Q&A

In the spirit of transparency, BCI has tried to anticipate questions the public, press or other stakeholders may have about the initiative, including those of a potentially controversial nature. We do not ask or expect that readers agree with all of our positions, but we do hope that this effort at transparency will at least help to understand our position on the various issues. We welcome additional questions from any source, and will expand and update this listing on a routine basis.

BCI Council members, as well as the general membership, will have their own detailed views on the various issues presented in this Q&A, and this Q&A should not be interpreted as reflecting the views of their separate, independent organizations. Readers are encouraged to contact the Council Members and/or general members directly for their individual views on the specific issues presented.

Is it true that BCI works with large scale, mechanised farms in addition to smallholder farms?

BCI’s highest priority is the transformation of cotton production world-wide in such a way that it becomes a mainstream, sustainable and socially responsible commodity.  Approximately 75% of global production comes from smallholder farms in developing countries, and addressing the key social, environmental and economic impacts of cotton farming in this ‘smallholder’ context is critical to BCI’s mission.  This engagement priority is reflected in our objective to have Better Cotton adopted by 5 million farmers by 2020.

That said, BCI works in developed and developing countries, on small farms and large farms because there is always room for improvement – for all farmers. BCI is a global and inclusive initiative – the standard is applicable to all countries and all categories of farmers.

It is noted that many key cotton producing countries, including some in the developing world, grow cotton on much larger farms, often using mechanised production techniques.  This form of farming has its own unique social, environmental and economic impacts.

To address the different contexts of farming production, BCI has adapted its Production Principles and Criteria so that they are relevant for each category of farming.  Categories for which unique processes and measures exist include smallholder farming (up to 20 ha), medium sized farms (up to 200 ha) and large-scale mechanised farming (>200 ha).

How confident is BCI that real water savings are being achieved?

Environmental academics teach their students about the Jevons Paradox. In the 1860s English economist Jevons noted that greatly increased efficiency in steam engines led to an increase in coal consumption rather than the expected decrease. The explanation is that increased efficiency lowered the relative cost of coal which led to greater demand.

This paradox, called the ‘rebound effect’ in contemporary society, applies to many, if not all eco-efficiency initiatives. If fishermen are taught to fish more efficiently, we should not be surprised that their aggregate catch increases. Similarly, eco-efficiency initiatives in agriculture deliver the desired yield increases and resource savings on a ‘like for like’ basis, but this increased efficiency may lead to ‘intensification’ and/or expansion of farming. This intensification may be good in terms of development benefits, but it may be undesirable if it results in deforestation, or increased use of water in water-stressed areas.

Better Cotton is not immune to the Jevons Paradox. A number of recent studies looking at rice, cotton and sugarcane eco-efficiency measures have highlighted the need to be cautious about claims related to net water savings to the ecosystem. It seems obvious that a farmer who adopts drip feed irrigation is going to use less water than one who uses inefficient ‘flooded furrow’ irrigation, and Better Cotton field measurements confirm this.

However, the science shows us that although flooding a field may be a wasteful practice on a local basis, the ‘wasted’ or excess water may well seep back into the aquifer and be available for use elsewhere in the water basin. Equally problematic is the increased use of water that results from intensification/expansion of cotton (or sugarcane or rice) farming in a region as a by-product of yield improvement methodologies.

So what to do? Clearly, we need to be precise in the language we use about water savings resulting from eco-efficiency. BCI is very clear in claims about water savings, and always compares the actual results observed to comparison groups who have not adopted the Better Cotton methodologies. Better Cotton is delivering real benefits in this respect and the challenge is to accelerate adoption of these practices, not slow them. That said, we also acknowledge that ultimately, water conservation and water quality measures need to be judged at catchment level, and not just at farm level.

Intensification of cotton farming as a result of eco-efficiency (and related increased usage of water) requires thoughtful analysis. Various ‘Water Stewardship’ initiatives which look at water management on a catchment level have been launched by organisations such as the Alliance for Water Stewardship, WWF and progressive partner companies, and BCI will collaborate closely with initiatives like these in the future.

Is BCI competing with other cotton standards around the globe?

We believe that other ‘sustainable’ cottons such as Fairtrade, Organic, MyBMP, CmiA, ABR, etc. offer retailers strong value propositions and can be part of any healthy cotton portfolio. BCI also collaborates with the Fairtrade and Organic movements at a number of different levels, and has partnership and recognition agreements with various other responsible sourcing programs around the globe.

There is clearly a role for the ‘premium’ sustainability standards, and they deliver clear environmental and social benefits. At the same time, BCI’s aim is to deliver a methodology that will lead to the transformation of the entire sector, not limited to any particular niche.

Better Cotton is not exclusive in terms of restricting technology or methodology used by farmers, and provides a holistic approach to agriculture that will allow farmers to elect which type of ‘sustainable’ farming is best suited for them. It is their choice.

In summary, Better Cotton complements, rather than competes with other responsible cotton standards. We provide a system that will enable sector-wide improvement in the production of cotton. We leave it to the farmers to choose the path that is most appropriate for them.

Why doesn’t BCI just promote organic cotton?

The Better Cotton Standard System is a holistic agricultural management system, and does not promote any specific technology or base methodology. The Better Cotton Standard System seeks to build on the strengths of whatever base methodology that the local farmer chooses, provide information about options, and then work collaboratively to improve the economic, environmental and social impacts associated with that production system.

The well-documented beneficial results that have been achieved by the adopters of Better Cotton speak to the efficacy of this approach.

We feel this ‘inclusive’ attitude with respect to the various farming methods available provides the best platform to achieve the environmental and social improvements we seek on a global scale.

What is GM (genetically modified) cotton (in layman’s terms)?

Contrary to what one might expect, GM cotton plants do not produce ‘super’ cotton bolls of extraordinary size or physical strength. In fact, one can only distinguish between conventional and GM fibre by using the most sophisticated scientific technology; the fibres are for all practical purposes identical.

So if there is no visible difference in the fibre, why do most farmers around the world pay a premium to use these biotechnology seeds? The answer is found in the two key categories of the GM cotton plant. One large class of GM cotton plants has a gene implanted that creates Bacillus thuringiensis (Bt), a toxin found in nature which provides ‘built-in’ protection from certain insect categories. Cotton is a crop which is particularly vulnerable to pests if no protection methodology is employed. Thus, the attraction of a GM ‘trait’ which is harmful to certain classes of insects has obvious appeal to some farmers (though organic and conventional cotton growers employ alternative Integrated Pest Management techniques to achieve the same pest control objective as GM cotton).

The other large class of biotechnology GM seed is referred to as HT cotton. In this version, the plant contains a trait that makes it tolerant to a range of commonly used herbicides, i.e. farmers may use ‘weed killer’ without harming the cotton plant.

BT and HT traits may be ‘stacked’ in a plant (both present), or the seed may be sold with only one trait present, depending on the local context and needs.

It is important to note that seed technology is never a silver bullet solution to a problem. As stated above, BT cotton is only harmful to certain categories of insects. GM farmers must be trained in other techniques to manage the remaining pest threat.  Moreover, GM technologies will fail over time due to insects or weeds developing resistance to the BT toxin or herbicides if farmers are not trained in ‘resistance management’ strategies. The Better Cotton methodology incorporates these vital training programs (for all categories of farmers – GM, conventional and organic).

What is BCI’s view of Genetically Modified (GM) Cotton?

Global biotech cotton area increased from 700,000 hectares in 1996/97 to 23.8 million hectares in 2011/12 and its share of world cultivated cotton area grew steadily over this period, from 2% to 66% (source ICAC).  Other sources claim that in 2012 biotech cotton production may have been as much as 81% of the global cotton area.

BCI has openly (and acknowledging that there are different viewpoints) adopted a position of being ‘technology neutral’ with respect to GM cotton. This means that BCI will neither encourage farmers to grow it, nor seek to restrict their access to it. The overriding considerations that BCI believes are important with respect to the use of technology are that:

  • It is legally available in the country of use (and not imported or purchased via black market channels); and
  • It is provided to Better Cotton farmers as part of an overall support package (e.g., training, advice, a choice among a range of other options, integrated with a resistance management program, etc.) that allows for the technology to be both freely chosen (not imposed) by the local farmers and used appropriately.

BCI seeks to be a mainstream initiative and targets improvements across a range of important issues associated with cotton farming on a large scale, such as improved water management, soil conservation and decent work conditions for farmers and workers.  It would be difficult to achieve these objectives if more than two thirds of the world’s cotton — which could very well benefit from improvements in those areas — were automatically excluded from being eligible for the Better Cotton program.

Is BCI an industry association?

No, BCI is a multi-stakeholder, not-for-profit association that was founded by a group of NGOs, global brands and retail organisations, cotton supply chain businesses and cotton producer groups that sought to address the social, environmental and economic impacts of cotton production at farm level. This same grouping of interests is represented in the board of directors (The Council) of the BCI today.

As an associate member of the ISEAL Alliance, the global association for sustainability standards, BCI meets the baseline criteria of ISEAL’s Codes of Good Practice, embraces ISEAL’s Credibility Principles and is committed to working with other mission-driven standards organisations to improve its positive impacts.

Producers, Civil Society groups, Supply Chain business and Retailers have three seats each in the Council, with one vote per seat. Thus, even if any particular group is over- or under-represented in the wider membership, the governance structure maintains a balance of power and influence over the Better Cotton strategy.

What is BCI’s attitude toward cotton from Uzbekistan?

BCI welcomes the day when Uzbek cotton farmers will be able to benefit from the methodologies of Better Cotton, recognition of basic human rights, etc. (ILO monitoring, and their recent engagement with the Uzbek government on this topic are promising developments).  Until then however, no cotton sourced from Uzbekistan complies with the Production Principles and Criteria of the Better Cotton Standard. 

The Better Cotton Chain of Custody does not allow Uzbek cotton to be sold by international traders or merchants as Better Cotton.

BCI does not monitor the origins of cotton that are not marketed as ‘Better Cotton’. It is the responsibility of Retailers and Brands who wish to avoid Uzbek cotton to ensure that their subcontracted spinners and mills are not using it in their products.

Does the Better Cotton Standard comply with the UN Guiding Principles for Business on Human Rights?

The UN Guiding Principles on Human Rights (Ruggie framework) were adopted unanimously by the United Nation member countries in 2011. There are two constraints which must be considered in our context. Firstly, the framework is not yet actionable in many of the countries where cotton is grown due to the absence of local enabling legislation, i.e., they are still ‘Guiding Principles’ rather than specific practices. Secondly, the primary focus of the Better Cotton Initiative is on farmer practices at field level. While systemic application of human rights practices will certainly apply to the operations of large businesses engaged in farming, many of the Principles are somewhat less relevant to the millions of smallholder, independent farmers.

To address these issues, BCI proactively engaged with the ILO and adopted and integrated into the Better Cotton Standard their relevant Conventions on ‘Decent Work’ such as child labour, forced labour, non-discrimination, freedom of association, etc.

The details are published in our Standard. This is the appropriate, ‘real-world’ level of engagement for the type of work that the Better Cotton Standard promotes.

An associated human rights issue is whether or not BCI members apply these ILO conventions and other human rights practices in their supply chains (beyond farmer level). BCI does not monitor or report on supply chain practice beyond the farmer, e.g., at spinning or cut and sew facilities, etc. However, the Code of Practice which all members sign includes a commitment from members to act with integrity at all times, and ensure that their external partners in their supply chains do so as well. Systemic abuses of human rights in the supply chain would not be consistent with the BCI Code of Practice.

Should farmers be producing food rather than cotton?

Cotton is for millions of people, in some of the world’s poorest countries, a vital and unique link to the global economy. As a ‘cash crop’, it provides a major source of income to pay for health services, education, transport and other vital family needs. The International Cotton Advisory Committee estimates that there are 250 million people who work in the wider cotton industry each year, positioning cotton as a major source of livelihood. However, population growth, water scarcity and finite arable land are growing concerns of experts in the field of food security, and this raises the question of ‘cotton or food?’.

Positioning these two agricultural products as mutually exclusive, polar opposites does not reflect the reality on the ground in large parts of the developing world where cotton is grown. They overlap in many ways. For example, farmers often use some of the inputs used for cotton crop protection or soil enrichment on their agriculture plots used for food. In other parts of the world, cotton production fits into a highly-desirable crop rotation cycle that includes food crops, and contributes to soil improvement and pest control.

Also, many of the techniques promoted by the Better Cotton Initiative are equally relevant for agricultural food production, e.g., water conservation, Integrated Pest Management and ‘Decent Work’. Teaching a farmer to grow cotton more sustainably also teaches a farmer to grow food more sustainably.

Finally, the global climate is a factor as well in choice of crops. Cotton is a fairly resilient crop that fares better than many other food crops in warm, dry areas threatened by water scarcity linked to climate change.

In summary, BCI does not find the simple paradigm of ‘food* or cotton?’ to be a helpful way to view this topic or make policy on this issue. A much more sophisticated analysis is necessary, which takes into account many other relevant contextual factors.

*It should be noted that approximately 60% by weight of the cotton harvest is used as cooking oil and food supplement, and as feed for livestock (crushed seed).

What is ‘Mass-Balance’ traceability? It seems like a way of allowing industry to avoid taking real action, and even misleading consumers.

For those unfamiliar with the notion of Mass Balance, an easy way to visualize the concept is your bank account.   Imagine you sell your used car for €2000 in cash.  You take the cash to the bank.  The bank verifies the amount of your deposit and they use their systems to ensure your account is credited.  When you return to the bank to withdraw cash they do not give you back the same bills that you deposited, but their systems ensure that the ‘mass received in equals the mass they can pay out’, and your personal account remains in balance.

In our context, Mass-Balance is a way of encouraging supply chain users of Better Cotton to buy and use more of it in a very cost efficient manner, as it does not require (costly) physical segregation of the Better Cotton fibre along the supply chain.  In a nut shell, our system records in a secure manner how much ‘Better Cotton’ is purchased by any user in the supply chain. This actual cotton can then be mixed with or substituted for conventional cotton to satisfy contracts. However, the supply chain actor can only claim to sell the amount of Better Cotton that has been purchased from the previous step in the chain. In other words, the ‘mass’ sold cannot exceed the ‘mass’ purchased. The ‘mass balance’ is assured via centrally controlled transaction monitoring on the Better Cotton Traceability System. Moreover, we have very clear rules that define the extent to which this substitution is allowed and help supply chain actors make credible claims about the Better Cotton they use. These are called our Chain of Custody Guidelines.

In this current expansion phase for Better Cotton, it is important to recognise the complexity of the textile supply chain, and allow flexibility that facilitates rapid uptake of Better Cotton (rather than requiring physical segregation and tracking every bale of Better Cotton throughout the entire chain).

There are no legal norms governing communication ‘claims’ linked to mass-balance.  However, there are well-established processes recommended by ISEAL, an international body that publishes codes of good practice to ensure consumers are not confused or misled by these claims.  BCI adheres to these recommended communication practices in their entirety.    Since we can’t say with certainty (using mass-balance) that Better Cotton yarn is physically in a specific end product, we don’t allow our Brand Members to state so either.  We can say with certainty, however, that a known mass of Better Cotton entered and exited the supply chain, and that farmers and planet have benefited from its production.  To reflect this, we only allow our Members to use our logo on an end product with a claim that demonstrates their support and commitment to BCI.  We do not allow labeling that suggests the content of Better Cotton in the product.

Though it is important for us as consumers to know where our cotton comes from, it is even more important to know that farmers, the environment and the industry as a whole benefited from its cultivation at scale – a claim we can make without (costly) physical traceability thanks to Mass Balance traceability.

Why doesn’t BCI require physical traceability? Isn’t it important to know where our cotton comes from?

BCI believes that it is very important to know where all our products, including cotton, come from. We also know the reality of the complex textile supply chain.

When you buy a food product such as a banana or a bag of sugar, it is very similar to its state in nature. When you buy a pair of jeans, they look nothing like the cotton plant in the field. They have gone through many stages of transformation. Therefore, establishing a system of full physical traceability from cotton plant, to bale, to yarn, to denim fabric to jeans takes time.

We are giving the textile industry the time it needs to make physical traceability a reality. We are considering introducing physical traceability throughout the entire supply chain in 2016 as an option. Until then we will work with a system that continues to incentivise procurement and use of Better Cotton (see Mass-Balance Q&A above) to develop Better Cotton as a sustainable mainstream commodity. Though it is important for us as consumers to know where our cotton comes from, it is even more important to know that farmers, the environment and the industry as a whole benefitted from its cultivation at scale – a claim we can make without (costly) physical traceability.

What is BCI’s policy for on-product labelling (using the BCI logo)?

BCI did not allow on-product labelling by our Retailer and Brand members during our ‘start-up’ years for two reasons. Firstly, it was important to position the Better Cotton program as a pillar of a responsible sourcing program, not a marketing campaign. We did not want there to be any confusion on this point, and proscribed use of the logo on-product for the first five years. Secondly, there are complex rules about what messaging can be used on labels to ensure that the consumer is not misled. We felt that it would not be credible for the BCI logo to be applied to products until we reached a significant amount of global cotton production and appropriate traceability systems were put in place to support on-product messaging.

During 2015-16, forecasts indicate that Better Cotton will represent 11-12% of global production. Moreover, our traceability system has been refined and now provides reliable ‘mass balance’ tracking data (see ‘What is ‘Mass Balance’ traceability?’ above), and we’ve identified a road map that will enable optional physical traceability within the foreseeable future. Finally, we have worked closely with international organisations such as ISEAL, as well as our key partners to develop appropriate wording so as not to mislead consumers when they purchase a product with a BCI label. (This messaging specification is known as a ‘Claims Framework’ by communications professionals, and BCI adhere to international standards of good practice in this important area)

Thus, with a credible amount of global production, a reliable traceability system, and a Claims Framework in place, we now feel ready to authorise our Retailer and Brand members to begin using BCI messages and the BCI logo on-product in a controlled framework. Moreover, our brands who have supported BCI so loyally during our start-up phase are excited about telling the BCI story to the consuming public, and use of the logo on-product will contribute to growing our profile internationally. This will create even more demand for BCI and will help enable us to bring our programme to millions of additional farmers around the globe.

The optional use of the BCI logo and a BCI message on-product by brands will begin prior to the end of 2015.

Will brands and retailers reduce the amount of money they are willing to pay for cotton if they learn that farmers are earning more money?

One of the ways in which farmers benefit from growing Better Cotton is by reducing the costs of the inputs they use to produce it. By spending less on fertilisers, pesticides and water, farmers can increase the margin they make on sales of Better Cotton.

It is vital that the benefit of this increased margin accrues to farmers and not to other supply chain actors. However, it is important to note that BCI can only build a system to reduce cost and monitor member behaviour. We do not set a fixed premium for Better Cotton, and recognise that pricing is a function of the market.

Moreover, one of the reasons that leading retailers and brands support the Better Cotton Initiative is that they realise that if famers do not earn enough money growing cotton, they will switch to some other crop, and this could eventually lead to increased costs for the brands or other supply scarcity issues. It is very much in the brands’ own best interest that farmers benefit from any margin improvement their efforts result in.

Why doesn’t BCI support the recycling of cotton?

The primary focus of the Better Cotton Initiative is on the sustainable and responsible production of cotton at farm level.  While BCI strongly supports the sustainability and livelihood benefits of a circular economy incorporating recycling, active participation in this aspect of the cotton life-cycle is beyond the scope of our mission.

Is BCI certain that Better Cotton is having a favourable impact on people and planet?

In the field of development and environmental science, it is important to use the word ‘impact’ with great care. For example, if a hypothetical farmer earns 20% more income due to better crop yields and reduced cost of inputs, can we say that the program has had a favourable ‘impact’ on his well-being?  Not necessarily. What if he uses his increased income to purchase alcohol?

To speak of ‘impact’ of a program, a rigorous scientific analysis must be completed by experts trained to measure and quantify the benefits and unintended consequences of interventions. It usually takes 3-5 years of data collection to provide the necessary degree of confidence in the statistical analysis.

Thus, BCI does not (yet) speak of ‘impact’, but rather of ‘results’. We can say with confidence (for example) that X farmers in Region A used 30% less pesticides than a control group of farmers in the same region who were not using our methodology.

We now have several years of data, gathered from hundreds of thousands of farmers grouped in producer groups that constitute our data base. Reputable independent bodies have studied our ‘results’ and concluded that they indeed reflect reality in the field, and that they are of sufficient depth and granularity to allow for reliable ‘impact assessments’ to be conducted in the relatively near future.

Although we are confident that people and planet are much better off due to the Better Cotton Initiative, we will say so in muted, factual terms until scientifically conducted impact assessments allow us to shout it from the rooftops.

How do you know that farmers are actually complying with the Standard?

Our verification system is comprised of three pillars. Firstly, farmers or groups of farmers (depending on their categorisation in the BCI program) conduct a self-assessment against the requirements of the Standard. We then conduct a ‘credibility check’ of this information (known by specialists as ‘second party checks’) either through our local country offices, or via designated ‘implementing partners’.

Finally, we orchestrate third party verification visits by BCI-approved verification organisations. One hundred percent of large farms are verified; in the smallholder and medium farm context, a sample of farmer groups in each country are third party verified. Farmer groups are chosen for verification based on a combined methodology of risk-based sampling and random selection. This rigorous approach to assurance allows for corroboration across up to three forms of assessment performed by a breadth of stakeholders.

Why don’t you just charge brands a premium and pass that directly to the farmers?

The BCI purposely avoids any discussion of pricing or premiums.  Prices are set in global markets and reflect a wide range of variables such as product availability, quality, counter-party risk, currency risk, transport costs, terms of payment, etc.   BCI does not intervene on this level, and as we aspire to be a mainstream, sustainable commodity, we want to avoid the risk of premiums, which often position eco-products into a niche, top-end category.

Instead of premiums, Better Cotton focusses on lowering costs to the farmer through reduced inputs of pesticides and inappropriate use of synthetic fertilizers, and improved yields through better agricultural practices.

How is BCI funded?

It is helpful to understand our structure and role in order to understand our funding. The ‘BCI’ is a relatively small secretariat (comprised of about 45 staff members). The Secretariat’s primary role is to act as ‘guardian’ of the Standard and to ensure its proper implementation, the credibility of the field data collected, the quality of the training conducted around the world, and provide various other ‘enabling’ functions. A much larger consortium of external partners actually implements the Better Cotton Standard with hundreds of thousands of farmers in the countries we operate in today (and will expand to tomorrow).

The BCI secretariat function is funded primarily via membership fees (which currently cover approximately 80% of costs), grants from public funding sources (roughly 10% of current costs), and the remaining 10% from service fees charged for various aspects of our work. The much greater cost of field implementation projects around the globe is funded by a combination of generous grants from progressive brands and retailers, and match funding provided by various international donor organisations. The names of our brand and retail partners, as well as our public funding organisations are prominently displayed throughout our website.

Our intention for the future is to become less dependent on ‘donor’ grants for both the BCI secretariat costs as well our field implementation costs. This will be achieved through two mechanisms: increased membership will generate the revenue necessary to sustain the secretariat, and the introduction of a ‘volume based fee’ (VBF) will fund our field projects. The VBF mechanism calls for Retailers and Brands to pay a fee based on the amount of Better Cotton they purchase (with built-in incentives to purchase more). These funds will go into a general ‘field implementation project pot’ which will also (hopefully) attract a degree of matching investments from donor organisations. It is anticipated that the transition to the new financial model will occur during the period 2016-17.

Why is BCI working in China’s Northwest Region (an area of social unrest)?

Data consolidated by the International Cotton Advisory Committee confirms China as the world’s largest producer of cotton. Within China, the Xinjiang region produces 56% of the country’s cotton output and accounts for 7 million farmers and workers. As readers will know, Xinjiang has been an area of social unrest for a number of historical reasons. And, like other cotton producing areas around the globe, Xinjiang faces challenges with continuously improving performance against environmental criteria such as water and pesticide use, and Decent Work criteria such as use of migrant labour, Freedom of Association, hazardous work, etc. Rather than avoiding the potential controversy of engaging in this region, BCI sees the potential benefits to farmers, workers, business and local government of working together to introduce our comprehensive set of farming practices in this region.

The BCI approach is to focus on all key cotton growing areas of the world in order to make cotton production better for the people who produce it, better for the environment it grows in and better for the sector’s future. As such, it is in incumbent on BCI to work in Xinjiang. We are confident that our due diligence, screening and close partnership with the local Implementing Partner, coupled with rigorous assurance (monitoring, verification and results reporting) processes are sufficiently robust to quickly identify any issues arising in such a manner that they can be dealt with in accordance with the spirit and objectives of the Better Cotton Initiative. BCI retains its independence from various partners in the region, receives no funding from them beyond their routine membership fee (similar to hundreds of others), and will withdraw its license should circumstances reveal that the principles of the Better Cotton Standard System are not being respected (just as it would elsewhere in the world).