FAQs About the ISCC System Updates

Some questions were raised about specific requirements on the content of the ISCC System Update on 18 April and the ISCC System Update on 28 April 2023. You can find the requirements, questions and answers below on this page.

ISCC is currently working on the provision of further details regarding some requirements, and the page will be in constant update, publishing answers soon.

Questions on the System Update of 18 April 2023

1. Certificates Must Reflect actual Material Flows and Business Activities

  • What needs to be done if, in a re-certification audit, it is discovered that the certificate holder has not purchased material indicated in the annex of the certificate? Can the certificate be maintained for potential flows of raw materials and final products?

For ISCC EU certificates, the certificate and its annex of materials should reflect the state of operations as verified during the audit. If it is detected in an audit that the System User did not purchase any material in the previous certification period, the relevant material must be removed from the annex, and if no activities under the certified scope were carried out, the scope must be removed from the new certificate. If during the audit evidence (e.g. a contract with the supplier) can be provided that the relevant material will be handled shortly, the material can remain on the annex. It is not possible to issue certificates for scopes that don’t reflect the actual business activity of a System User, or to include materials in the annex that are not handled. It is however possible at any time to update the material annex or perform an extension audit to add another scope to

For ISCC PLUS certificates, please find further information in our System Update of 05 May 2023.

  • Can System Users who plan to handle new materials start buying these new types of materials before they are added to the annex of the certificate by the Certification Body?

No. Materials can only be handled as sustainable if they are included in the certificate annex of the System User.

  • How does this requirement need to be applied for certificates that contain only one input and one output material and no quantities were handled since the previous audit?

In this case, the Certification Body should not issue a new certificate to the System User unless it can be proven by the System User that material flows are scheduled after the issuance of the new certificate.

Questions on the System Update of 28 April 2023

1. General scope of application

  • Do these requirements only apply to ISCC EU or also to ISCC PLUS?

The requirements of the System Update of 28 April 2023 apply only for the certification of waste and residue supply chains under ISCC EU (such as waste/residues from processing of animal or vegetable oils / soapstock, food waste, POME oil, brown grease/grease trap fat, sewage sludge and UCO supply chains), including all kinds of certification scopes that handle the relevant materials.

  • From what date onward do the new requirements apply?

The first part of the requirements (requirements 1-9) listed in the System Update of 28 April 2023 will become effective as of 01 August 2023 for initial and recertification audits conducted from this date onwards.

The second part of the requirements (requirements 10-16) must be complied with in all initial and recertification audits since the date of the System Update, i.e., 28 April 2023.​​​ Please also note that some of the listed requirements are already existing ISCC requirements and the System Update only provide further clarifications and highlights the importance of following these requirements.

2. High risk level for audits from System Users that handle waste/residues from processing of animal or vegetable oils / soapstock, food waste, POME oil, brown grease/grease trap fat, sewage sludge and/or UCO (requirement n. 1)

  • Is the high-risk level requirement only applicable for the listed feedstocks or also for final fuels made from these materials?

Only audits for individually certified Points of Origin, Collecting Points, and Central Offices (for groups of Points of Origin) handling the listed raw materials need to be conducted under high risk level.

ISCC EU System Document 204 “Risk Management” provides the guideline that for audits with high risk level, the documents from three consecutive months should be checked. We herewith clarify that in cases where the amount of documents from three consecutive months exceeds a reasonable audit scope (e.g., due to high numbers of deliveries from small PoOs such as UCO from restaurants), the sample size of the documents can be reduced. If the audit includes sampling of third-party locations, e.g., Points of Origin or storage facilities, the minimum sample size must be multiplied with the risk factor 2.0.

Adjustment July 2023: Exception for sample audits of public containers: If collecting points collect materials from public containers, the initial sample size of public containers to be audited on-site may be determined based on a regular risk level. If during the on-site audits any irregularities are found, the sample size must be increased to reflect a high risk level.

3. Forwarding of information on Points of Origin throughout the supply chain for waste/residues materials that are generated at an oil mill, refinery or another processing unit (requirement n. 2)

Adjustment July 2023: Based on feedback from certification bodies and other stakeholders referring to the protection of company sensitive information the implementation of this requirement will be suspended until further notice.

4. Certification of the scope Collecting Point

4. 1 A Collecting Point can only be certified under ISCC if an up-to-date list of Point of Origins is available, at least one Point of Origin is listed with a valid Self-Declaration and deliveries from at least one Point of Origin are expected within the first 3 months of the validity of the certificate.

Adjustment July 2023: This requirement is applicable for the initial (first) certification of collecting points. If during the mandatory surveillance audit six months after the initial certification no deliveries from at least one point of origin can be documented, the scope collecting point must be removed from the certificate.
Until further notice, this requirement is not applicable for biogas plants that are also acting as collecting points.

4.2 Requirements for recertification audits of collecting points

After considering stakeholder feedback received, this requirement has been modified.

As described in the ISCC System Update of 18 April 2023, System Users may not be certified as a Collecting Point if no materials are collected from Points of Origin with self-declarations. If a recertification audit identifies that in the previous certification period, no material was collected, the scope Collecting Point must be removed from the certificate.

If it was not possible to collect material reasonable and verifiable reasons must be presented to the auditor. If deliveries from Points of Origin are expected for the next certification period and this can be demonstrated by the Collecting Point the scope can be included on the certificate again.  Further guidance will be provided in due time.

Also, ISCC will update the due-diligence processes and requirements for new registrations with ISCC to verify that the certified scope is applicable.

5. All certificates will require a material annex per scope (requirement n. 5)

  • Does this mean that all intermediate steps must also be mapped, even if they are not ISCC relevant? (e.g.: crude oil -> refined oil -> biodiesel or crude oil -> biodiesel)

The same approach as how to list input and output materials that is already applicable today applies (i.e. naming input and output materials according to the wording of the ISCC EU list of materials). Additionally, in case the certificate is issued for more than one scope, for each input and output the relevant scope(s) handling the materials have to be named. This requirement is applicable for all scopes dealing with waste/residues and waste/residues based intermediate and final products.

  • Will there be a new certificate template for this requirement?

Adjustment July 2023: ISCC has provided an updated template for the ISCC EU certificate. This template is available for certification bodies in the CB section of the ISCC website (login required).

  • Will the materials for traders and storage locations have to be included in the annex?

Adjustment July 2023: No, the materials handled under the scopes trader, trader with storage, warehouse and/or logistic centre do not need to be stated on the annex to the certificate.

  • Will there be the possibility to list the materials by scope in APS?

This is already possible in APS.

6. The individual certification as Point of Origin for Palm Oil Mills and Refineries that want to supply waste and residues material under ISCC will be made mandatory (requirement n. 6)

  • Can Collecting Points that were audited and certified before 01.08.2023 continue receiving material from Points of Origin that signed a Self-Declaration until the end of the validity of their certificate, or do all their Points of Origins need to be individually certified as of 01.08.2023?

Collecting Points can continue receiving material from non-certified PoOs until their next re-certification audit that takes place after 01 August 2023. From the new re-certification audit onwards, all supplying PoOs (Palm Oil Mills and Refineries) must be certified individually.

Since 01 November 2022, all Palm Oil Mills supplying waste and residue materials as PoOs to Collecting Points must be audited individually. The individual certification will permit an easier certification process, as the concerned Points of Origin can choose Certification Bodies depending on their availabilities instead of being covered by the same Certification Body that conducts the audit of the certified Collecting Point.

  • Does this requirement mean that Collecting Points for waste and residues from Palm Oil Mills and Refineries will not be needed anymore? 

Yes, for supplying waste and residues, Palm Oil Mills and Refineries will need to be certified individually, and hence they will not need to supply the material to a Collecting Point anymore. They can sell the material directly to e.g. a trader or a processing unit.

  • Does this requirement only apply to palm-based materials or for all kinds of waste and residue materials being generated in refineries?

The requirement applies for all refineries that are PoOs and for all kinds of waste and residue materials that are generated in refineries.

7. All material deliveries to barges and vessels require storage facilities at the port (requirement n. 7)

  • Does this requirement also apply to ISO tanks or flexibags?

This requirement is applicable for cases in which the material needs to be transferred from one container to another at the port. The requirement does not apply to already packaged goods e.g., ISO standardized shipping containers.


8. Publishing of list of non-compliant PoOs on the ISCC website (applicable for all kinds of waste and residue materials) (requirement n. 8)

  • Can Collecting Points continue collecting from Points of Origin listed on the ISCC website as non-compliant?

Non-compliant Points of Origin (PoO) for all kinds of waste and residue materials will be excluded as suppliers of sustainable material for five years and cannot be covered under the certificate of any Collecting Point or Central Office (for groups of points of origin) or obtain an individual certification as Point of Origin for this period of time. Non-compliant PoOs listed on the ISCC website must be removed from the supply base of Collecting Points and Central Offices immediately.

This does not apply to farms and plantations supplying agricultural residues.

Non-compliant means here that the supplied material of the Point of Origin does not consist exclusively of the waste or residue material as indicated in the Self-Declaration signed by the PoO, the requirements on the signed Self-Declaration are not fulfilled, or access to auditors is denied by the Point of Origin.

ISCC will inform Certification Bodies and System Users about PoOs that were added to the list via notification email (please note that you will have to register to receive the notification by using this link).

  • Does the list of non-compliant Points of Origin have to be checked during every audit or only during audits at Collecting Points?

The list of non-compliant Points of Origin must be checked for the audit of the relevant certification scope, i.e., for audits of Collecting Points, Central Offices and First Gathering Points that collect material from non-certified Points of Origin. Please note that also Collecting Points and Central Offices must check this list to ensure that non-compliant Points of Origin are removed from the supply base without delay (see the question above).

  • Can “non-compliant” Pints of Origin be taken off the published list again?

A Point of Origin remains on this list for five years from publication. After that, the Point of Origin may only supply to a certified Collecting Point again after a successful audit.

9. The Collecting Points must check the plausibility of the received amounts of material for each delivery from a Point of Origin and assess whether the collected amount is verifiable (requirement n. 10).

  • How should auditors check this requirement in the recertificate audit?

In the audit, it should be verified that documents and/or processes are available, which serves as the proof that the Collecting Point has conducted effective plausibility checks of the material received from PoOs.


  • Does the verification have to be done for each individual PoO?

For PoOs that are processing units/palm oil mills, the verification by the Collecting Points must be done for each individual PoO. For other PoOs (e.g. UCO restaurants), the plausibility of the overall amounts of each waste or residue raw material collected from the points of origin must be checked. This includes that e.g., noticeably high amounts or round numbers need to be verified.

10. After each audit of a Collecting Point, the Certification Bodies must submit the updated list of Points of Origin for each audited material to ISCC (requirement n. 15)

  • What information exactly does the list of PoOs have to contain?

The list of Points of Origin must include at least the full names and addresses, and indicative amounts of waste/residues supplied by each Point of Origin (see ISCC System Document 203, chapter 3.4.6).

11. Specific conditions to be taken into consideration for POME oil (requirement n. 16)

  • Often, in shipping documents, POME oil is declared as “Acid Oil” or similar while on the Sustainability Declaration “POME oil” is indicated. Can we keep on allowing this practice?

Different namings of POME oil in shipping documents or in local terminology are one of the main challenges for the verification of POME oil supply chains that may not be changeable by ISCC due to local or customs regulations. For audits at POME oil Points of Origin and Collecting Points, it must be verified that the material corresponds to the ISCC definition of POME oil (please refer to the ISCC Guidance Document on Waste and Residues from Palm Oil Mills). For the downstream supply chain, shipping documents containing different terminology may be accepted, but it must be checked that the material name on the shipping document refers to the material declaration on the Sustainability Declaration and unplausible high amounts of POME oil should be reported to the ISCC Integrity Management via integrity@iscc-system.org.

12. Specific conditions to be taken into consideration for sewage sludge (requirement n. 16)

  • Can Points of Origin (PoO) for sewage sludge only be wastewater treatment facilities, i.e., companies that are exclusively engaged in wastewater treatment, or can any company that has a wastewater treatment facility be a PoO even if it is not their main activity?

Sewage sludge must occur in a wastewater treatment facility, but not limited to companies exclusively engaged in wastewater treatment. It can also occur from companies that operate their own wastewater treatment facility, without this being the main business activity.