In the definition of the Sn factor in the Annex VI, Part B RED II, the inputs are clearly defined as annual. This would mean that all feedstocks that enter a digester over a 12-month period would have to be considered in the GHG calculation.  

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We understand that it may be beneficial to do the calculation on a shorter time period, i.e. per individual batch or per month. Such an approach could be applied, if system users coordinate with their Certification Body and an appropriate audit approach is developed. The auditor must verify that the needed information of all relevant inputs for the production process are documented and measured accordingly. We have asked the EU Commission for clarification on this topic. Therefore, until the EU commission confirms whether this is permissible, ISCC’s recommendation remains a yearly calculation.