Public Consultation
Newly developed system documents or fundamental changes will be published for public consultation.
The ISCC System has been developed in a multi-stakeholder process, including international associations, corporations, research institutions and NGOs from around the world to meet high demands regarding social and ecological sustainability as well as to ensure high practicality and cost effectiveness. Hence, the ISCC Association (ISCC e.V.) was established as a legally registered body responsible for governing ISCC, for guiding the fundamental (i.e. strategic) decisions taken by ISCC, and for unifying and representing ISCC’s stakeholders. In addition, the EU system is subject to a revision by the European Commission every five years in which the system as a whole is reviewed and the standards are adapted according to the latest scientific findings, feedback from stakeholders and to incorporate practical experiences and best practices. Please find more information on the ISCC Governance in the ISCC EU 102 System Document at the bottom of the page.
As ISCC is continuously working to improve the ISCC System, feedback from companies using ISCC, certification bodies and other interested third parties is an important source for the ongoing development and therefore highly welcome.
Documents in the Public Consultation
ISCC Carbon Footprint Certification
The ISCC Carbon Footprint Certification Document has been updated: It now includes a new certification approach for the PCF calculation of silicon metal production and a description of certification approaches for downstream entities handling CFC certified material. The certification approaches for the usage of CCS and CCU remained unchanged.
The document is subject to Public Consultation until 8 November 2024.
Public Consultation – Procedure
ISCC publishes fundamentally changed or new documents for public consultation. Please note that all published documents are draft documents. In addition, finalised versions of the documents might be subject to further adjustments.
ISCC invites all interested parties to send their feedback regarding the documents. ISCC will announce documents that are in the public consultation via ISCC’s communication channels in order to ensure adequate balance of various stakeholder groups.
The first round of public consultation will last 60 calendar days from the date of publishing. Please use the contact form below to submit your feedback. All fields marked with an asterix (*) are mandatory.
Where substantive, unresolved issues persist after the first consultation round, or where insufficient feedback was received (for example, inadequate representation of stakeholder groups relevant for the topic), ISCC will carry out additional rounds of consultation that last 30 calendar days. In case of necessity of another round, ISCC will make the synopsis of the previous round publicly available to comment on it.
ISCC will publish the feedback during the public consultation phase in the table below for reasons of transparency.
After the final round of public consultation, ISCC will analyse and consider the feedback received before publishing the final version of the document. All feedback is handled impartially. In case of adjustments or changes to the relevant content of ISCC EU in the version recognised by the European Commission, ISCC will notify the European Commission. Only after approval by the European Commission such adjustments or changes can be implemented. If fundamental changes of the existing system are requested (especially in the ISCC PLUS system) ISCC will notify the Board of the ISCC Association. Only after approval by the ISCC Board such adjustments or changes can be implemented.
ISCC will announce the date from which on the document will be valid and allow an appropriate transitional period for all stakeholders to adapt to the adjustments or changes.
Submit your Feedback
Submitted Feedback
Please find feedback from ISCC stakeholders regarding documents published for public consultation below. ISCC reads all comments thoroughly and considers the feedback for the further development of ISCC documents.
| First name | Name | Company | Document in Public Consultation | Message | Date |
|---|---|---|---|---|---|
| Anonymous | Anonymous | Anonymous | ISCC Carbon Footprint Certification (v1.2) | The proposed document appeared towards certification for product carbon footprint where ISO 14067 have been quoted several times. However, ISO 14067 is developed on the strong foundation of LCA from ISO 14040/44. Thus, it is recommended to realign this document with the core principles from the ISO 14040/44. | 25 September 2024 |
| Rosa (Yoonju) | Kim | Control Union Korea | ISCC PLUS Guidance Document for Ocean-bound Plastic (v1.0) | I was delivered that the OBP standard is now available. So, I would like to leave some comments in the aspects of auditing. Feedback 1. Social criteria: Under ISCC PLUS, the social relevant thing has not been covered as mandatory. So for ISCC auditor, usually there is not high background regarding it as well. Is there any plan to conduct a training for this? Feedback 2. The checklist and audit procedure for social criteria seems not yet prepared. When can it be organized? If there is, where can I find it? Feedback 3. There is a restriction of 50km of ocean coastlines. In that sense, technically 60 km or 70km from ocean coastlines cannot be certified. But in reality, it cannot be guaranteed that those were gathered from the place of 50 km or less of ocean coastlines. Is there any means to make it more credible and guaranteed that is it a real OBP which meets 50 km restriction? If so, could you give us any advice? | 1 August 2024 |
| Joseph | Fallurin | RMI | ISCC Carbon Footprint Certification (v1.1) | Executive Summary -Selection of CO2 sources based on additional conditions -Removal of ambiguity and subjectivity from the guidance to avoid misinterpretation, unintended consequences, or gaming of the standard. -The need for more robust verifiable data underpinning claims. -Reconsideration of a threshold approach in favor of multiple tiers and progressive tightening of the standard in favor of non-fossil feedstocks and climate-aligned targets. Section 2.1: Verification Process Context: The auditor must document emissions occurring at the audited site (for all relevant elements) and, if relevant, the savings achieved in the audit report. If the emissions deviate significantly from typical values, then the report must also include information that explains the deviation. Comment: The highlighted guidance for the auditor is subjective and creates opportunity for variability in interpretation, putting the credibility of the standard at risk. Consider providing guard-rails by defining a range for ‚typical value and a threshold for what constitutes as a significant deviation from typical value such as following ISCC 205 deviation thresholds. Section 2.1: Verification Process Context: The economic operator / system user has to provide records and evidence of the following data which will be verified during the audit: Sources of emission factors (e.g., scientifically peer-reviewed literature, LCA databases such as ecoinvent) including the year of publication and their applicability (with respect to time period and region). Comment: As currently stated in the highlighted text, the economic operator / system user is afforded extreme flexibility in what they use as the source of their emissions factors. This may create a perverse incentive to cite sources that may otherwise may be considered questionable by most experienced life-cycle analysis practitioners. Instead, consider maintaining a public evergreen list of approved sources on the ISCC website that the economic operator / system user must use for emissions factors. Section 2.1.: Verification process Comment: There is no mention of (1) the need for independence of certifiers / auditors nor (2) how disagreements or grievances are resolved. It would be prudent to install a fair, transparent and impartial process to duly handle and address grievances, complaints, and appeals. Section 3.2: Certification approach for CCS supply chains Context: Figure 1 (pg. 9) and Processing unit assigning the CO2 savings (pg. 10) Comment: Figure 1 could be misinterpreted. Add clarification that all processing units sit within the same site and corporate boundary. Further, it is unclear what happens if Processing Unit II creates multiple co-products as often happens in chemical plants, with some products not reaching Processing Unit IV. In that case, would there be restrictions on how many CO2 savings declarations can pass through from the CCS unit to Processing Unit IV? If so, what would be the criteria (e.g., mass ratio, value ratio)? Section 3.3 Methodology for the calculation of net CO2eq savings Context: All process steps for CCS (capturing, transport, injection, and storage) must be considered for calculating the net CO2eq savings. For all three steps, leakages and uncontrolled CO2 fluxes must be monitored, measured, and considered to determine the net CO2eq storage. Comment: It is unclear if the auditor should also assess the methods, protocols, certification, or compliance statement that provide assurance of the tools, instruments, mechanisms, devices, and/or processes of emission measurements used to calculate the net CO2eq savings. Section 3.4: Generation and Utilization of net CO2eq emission savings Context: The baseline PCF verified during the certification process can be used during the validity period of the certificate to calculate the CO2eq savings for carbon neutral claims if no major changes with a significant influence on the baseline PCF occurred. (Pg. 12) Comment 5: The term significant in the highlighted text above is open for interpretation. This may create a perverse incentive for economic operators / system users to interpret the guidance in their best interest. (Ex: changes to baseline process result in 20% reduction in emissions intensity but the economic operator / system user considers this insignificant). Consider providing a threshold for what is considered a significant influence on the baseline PCF. Section 3.4: Generation and Utilization of net CO2eq emission savings Context: The net CO2eq savings can be transferred from the CCS unit to the processing unit from which the CO2 was captured, or to other downstream processing units physically linked to the supply chain (see description of system boundaries for assignment of CO2eq savings in chapter 3.1.3.). Comment: "Permanent" storage of CO2 is assumed at point of sales for chemicals, including methanol, and capture facilities are regularly audited. If certification is lost, however, it will only impact the ability to continue selling certified storage, not the booked carbon reduction for the products already sold. Section 3.7: Double claiming of CO2eq savings Context: ‚The CO2eq savings can also not be separated, transferred, or sold individually without the product they were assigned to. Thus, in case the CO2eq emission savings are used under ISCC, those cannot be used to generate e.g., carbon credits on the voluntary market. (Pg. 15) Comment 5: This is a good rule but could benefit from further clarification. How will it be verified? What is the penalty for non-conformance? Consider adding language to note that one role of the auditor is to verify that economic operators / system users are not double- counting savings. In addition, please specify what action will be taken against economic operators / system users that break this rule. Section 4.3.1. Eligible CO2 sources Context: The CO2 used in the certified MeOH converter needs to come from one of the following eligible sources: Comment: As mentioned in the comment on H2 feedstock eligibility below, a more effective method for reaching the certification goal of guaranteeing low-carbon methanol would be to apply a lifecycle assessment to the final product that sufficiently covers feedstocks, including CO2 sources in combination with a low GHG threshold. Negative emissions incurred in the lifecycle of the CO2 (by, for example, capturing CO2 out of the atmosphere using either biomass or direct air capture) could offset the carbon emitted during the use phase of the methanol. Section 4.3.1. Eligible CO2 sources Context: The CO2 used in the certified MeOH converter needs to come from one of the following eligible sources: Biogenic CO2 which originates from biomass Atmospheric CO2 from direct air capture Post-industrial (fossil) CO2 captured from industrial processes, which use fossil sources to deliberately produce electricity, heat, or materials (e.g., cement, iron and steel, petrochemical industry) and would have otherwise been emitted to the atmosphere Comment: Point source carbon capture should primarily be avoided through alternative processes that do not emit CO2 and are only applied in select industrial instances. We propose limiting the eligible CO2 sources further to process emissions, ideally non-combustive or non-heating, from select types of material production sites specifically cement and petrochemicals. As mentioned in a comment on section 3.4., "Permanent" storage of CO2 is assumed at point of sales for chemicals, including methanol, and capture facilities are regularly audited - but if certification is lost due to i.e. leakage, it will only impact the ability to continue selling certified storage, not the booked carbon reduction for the products already sold. An alternative could be to include carbon sources based on a lifecycle assessment, paired with a GHG intensity threshold. Section 4.3.2 Eligible H2 sources Context: Section 4.3.2 (pg. 18) So called blue hydrogen with all carbon emissions originating from the fossil feedstock during the H2 production being stored permanently via CCS is an eligible H2 source under this certification approach. Comment: An alternative to production technology determining eligibility is setting an emission intensity threshold for hydrogen. This will allow industry more flexibility in its production methods, while simultaneously ensuring only hydrogen with minimal emissions qualifies. For example, blue hydrogen has a very limited set of low-carbon use cases that generally do not overlap with methanol production. Direct integrated production of low-carbon methanol from unavoidable methane is already a more efficient method of utilizing CO2 from fossil fuel-based sources than separate methane-based hydrogen with CCS. Additionally, incorporating high quality upstream methane leakage rate estimates for natural gas feedstocks used in blue hydrogen production would likely preclude the technologys inclusion to meet the 70% reduction threshold for this standard. Section 4.4.5: Data basis (PCF of MeoH from Carbon Capture and Utilization) Context: The PCF calculation is based on actual data gathered from the ISCC System User and data sourced from databases and literature. (Pg. 22) Comment: Same as Comment 2 above As currently stated in the highlighted text, the economic operator / system user is afforded extreme flexibility in what they use as the source of data choosing a data source to use. This may create a perverse incentive to cite sources that may otherwise be considered questionable by most experienced practitioners. Instead, consider maintaining an evergreen list of approved sources on the ISCC website that the economic operator / system user must use. Section 4.6: Benchmarking Context: The benchmark value is a reference value for emissions related to conventional MeOH production (cradle-to-gate PCF) on a global level. ISCC has selected a cradle-to-gate PCF value for MeOH production from of 28.2 gCO2eq/MJ MeOH (= 0.561 kg CO2eq/kg MeOH14), sourced from the Commission Delegated Regulation 2023/1185. (Pg. 25) Comment: A single baseline PCF value for methanol production neglects the regional differences in emissions intensity of feedstocks and fuel sources for the baseline MeOH process. Consider region-specific emissions factors for more accurate representation of emissions intensity of baseline methanol production. Section 4.6: Benchmarking Context: When the calculation of the CCU MeOH PCF according to the here outlined methodological requirements results in lower emissions than a defined threshold of the reference global value, a claim on low-carbon CCU MeOH is possible. For the certified CCU MeOH PCFs under ISCC CFC this threshold is set to 70% reduction compared to the global reference value to qualify for a low carbon CCU MeOH claim (PCF lower than 0.561*(1-0.7) = 0.168 kgCO2eq/kg MeOH). Comment: A fixed two-tier, cradle-to-gate based threshold ignores the nuances of continuous improvement and significant use/end-of-life emissions differences. At minimum, the claim wording should transparently reflect the nuanced scope. Examples of such wordings include ‚low-carbon (production only) CCU MeOH or "cradle-to-gate low-carbon CCU MeOH. Consider adopting a multi-tier threshold over time to further incentivize adoption of low-carbon feedstocks in line with the needs of a low-carbon future. This can be a sliding scale threshold for emissions intensity similar to RMIs sustainable steel principles (page 22). Since low-intensity methanol is a key component in a de-fossilized future chemical industry, we propose tightening the "low-carbon CCU Methanol threshold by 15% every 5 years until 100% reductions are reached by 2035 to transparently incentivize capital decisions. | 13 May 2024 |
| Anonymous | Anonymous | Anonymous | ISCC Carbon Footprint Certification (v1.1) | Dear ISCC Association, I have some questions that green ammonia and green methanol how to get ISCC certification beg your answers. 1. Where and how can I get the carbon emission factor of CO2 from industrial exhaust gas? 2. Under grid connection, how to calculate the GHG of ammonia and methanol during the processing? And in this situation, is the ammonia and methanol can be recognized as green or sustainable? | 6 May 2024 |
| Anonymous | Anonymous | Anonymous | ISCC Carbon Footprint Certification (v1.1) | Is there a possibility to include guidance under which conditions waste in the bio and bio-circular category can be assumed burden-free in PCF/LCA calculations. This does not seem to be captured in the guidance at this moment. Despite falling into the ISCC+ waste definition, if traded for commercial value, the bio or bio/circular feedstock does not fall into the LCA waste definition. Additionally please provide clarification on difference between waste and co-product. In point 3.6 how is methane capture considered? This is not clear from the document. Please let us know if you would like to discus in more detail on above questions. | 30 April 2024 |
Further Information
ISCC EU 102 Governance
This document lays down the general principles according to which the ISCC is governed globally. It specifies the goal and internal structure of ISCC, as well as the relationship between ISCC and its stakeholders.
Documents recently in Public Consultation
ISCC Carbon Footprint Certification – Food and Agriculture
This document was subject to public consultation until 13 September 2024. The public consultation is now closed.
ISCC PLUS Guidance Document for Ocean-bound Plastic
This document was subject to public consultation until 13 September 2024. The public consultation is now closed.