ICE CoT

There are three key categories of data uploaded by users which are reviewed and validated by the ICE CoT methodologies:

Farm Plot Data

Provides details related to cocoa and coffee production, including geolocation information;
Tested against ICE CoT’s Farm Plot Data Validation Methodology;
Developed with the support of Meridia using forest mapping data from Space Intelligence along with protected agricultural area information;
Can be uploaded independently of a product consignment, ideally prior to the harvest and physical flow of commodities, but must be uploaded before any traceability information for a product consignment.

Lawful Production and Compliance Risk Data

Provides details of the systems and processes for aggregators and others along supply chains which support compliance with applicable local legislation and the mitigation of risks of non-compliance.

Is reviewed against ICE CoT’s legality and risk review protocols, developed with the support of KPMG Netherlands.
Information is collected through questionnaires, which can be completed independently of a product consignment but must be completed before uploading any traceability information for a product consignment.

Parcel Traceability Data

Provides information regarding each product consignment, linking it back to previously submitted farm plot data.
Includes details of aggregator supply, transport, shipping, warehousing and processing, and is tested against our Parcel Traceability Data Validation Methodology.
Is uploaded when a product consignment is registered to ICE CoT. Certain traceability information and data relating to systems and processes at supply chain control points are collected through data uploads and questionnaires, which can be completed separately but must be completed before uploading any related product consignment information.

ICE CoT supports the submission, storing, testing and sharing of due diligence information required under the EUDR, and helps users to demonstrate that cocoa and coffee and related products are deforestation-free and lawfully produced when entering the EU market.

View the full video

ICE CoT: Keeping EUDR-compliant cocoa and coffee tradeable

The European Union Deforestation Regulation (EUDR) is an initiative aimed at combating deforestation and forest degradation. The regulation introduces supply chain due diligence requirements for certain commodities, including coffee, cocoa, and their related products, whether they are imported into, supplied within, or exported from the EU. The aim of the legislation is to ensure that these products are both deforestation-free and legally produced.

The EUDR places specific obligations upon “operators” who import or process materials into covered products within the EU or export them as well as “traders” supplying covered products within the EU. These requirements are designed to demonstrate covered products entering, circulating within, or leaving the EU market are:

Originated from land that has not been deforested after December 31, 2020.
Produced in accordance with the relevant legislation of the country of production.
Accompanied by a due diligence statement.

The due diligence process involves collecting specific prescribed information, including the precise geolocation of the plots of land where the relevant commodities were produced. For commodities originating from countries or regions not classified as low risk by the European Commission (EC), operators are required to perform additional risk assessments. If necessary, they must also undertake risk mitigation activities to ensure there is no or only a negligible risk of non-compliance with the EUDR.

In addition to these core requirements, the EUDR also mandates specific protocols related to due diligence processes and systems, record keeping, and data transparency. To enforce these regulations, National Competent Authorities (NCAs) of EU Member States are tasked with conducting checks within their territories to verify compliance among operators and traders.

The consequences of non-compliance with the EUDR are severe. Penalties can include fines of up to 4% of a company's total turnover within the EU, confiscation of relevant products, and temporary prohibitions on importing, supplying, or exporting relevant products to, within, or from the EU.

ICE CoT has been designed to help traders and operators comply with the EUDR while supporting continued trade-ability of cocoa and coffee.

ICE CoT requires farm plot geolocation and related data to be uploaded by a user before uploading any traceability information for product consignments originating or derived from these farm plots. The uploaded farm plot data will be tested by ICE CoT against the Farm Plot Data Validation Methodology and test results returned to the user.

ICE CoT currently supports file upload in GeoJSON format, which is also the format currently required by the EU Information System for due diligence statement uploads. Future support for other formats will be decided upon based on user demand.

Required farm plot input data includes:

ProducerCountry - Two letter country code from ISO 3166-1 alpha-2. For example, “CI” for Côte d’Ivoire or “BR” for Brazil. Must match one of the values within the list of supported countries.
Commodity - “Coffee” or “Cocoa”.
CTOFarmerID - A unique identifier for the farmer, assigned by the user. Multiple farm plots may be linked to the same farmer.
CTOPlotID - A unique identifier for the farm plot, assigned by the user. This field should be unique for each given ProducerCountry and Commodity.
DateofMapping - As details of a plot may change over time, this determines which version of the farm plot was current on a particular date.
Geometry - Either a polygon defining the outline/border of the plot or a point indicating a physical location within the farm plot. If a point is specified, the farm plot area must also be specified. Plots over 4ha must be specified as polygons.
Area - The area of the farm plot, in hectares. Where the geometry is a point, Area is required and must be no more than 4ha.

Optional data may also be added including ProducerName, NationalFarmerID, NationalPlotID, AggregatorIDs, DataProvider, and ProductionPlace.

Underlying documentation to evidence the uploaded information is required to be available for inspection and verification.

Farm plot data is not shared with a buyer or with other users except that: Geometry (plot polygon or geolocation point) is always shared with a buyer until due diligence statement creation, after which it is not shared; other farm plot data may be shared with a buyer at the seller’s option.

Farm Plot Data Methodology Tests

Farm plot data is subject to several tests under the Farm Plot Data Validation Methodology, including using forest mapping data from Space Intelligence and Meridia designed tests with protected agricultural area information and basic data consistency and reasonability tests including checks for deforestation and protected area proximity and overlaps. All required data fields must be supplied. Where farm plot data fails any test, that farm plot may not be used as an eligible production plot for any product consignment traceability. Test failures may be challenged by a user if the farm data is believed to be compliant. In in case of upload errors, the data can be corrected and re-uploaded. Some farm plot data tests (e.g. “Farm is extremely large”) have reasonability thresholds which may vary by country.

ICE CoT Farm Plot Data Validation Methodology test methods and thresholds are subject to continuous review and may be updated, removed or added to.

Current tests include:

Mission Reports

Vietnam

Ivory Coast

Basic geometry tests for polygons:

Farm has too few boundary vertices
Farm has self-intersecting boundary segments
Farm plot polygon contains holes
Farm plot polygon is not closed

Deforestation, protected area and plot size tests:

Farm overlaps with deforestation
Farm overlaps with forest
Farm overlaps with protected area
Farm plot is recorded as a geopoint with estimated size greater than 4ha
Geopoint too close to deforestation

Reasonability tests:

Farmer has implausibly high number of farms
Farm plot is distant from farm plots with the same Farmer ID
Farm plot mapping date is far in the past
Farm plot overlaps with other farm plot(s)
Farm plot is duplicated with same Farmer ID
Farm plot is duplicated with different Farmer ID
Farm plot has a very unusual shape
Farm plot boundary has spikes
Farm plot is extremely large
Farm plot is outside of country boundary
Farm plot overlaps built-up area
Farm plot overlaps water body
Farm plot location time-series mismatch
Inconsistent farmer data

View Space Intelligence Methodology

EUDR-compliant supply chains are expected to have in place internal management systems which include documented procedures and processes for aggregators and others within supply chains to ensure compliance with applicable legal and compliance risk mitigation requirements, and to identify and confirm on which farm plots any commodities supplied by aggregators were originally produced.

ICE CoT uses questionnaires to collect and analyse information regarding these systems, procedures and processes as they relate to making sure: (i) the commodities and related products contained in or used to make the product consignment were lawfully produced; (ii) as required, appropriate compliance risk mitigation was exercised; and (iii) each product parcel supplied by an aggregator contains or is made only from commodities produced on some or all the farm plots associated with the product parcel within the provided physical flow traceability data, and no other farm plots.

Two types of questionnaires are used:

the registration questionnaire collects information regarding the list of aggregators and the types of internal management systems for each production country, along with information regarding supply chain communication, grievances and compliance violations; and

the legality and risk questionnaire asks how these systems ensure compliance with the applicable legislation for each specified legality topic in each production country and how remaining risks are mitigated.

Relevant systems and documentation to evidence the answers to the questionnaires must be available and may be inspected and verified.

Only aggregators (and related supply chains) with fully and satisfactorily completed questionnaires are eligible to be identified in the physical flow traceability input data for any product consignment.

Registration Questionnaire

The Registration Questionnaire is a standardized questionnaire designed to help assess whether a user has reliable systems and processes in place for aggregators and related supply chains to ensure compliance with and provide reliable information related to lawful production of commodities, including whether and how these systems are audited. It also seeks to obtain information regarding good communication regarding EUDR requirements and effective grievance management procedures, along with information regarding complaints, compliance breaches and legal proceedings.

Legality and Risk Questionnaire

The Lawful Production and Compliance Risk Questionnaire is a detailed and adaptable questionnaire designed to help assess how the internal management systems ensure compliance with applicable local laws and mitigate residual risks of non-compliance with the EUDR. Users must confirm whether they have internal management systems in place covering all aggregators (and the related supply chains) in each production country to collect, verify and risk assess information which shows compliance with relevant legislation regarding each applicable legality topic, including the specific laws identified by local legal and sustainability experts for each legality topic as applicable for each production country. Legality topics include land use rights, environmental protection, third-party rights and Free, Prior, and Informed Consent (FPIC), labour and human rights, and tax, anti-corruption, trade, and customs regulations.

Where the internal management system reveals a risk of non-compliance with relevant legislation, users must confirm they have implemented the required mitigation measures specified regarding each legality topic. If a user does not confirm an internal management system is in place for each legality topic, or does not confirm that the required mitigation measures have been adopted, the aggregators and their related supply chains are not eligible to be referenced in a product consignment within ICE CoT.

Risk Assessment Process

ICE CoT's risk dashboard includes information relating to specified risk criteria and identifies how users can use this as part of their EUDR risk assessment processes regarding a product consignment.

The information includes:

ICE CoT Farm Plot Data Methodology outcome;
ICE CoT Physical Flow Traceability Methodology outcome;
Lawful Production and Compliance Risk Questionnaire outcome;
European Commission production country risk assignments and expert group conclusions;
Data regarding the presence of forest and prevalence of deforestation in the production country (Space Intelligence and EU Observatory maps);
Public resources information regarding corruption perceptions, regulatory quality, rule of law, human rights, conflicts and sanctions in the production country; and
Data regarding indigenous peoples risks.

A product consignment is a specified quantity of a single physical cocoa or coffee commodity product type (e.g. cocoa beans, cocoa butter, coffee beans) whose details are uploaded onto ICE CoT. A product consignment may be uploaded at any point in the supply chain after it has been supplied by an aggregator. Each uploaded product consignment will require data regarding specified events between the aggregator supply and the point at which the product consignment is uploaded, including any transport, storage and processing of the product along the way.

The sequence of submitted event data can be used to track the commodities and products that comprise or are used to make the product consignment through the physical supply chain, back to the aggregators from which the relevant commodities or related products were sourced, and identifying the farm plots where the commodities were produced (a “traceability tree”). Each separate quantity of a single physical commodity or related product at each event along the traceability tree, starting with the initial supply by an aggregator, is called a “product parcel”.

The event types supported by ICE CoT include:

CreateParcel – sourcing of a product parcel from an aggregator. The start of every traceability tree, this provides the direct link to a list of eligible farmers identified in the farm plot data. Every subsequent event ultimately links back to a CreateParcel event.
Transport – movement of a product parcel, for example by truck.
Warehousing – storage of product parcel at a warehouse or other facility.
Operation – specified action carried out on a product parcel. For example, washing, processing beans into liquor, butter or powder at a factory, the splitting or merging of a product parcel/product parcels, and any ownership change.
Shipping – movement of product between countries associated with a bill of lading document. For the Shipping event, it is a requirement to upload selected details from the Bill of Lading document, and a scanned copy of the document.

Every event in the traceability tree for a product consignment must be identified by a numeric event ID, which determines the sequence in which events occurred. Events have lists of inputs and/or outputs defining the product acted on or produced by the event. The weight of each product parcel must be known at every stage in the supply chain.

Optional data may also be added including. Underlying systems and documentation to evidence the uploaded information are required to be available for inspection and verification.

Parcel traceability data is not shared with a buyer or with other users except that: details regarding the immediate seller are always shared with a buyer; bill of lading information is shared with a buyer until due diligence statement creation, after which it is not shared; other parcel traceability data may be shared with a buyer at the seller’s option.

ICE CoT currently supports file upload in a JSON format text file with a defined set of objects and fields.

Parcel Traceability Data Methodology Tests

ICE CoT applies consistency and reasonability tests to the parcel traceability data under the Parcel Traceability Data Validation Methodology. All required data fields must be supplied.

ICE CoT Parcel Traceability Data Validation Methodology test methods and thresholds are subject to continuous review and may be updated, removed or added to.

The linkage of events and product parcels must form a consistent sequence in time
Event inputs and output product types must be consistent for the specified event type
Event inputs and output product weights must be consistent with the specified event type
Each identified aggregator must be from eligible list
Each identified facility must be from eligible list
Data relating to bills of lading will be checked against the document scan

Parcel Traceability Questionnaire

EUDR-compliant supply chains are expected to have in place systems and processes for warehousing or operational facilities to ensure compliance with required traceability requirements.

ICE CoT uses questionnaires to collect and analyse information regarding these systems and processes as they relate to making sure each product parcel is tracked through each warehousing and operational facility to ensure the identity of the input and output product parcel follows and corresponds with the provided parcel traceability data, and that no mixing or contamination with unidentified product has occurred.

Relevant systems and documentation to evidence the answers to questionnaires must be available and may be inspected and verified.

Only warehousing and operational facilities with fully and satisfactorily completed questionnaires are eligible to be identified in the parcel traceability data for any product consignment.

The ICE CoT badge symbolises a parcel that has all the required information and has passed the ICE CoT validation tests.

The badge may be shared with buyers, along with certain underlying information. ICE CoT will hold all information in relation to a parcel, which may be added to and shared as it moves along the supply chain.

Where required, a user can use ICE CoT to create and submit a due diligence statement to the EU.

ICE CoT uses a risk-based, third-party desk and field-based inspection and verification program to support the data collection and validation methodology processes described above.

All uploaded data, and all systems, processes and data confirmed to be present in questionnaire responses, must be available for inspection and verification on request to check its completeness, truthfulness and accuracy.

Data checks and control points will be identified regarding the ICE CoT data across farm plots, legality and risk systems and processes, and physical flow traceability for product consignments. Risk-based samples will be subject to field and desk-based inspection and verification processes in accordance with ICE CoT’s Data Inspection and Verification Program.

List of Supported Origin Countries

ICE CoT intends to support the following countries of production for both cocoa and coffee commodities and products when the EUDR enters into application on December 30, 2025.

Africa

Angola, Burundi, Cameroon, Congo (Dem. Rep. of), Côte d'Ivoire, Equatorial Guinea, Ethiopia, Ghana, Guinea, Kenya, Liberia, Nigeria, Republic of Congo, Rwanda, Tanzania, Togo, Uganda

Asia

India, Indonesia, Laos, Malaysia, Vietnam

Australasia

Papua New Guinea

Caribbean

Dominican Republic

Central America

Costa Rica, El Salvador, Guatemala, Honduras, Nicaragua, Panama

North America

Mexico

South America

Brazil, Colombia, Ecuador, Peru, Venezuela

Membership

ICE Benchmark Administration (IBA) has implemented an ICE CoT Membership process towards ensuring that users of ICE CoT are of good standing

To become a Member of ICE CoT an applicant must:

Complete an ICE CoT application form and associated documentation;
Undergo a review by the ICE CoT Membership Committee;
Pass KYC screening checks; and
Execute a User Agreement

Interested in becoming a member?

Governance

IBA is responsible for ensuring that there is appropriate governance over ICE CoT and has established the ICE CoT Advisory and Oversight Committee to provide ongoing direction and oversight of the service.

The Committee is comprised of an independent Chairperson and a broad range of experts and representatives from across the cocoa and coffee industries.

The Committee’s terms of reference include:

Providing guidance on the design principles and implementation of ICE CoT in the context of the needs of market participants for compliance with the EUDR, including due diligence, data collection and verification, risk assessment and mitigation, and in supporting the transfer of products along the supply-chain;
Overseeing, reviewing and commenting on the design and implementation of ICE CoT, and in particular the methodologies for the validation checks for farm-origin data and for physical-flow traceability data in respect of cocoa and coffee and processed cocoa and coffee products;
Providing an important and authoritative voice in respect of ICE CoT, to include assisting IBA in the formulation of feedback to regulatory and governmental organisations in the EU and globally regarding deforestation legislation, and to support ICE CoT in any discussions with industry associations and NGOs; and
Overseeing the work of the ICE CoT Technical Working Group and any other working group or sub-committee appointed by the Committee.

ICE CoT Advisory and Oversight Committee Composition and Disclosures of Conflicts of Interest

ICE CoT Advisory and Oversight Committee Terms of Reference

Oversight Committee Meeting Minutes

Further details on IBA’s general governance structure, including IBA’s independent Board of Directors, whistleblowing policy and other policies are available on IBA’s Governance page.

Advisory and Oversight Committee Meeting - 11 March 2025

Advisory and Oversight Committee Meeting - 27 January 2025

Advisory and Oversight Committee Meeting - 12 December 2024

Advisory and Oversight Committee Meeting - 15 November 2024

Advisory and Oversight Committee Meeting - 6 November 2024

Advisory and Oversight Committee Meeting - 26 September 2024

Advisory and Oversight Committee Meeting - 13 August 2024

Advisory and Oversight Committee Meeting - 18 June 2024

Advisory and Oversight Committee Meeting - 15 May 2024

Advisory and Oversight Committee Meeting - 26 March 2024

Advisory and Oversight Committee Meeting - 27 February 2024

Advisory and Oversight Committee Meeting - 17 January 2024

News & Press Releases

News

Webinar: ICE Commodity Traceability (ICE CoT) service launches soon

Learn about the full functionality of the ICE CoT platform and how it supports compliance with the European Union Deforestation Regulation (EUDR).

Webinar: ICE CoT's Trial is Now Live

Get a better look into the platform design to support market participants in their EUDR compliance.

ICE Commodity Traceability (ICE CoT)

Federation of Cocoa Commerce (FCC) Members

Press Releases

ICE Collaborates with Space Intelligence to Launch ICE’s Commodity Traceability Service

August 27, 2024

ICE to Collaborate with Meridia to launch the ICE Commodity Traceability Service to Support Commercial Trade Affected by the EU Deforestation Regulation

September 13, 2023

ICE Benchmark Administration Plans to Launch ICE Commodity Traceability Service to Help Cocoa and Coffee Industries Comply with EU Deforestation Regulation

June 13, 2023

Assurance Mechanism

ICE CoT's robust Assurance mechanism, provides a transparent evaluation of the platform's design and implementation.

This independent assessment scrutinizes ICE CoT's evaluation of articles 9, 10, and 11 of the EUDR in relation to users’ data uploads, ensuring thorough analysis and verification.

The assurance process also examines ICE CoT's capacity, resilience, and operational processing capabilities, offering stakeholders confidence in the platform's ability to handle complex traceability requirements.

By making this assessment publicly available, ICE CoT demonstrates its commitment to transparency and accountability.

This rigorous third-party validation not only enhances the credibility of ICE CoT's services but also provides valuable insights into its operation.

Documentation

ICE CoT Grievances

ICE CoT Complaints

All uploaded data, and all systems, processes and data confirmed to be present in questionnaire responses, must be available for inspection and verification on request under ICE CoT’s Data Inspection and Verification Programme.

View the Public methodology

ICE CoT collects and runs a series of reviews and tests on the uploaded data, conducted in accordance with our published methodologies, to support users in showing the relevant product consignment can be traced back to farm plots which are free of deforestation, and that it has been lawfully produced (including being produced outside legally protected areas).

The methodologies include checks that the uploaded data is reasonable and consistent. The questionnaires ask whether systems and processes are in place to support traceability and legal compliance. Parcel traceability data may be supplemented as the product consignment moves through the supply chain, and is subject to further validation against the methodologies.

A risk assessment dashboard includes additional information to support users in conducting further risk assessments against specified criteria. All uploaded data, and all systems, processes, evidence and information confirmed to be present in questionnaire responses, must be available for inspection and verification on request under ICE CoT’s Data Inspection and Verification Programme.

Make the connection

Get in touch with a member of our team for more information on ICE CoT.

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ICE Commodity Traceability (ICE CoT) Service

Supporting trade in EU Deforestation Regulation (EUDR) compliant cocoa and coffee.