ASI Chain of Custody – Preparing for CoC 2027

10 October 2023

As part of ASI’s goal to ensure that we continue to produce Standards that are both relevant and implementable for the aluminium industry, this year, between 26 June and 31 August, we conducted CoC qualitative research interviews to begin to determine how the ASI Chain of Custody (CoC) Standard needs to evolve in future. We sought to understand this in relation to evolving stakeholder and regulatory expectations on ‘traceability’.

During the time period, we interviewed 15 companies represented by ASI Members from different membership classes: Production and Transformation (9), Industrial Users (4) and Downstream Supporters (1), and one non-ASI Member. Out of the 14 Members, 11 had already  achieved CoC certification.

The primary objective of the interviews was to find out how ASI CoC Certification is being used in practice and how it may need to evolve in the future to meet market and stakeholder expectations. We are still in the process of gathering this information which will be used to inform the 2027 revision of the ASI CoC Standard and related aspects of the Claims Guide – the link to the ASI CoC Survey is included below, should you wish to participate)..

So far, the interviews have discussed the following:

• Internal/external drivers for companies to obtain an ASI CoC Certification.
• Challenges in implementing and auditing the current ASI CoC Standard.
• The idea of a ‘Dream’ CoC Standard:  what would it deliver?
• And Interest in sustainability data.

Results to date

Drivers to obtain CoC Certification 

Main Driver: Suppliers/Customer Demand

Customers either directly asked about the CoC Certification or companies expected demand for the CoC Material.

Key Drivers: Demonstrate ESG Performance, Product Differentiation

Other Drivers: Marketing, Legislation, Sustainability, Transparency

Under legislation several specific regulations were mentioned around Due Diligence or GHG accounting.

Challenges to implement and audit ASI CoC Standard 

Main Challenge: Data Collection and Management

Setting up an appropriate data management system requires a lot of effort. Even with systems set up, often manual handling of data is needed, which is a burden when dealing with large volumes of data.

Key Challenges: CoC Implementation, ASI Audits

Difficulties understanding Mass Balance, including how to properly account for material inputs and outputs i.e. materials entering and leaving an Entity’s Certification Scope. The struggle to fulfill Due Diligence requirements. Overall, the implementation of CoC Guidance requires a lot of effort.

As much as auditors are very well informed about the Performance Standard, their knowledge could be improved for the CoC Standard.

Other Challenges: Resource Constraints, CoC Awareness, Complex Supply Chains

Human, material and financial resource constraints. Often lack of internal and external awareness of the added value of CoC Certification. With complex supply chains, companies have difficulties ensuring that each partner at each stage of the supply chain complies with the CoC standard.

There were several companies that did not identify any complex challenges for implementation.

Dream ASI CoC Standard 

Material Accounting: Methods including traceability, transparency, GHG & Scrap accounting

Potential Developments: Compliance with regulations, IT systems, industry recognition, benchmarking with other initiatives, specific changes to CoC Standard and Guidance V2, claims.

Call for improved IT systems, for example more detailed and easily accessible data around ESG issues of other companies (ASI is currently working on rebuilding its assurance platform, elementAl), digitization of CoC Documents and increased industry recognition of the CoC.

Feedback on Mass Balance and Traceability 

Interest in traceability and a physical link to sourced materials, while acknowledging potential challenges and practical issues in implementation for ASI and Entities.

Other insights gathered from the interviews pointed to the fact that there is a wide range of issues and the variety of certifying Entities require different approaches. There is no one-size-fits-all solution.

There were calls for more industry awareness around CoC Material, including a role for ASI (which has limits due to competition law).

Calls for ASI to research how CoC Certification could evolve to meet market demands for greater traceability.

Companies highlighted that any changes to the ASI CoC Standard should consider value added, feasibility of implementation, available technology, financial costs, etc.

We have started now to engage with stakeholders on the Chain of Custody, because we understand that addressing all these points will require a major multi-stakeholder revision process which also considers integration with evolving regulatory requirements, ASI digital systems, and alignment with the Performance Standard restructure.

The CoC Survey is live and we welcome your feedback. Click here for more information and to complete the survey.

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