Forest Certification (PEFC).

  1. SOY

Contract paperwork will include the following requirements:

  1. Refer to DCF requirements and commitment and to comply by 2025
  2. that they should ask their direct suppliers to adopt and cascade this commitment.
  3. Integrate UK soy manifesto (or equivalent) into their purchasing contracts
  4. Publicly disclose progress
  5. Encourage harmonised monitoring, verification and reporting

TFSL will ask for an annual report on Soy usage and an update on their transition plans covering:

  1. Records detailing Country of origin sourcing (including sub-national where available) and to categorise these as low/med/high risk in the context of deforestation and land conversion.
  2. Traceability/chain of custody with appropriate evidence,
  3. Options the supplier considered for replacing Soy.
  4. Non-conformances identified with the supply chain and the DFCF claims
  5. Certification schemes – see below


Accreditation of certification schemes

  • The Round Table on Responsible Soya (RTRS)
  • Cefetra – The Certified Responsible Soya (CRS) standard
  • ADM – The Responsible Soybean Standard
  • ProTerra
  • ISCC (International Sustainability & Carbon Certification)
  • Cargill Triple S
  • Donau Soja/Europe Soya
    1. Audits/validation and verification processes
    2. Soy footprint


Supporting documentation

  1. TFSL Contract paperwork, Terms and Conditions. Owner – Purchasing dept
  2. Sedex Links to suppliers. Owner – Purchasing dept
  3. Annual report on Soy used – direct and indirect. Owner – Purchasing dept
  4. Annual report on transition plans. Owner – purchasing dept.


TFSL Soy Action plan

Q1 2024Submit  3 keel reportingComplete
Q3 2024sign up to Soy ManifestoComplete
Q3 2024write up TFSL policy, circulate and agree.Complete
Q4 2024Finalise policy. Add policy requirements to contract paperwork. Circulate to supply base.Complete
H1 2025Request supplier reports on Soy and review.Complete
H1 2026Revie format for supplier data capture to improve quality of data in supplier replies 
Dec 2025Soy (direct/embedded) to be physically segregated or alternative equivalent evidence to demonstrate soy is physically verified as deforestation and conversion free 


Appendix – Soy certification

Direct Monitoring

Suppliers who can pinpoint sourcing regions may prove their soy is deforestation-free if it originates from areas protected by reliable initiatives like The Amazon Soy Moratorium. Companies purchasing from traders who have signed and comply with the moratorium, as verified by independent audits, can be reasonably confident that the soy they receive from Amazonian sources is not linked to deforestation. We will keep under review other initiatives that can provide similarly credible and reliable verification of deforestation-free status and update our policy accordingly, for example the emerging deforestation free national standard for soy in Argentina (VISeC)

Certification Standards

There are several certification standards associated with responsible soy production. TFSL accepts any schemes benchmarked by ITC (International Trade Centre) against the FEFAC Soy Sourcing Guidelines (2021) with criterion 34 now being mandatory (which covers the conversion of natural vegetation with fixed cut-off date of 2020).

https://fefac.eu/newsroom/news/fefac-soy-sourcing-guidelines-2023-update-includes-conversion-free-soy-as-essential-criterion/

Chain of Custody Supply Chain Model

There are five supply chain certification models supporting the production of certified soy.

  1. Segregated (SG)A supply chain model that ensures certified soymeal is kept segregated from non-certified sources through each stage of the supply chain.
  2. Identity Preservation (IP)
    In an IP model, certified material from a single source is kept separate from all other material throughout the supply chain, allowing maximum traceability from production to end use. This also results in separate documentation for each batch of single-source certified product from other certified and non-certified product
  3. Mass Balance (MB)
    Soy from one or more certified facilities/sites may be mixed (transport/Storage) with sources of non-certified soy. An accounting system ensures the volume of certified soy corresponds to the total volume of soy delivered by certified farms.
  4. Area Mass Balance (AMB)This combines Mass Balance and the Book & Claim system. The certificates are bought from certified farms from the region in which the delivery of physical material by a mass balance model.
  5. Book & Claim (credits)
    A supply chain model that enables the trade of Book & Claim credits through an online trading platform. The certificates are separated from the physical material.
    Claim is not tied to the physical soy volumes, but instead is traded on a separate online market. Claim is not tied to the physical soy volumes, but instead is traded on a separate online market.

Only Segregated (SG) and IP supply chain model can demonstrate deforestation and conversion free. The other mechanisms are only permitted as transition plans to physically verified DFC free soy by Dec 2025.

Troy Foods (Salads) Ltd UK Soy Manifesto Progress Report 2025 for reporting year 2024


Introduction

We are a medium sized family business and produce a range of chilled salads, mayonnaises and dressings supplied into UK retailers, food service partners and other Food manufacturers.   

The mass production of soy causes environmental and social issues from the deforestation or conversion of land to produce Soya, and we are committed to playing our part in preventing the erosion of this Biome. We are working with the UK Soy Manifesto, our customers and suppliers to ensure all soy entering our supply chains will be deforestation and conversion free.

We are recent signatories to the UK Soy Manifesto; our policy and action plans can be found on our Web site: https://troyfoods.co.uk/policies/

Our analysis includes all our manufactured products supplied into retail, Food Service and other food manufacturers. Nearly all the soy within our footprint is from the use of soy as an ingredient in the animal feed used in the production of pork, poultry, eggs and diary ingredients


2025 Report Headlines

This is our first UK Soy Manifesto compliance report, it is fair to say that the landscape is challenging, and the availability of information limited.
All our suppliers were contacted however not all responded with sufficient detail.
Our analysis indicates that we only used a small amount of indirect Soy in 2024, amounting to approximately 588t. Indications are that some of this soy came from ADM, Cofco and ABN. Certification and traceability repsponses point to the use of RTRS credits, Proterra (IP or chain of custody); countries of origin included North and South America and Europe.
Methodology and data sources for determining our soy usage was 3Keel and the RTRS calculator.


Our progress towards sustainable soy

Policy written in 2024 and Issued to all suppliers in Q4/2024.
Traceability challenge and a request for information was sent to all suppliers in Q1 2025.
We have included in our purchasing contracts the requirement for relevant suppliers to comply with the UK Soy manifesto expectations.
This is clearly an iterative process and our supplier request in 2026 will be developed to provide better responses providing improved data quality and supply chain transparency.