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 Public Consultation
Waste and Residues from forestry and forest based industries: Crude Tall Oil (CTO)
This document will be on public consultation for 60 calendar days from the day it was published ( until 17 August 2025).
The contents of this guidance focus on points of origin and collecting points for waste and residues feedstocks from forestry and forest based industries. Topics like the properties of the waste and residue feedstocks, supply chain elements involved and points to consider for plausibility are described. This document supplements the ISCC EU system document 202-5 Waste and Residues in its currently applicable version as published on the ISCC website. The document will be reviewed and updated periodically.
Waste and Residues from Food and Food Processing (V1.2)
This document will be on public consultation for 60 calendar days from the day it was published ( until 17 August 2025).
The contents of this guidance focus on points of origin and collecting points for waste and residues feedstocks. Topics like the properties of the waste and residue feedstocks, supply chain elements involved and points to consider for plausibility are described. This document has been developed through a multi-stakeholder ISCC working group on wastes and residues involving members of the ISCC Association (companies and industry associations with expertise in this topic), certification bodies and auditors. This document supplements the ISCC EU system document 202-5 Waste and Residues in its currently applicable version as published on the ISCC website. The document will be reviewed and updated periodically.
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 |
|---|---|---|---|---|---|
| Carolan | Sandanayake | iogen | ISCC EU Mass Balance Guidance Document (v1.0) | In addition to other comments submitted by iogen on the proposed ISCC Mass Balance Guidance Document, we wish to submit the following comment specifically on Annex II in the document: Annex II is not referenced in the document, does not add value to the document, and is a potential cause of confusion regarding the identity of final products. For these reasons it should be removed from the document. Annex II provides a table of Final Products, with the text “List of final products that can be considered as physically identical if produced under mass balance. Based on list of material eligible for ISCC EU certification, as of 11 March 2025.” It is unclear why this table is included here, when the ISCC already publishes the ISCC Material List which includes all Intermediate and Final Products eligible for certification. The proposed ISCC Mass Balancing Guidance Document, section 2.1, does not refer to Annex II, but instead references the ISCC Material List as the reference for assessing physical identity. The ISCC routinely updates the Materials List, and Products may be added or removed from the list, making it the proper reference source. Any table included in the Mass Balancing document will soon become out of date, creating confusion for a Product which appears on the Materials List but not in the Mass Balancing Guidance Document. Furthermore, the table provided in Annex II of the proposed Mass Balance Guidance Document does not include all the Final Products currently on the ISCC Materials List which can be considered as physically identical if produced under mass balance. For example, Bioammonia is on the current ISCC Materials List, but not in Annex II. The current ISCC Materials List includes a number of co-processed fuels (see list below), which were omitted from Annex II. These omissions could create confusion in an audit involving these products where mass balancing is used. For these reasons, Annex II should be removed from the document. Some examples of Products from the ISCC Materials List which were not included in Annex II: Bioammonia Co-processed diesel/petrol/jet fuel produced from biomethane Co-processed oil to be used for replacement of diesel Co-processed oil to be used for replacement of marine fuel Co-processed oil to be used for replacement of methanol Co-processed oil to be used for replacement of naphtha Co-processed oil to be used for replacement of petrol Co-processed oil to be used for replacement of jet fuel Co-processed oil to be used for replacement of liquefied petroleum gas Co-processed oil for the replacement of diesel/petrol/jet fuel produced from biomethane | 01 April 2025 |
| Carolan | Sandanayake | iogen | ISCC EU Mass Balance Guidance Document (v1.0) | In addition to other comments submitted by iogen on the proposed ISCC Mass Balance Guidance Document, iogen would also like to submit the following comment specifically for section 2.1 on Mass Balancing Basics. We propose to add a sentence to the fifth paragraph in this section to improve clarity, as the current language could lead to different interpretations. We have copied the existing paragraph below, with our proposed sentence added at the end: Only one exception remains to this rule, which occurs when materials and intermediates are mixed for the purpose of further processing within the boundaries of the final fuel production plant (IR, Art. 19, 2. (b)). In this case, a flexible assignment of sustainability characteristics to different products becomes possible. Regarding co-processing, it is firstly required to determine the bio-content via an eligible measurement method (EU Delegated Act 2023/1640). After following such, a flexible assignment of sustainability characteristics to varying products is possible. For clarity, product from a co-processing operation may be assigned as a batch containing 100% bio-content product, and a batch containing 0% bio-content product, in proportion to the overall bio-content of such product. | 01 April 2025 |
| Pat | Foody | iogen | ISCC EU Mass Balance Guidance Document (v1.0) | These comments are submitted by iogen, a company that is involved in RED-compliant and ISCC-certified supply chains which source biomethane from several locations, where each source injects in into “interconnected infrastructure” (as defined by Article 2 of Implementing Regulation 2022/996), where withdrawals of an equal quantity of biomethane from the same interconnected infrastructure occur, and where the biomethane is used as a feedstock in a processing unit to make renewable co-processed gasoline, diesel, and jet fuel, each eligible to satisfy Member State requirements under RED. We have substantial experience with the practice of biomethane mass balancing within interconnected gas grids, and respectfully offer the following comments: 1. ISCC system documents should enable the practice of mass balancing within any “interconnected infrastructure”, as required by Implementing Regulation 2022/996. The IR 996 has a clear definition of “interconnected infrastructure”, which is not limited to only the EU natural gas grid, and IR 996 clearly requires mass balancing in any such interconnected infrastructure. Mass balancing in grid systems other than the EU grid need to be enabled. For instance, local grids within Europe that are not interconnected to the EU grid system should be recognized as independent mass balance systems, as should third-country grid systems that are not connected to the EU grid system. Likewise, there are hydrogen pipeline systems and liquid fuel pipeline systems that should be considered. ISCC should offer universal system requirements to address the integrity of sustainable material handled in pipeline/grid systems, including the integrity of: 1) the injection metering evidence, 2) the withdrawal metering evidence, 3) any title transfers of the sustainable material (which should comprise the physical material and its sustainability attributes), and 4) absence of double claiming and evidence supporting such. The guidance (or at least the audit checklists) should more clearly specify the requirements for each of these elements. As an example, requirements for specific capacity licenses and trading at particular points should be avoided, as they may not be applicable. The requirements should capture the essence of the intended controls, and use the risk-based control paradigm already adopted by ISCC. 2. ISCC needs to have a consistent definition of a single mass balance system, where sustainability attributes can be flexibly assigned without physical movements or physical transport of product. The application of mass balance assignment principles seems to be conflicting among different types of systems, particularly for interconnected infrastructure handling biomethane. As per Implementing Regulation 2022/996, Article 19, item 2(d), for gaseous fuels, the interconnected infrastructure is to be treated as a single mass balance system. The proposed ISCC Mass Balance document states that the “…gas grid can be considered as one single storage facility, or a “big tank”, where biomethane and natural gas are collectively stored and transported.” This is an appropriate analogy, however additional requirements identified in the document are not consistent with this analogy. The requirement for “licenses to transport”, “license to operate”, and the ability to “facilitate movement” are inconsistent with mass balancing conventions, implying a need for physical movement that should not exist. Mass balancing is different from physical transport like trucking, and ISCC should not intermingle the two; mass balancing involves the assignment of sustainability attributes across a connected pool of product WITHOUT physical movement. Physical transport should ONLY be required between different mass balance systems. If no transport is actually required, then a requirement to be licensed to perform transport would seem to be an unnecessary burden that restricts participants, adds costs, and does not add compliance value. ISCC should articulate a purpose to such requirement and ensure that its implied costs are justified by the added compliance value, if any. Otherwise, the chain of custody system which imparts controls upon title transfers should be adequate. 3. VTPs should NOT be the only allowed trading locations – title transfers should be permitted at BOTH injection and withdrawal points, and at ANY point within the interconnected infrastructure where title transfers are permitted by the respective system operator requirements. Many pipeline operators can and do recognize specific meter locations (such as injection and withdrawal meters or storage site meters) as locations for gas title transfers within their systems. VTP locations are common trading locations with referenced pricing, but they are not the only locations permitted for registered title transfers of gas. The restriction of using only VTPs is too limiting, unnecessary, and in some cases impractical. If ISCC is seeking to create evidence of title transfer, records of title transfers of gas can be demonstrated through the sales contracts of physical gas (i.e. gas with its sustainability attributes, sold at a specific location). It is important that title transfers be permitted at injection and withdrawal locations (see items 5 and 6 below for additional commentary); these locations have transfer meters and all the evidence to effectively operate a mass balance system, are clearly connected to the grid infrastructure, and enable the execution of the “what goes in must come out” principle. Sometimes, trades at such locations are the ONLY way to ensure the transfer of sustainable material. If the trading location is not an injection or withdrawal location, ISCC could reasonably require that any title transfer be subject to the title transfer requirements of the respective system operator. These requirements are consistent with ISCC System Document 203: Traceability and Chain of Custody, and the Audit Checklist for Chain of Custody v5.5 21 May 2025, language that require “contractual evidence of ownership of the corresponding volumes of material in the grid” and that “the PoS must remain tied to real volumes through documented proof”. 4. It should be clear that, within both the “physical” and “virtual” trading domains, title transfers of biomethane (or any other sustainable material) must be physical. ISCC refers to the “physical transfer domain” and the “virtual transfer domain”, while across physical systems including pipeline grids, there is always clear title to every bit of physical product within the system. Physical trades can and do occur within the virtual transfer domain, including at VTPs and at other locations. Physical product trades must include all the necessary documentation to convey physical title, including the location of the physical transfer, and details of sustainability attributes. Non-physical trades can also occur in the virtual trading domains (examples include futures contracts, options contracts, spread trades, and fixed or floating price swaps) – non-physical trades should be disallowed for biomethane title transfers. Every transfer of ownership of biomethane should be physical and include both physical gas and its documented sustainability attributes. Transferring a PoS without a title change of physical gas is “book-and-claim” and should be prohibited, even at a VTP. ISCC should observe mass balance conventions whereby the sustainability attributes can be flexibly assigned to any material within the mass balance system, AND upon any title transfer of sustainable material in such system, the sustainability characteristics must be assigned to the traded product. 5. The execution of “inverse” trades outside VTPs needs to be permitted in certain circumstances. The ISCC Mass Balance Guidance document includes a note which states “Any “inverse” transaction, i.e., where biomethane is notionally swapped for fossil gas, may only occur at the VTP. This form of transaction may not occur at the point of physical injection or withdrawal. This ensures that each transaction aligns with actual grid flows and license requirements.” In terms of a single mass balance system, the “inverse” transactions which are being referenced, when properly executed, are entirely consistent with a mass balance system. Effective use of such transactions should not involve a “notional swap”, rather there must be documented change of title of physical ownership of sustainable product, and as often necessitated for physical balancing, there is a matched physical change of title to non-sustainable product. These buy-sell transactions (i.e. buy physical sustainable material, sell physical non-sustainable material) are in fact evidence of mass balancing between two different locations with a physical and contractual reconciliation, where sustainability attributes are assigned to different physical gas through transactions. When a permitted mass balance assignment of sustainability characteristics occurs from one location to another, the physical balance at each location changes between non-sustainable and sustainable material, and there is inherently an “inverse” change of state occurs at each location. When buy-sell transactions are aligned with sell-buy transactions, one pair at the injection meter and one pair at the withdrawal meter, the result is valid and compliant title transfer of a consignment of gas with its sustainability characteristics from the injection point to the withdrawal point. The contracts document the flow of title associated with the physical gas and to associated attributes, which are always sold together. These transactions align with the current requirements and are widely practiced in the industry, particularly where injection and sale are concurrently executed through meter matching. These transactions are particularly useful where an injecting party transacts directly with an end user, but they are also suitable for trading situations. Limiting such transactions at injection and withdrawal locations implies a requirement for transportation of gas, which is contrary to mass balance principles. Further, limiting transactions of non-sustainable material should be outside the scope of ISCC’s authority, and thus not within its guidance. 6. If ISCC is seeking evidence of ownership of gas within the interconnected infrastructure to enable the “use” of the grid for mass balancing, licensing should not be the required evidence – title to gas should be the evidence. To remain consistent with mass balance principles, if biomethane injected into an interconnected grid system, its sustainability characteristics can be assigned to any product within such system. Any buyer of biomethane at an injection point should be permitted to assign the sustainability attributes from the injection point to ANY other gas within such system. Thereafter, such buyer should not be restricted in if/how/where/when they sell non-sustainable gas molecules at such location. The same is true at a withdrawal location. A “license” to make any such transaction is an unnecessary requirement that is inconsistent with mass balancing. If ISCC is seeking evidence of physical gas ownership within an interconnected grid system as a condition of “use” of the grid, ISCC might apply a prohibition on “inverse” transactions ONLY if the buying or selling party (if not the party injecting or withdrawing) does not concurrently own an equal quantity of gas at any location within the interconnected infrastructure, and provide evidence thereof. If a buyer or seller owns an equal or greater quantity of gas within the interconnected infrastructure, “inverse” transactions ought to be permitted – they facilitate mass balance title transfers as described above. There should not be a “license” requirement for buyers or sellers, and there should be no restrictions on how non-sustainable material is traded. 7. ISCC should beware of unintended consequences if it intends to require (directly or indirectly) physical transport across any parts of grid systems (or even licenses thereto), including from injection points to VTPs, between VTPs, and from VTPs to withdrawal points. If, despite the inconsistency with the conventions of mass balancing systems, ISCC wishes to create new requirements for physical transport of molecules within the interconnected infrastructure, these new requirements will need to be thoroughly evaluated to take into account the practical requirements associated with transport of physical gas molecules. For example, the proposed ISCC Mass Balance Document does not describe the use of shippers for transport, protocols for transport between interconnected DSOs (lower pressure, small bore pipelines) and TSOs (higher pressure, large bore) where the actual flow is opposite to the supply chain flow, backhauls, or injection into DSOs which take ownership of the injected gas themselves. Adequate access to natural gas shipping services and capacity also needs to be confirmed by Member States, to ensure it is possible for Traders to obtain the services being prescribed. Requiring physical movements would inevitably increase costs of delivery and impair the adoption of the use of biomethane. Any such burdens should be considered in the context of the additional compliance assurance value. Finally, requiring physical transport would be a break with conventions of trading biomethane; sufficient time would be required to allow economic operators to update their contracts and operating protocols to align with new requirements. | 01 April 2025 |
| Dallas | Spiecker | Mass Energy Works | ISCC EU Mass Balance Guidance Document (v1.0) | I am writing on behalf of Maas Energy Works—a family-owned business headquartered in Redding, California. Our company develops, owns, and operates on-farm renewable energy facilities in partnership with dairy families across the United States. With approximately 180 employees, Maas Energy Works operates the largest fleet of dairy digesters, serving over 70 farms in eight states. We specialize in converting cow manure into biogas, which is then upgraded into vehicle fuel, typically compressed natural gas, but can also be used for electricity or hydrogen production. We are closely following developments and stand ready to engage as infrastructure and trading systems evolve to support broader access. We recognize the importance of clear, workable, and inclusive sustainability certification standards. We appreciate ISCC’s role in facilitating transparent trade frameworks, but we are concerned that recent proposed guidance on biomethane mass balancing could inadvertently restrict market participation and create barriers for practical implementation. We echo and support the comments submitted by the RNG COALITION, particularly regarding the following three areas of concern: Limiting transfers to the virtual trading point conflicts with the principle of a single mass balance grid. Gas trading licenses are not uniform across countries. Clarification on applicability to third country grids is needed. We recommend pausing implementation of the current proposal until a new working group can review and revise the guidance. Involving both established and newer market participants will support the development of clear, practical rules that maintain open and competitive access to the biomethane market. | 01 April 2025 |
| Andre | Marquette | Valero Services Inc | ISCC EU Mass Balance Guidance Document (v1.0) | Valero Services Inc. welcomes the opportunity to comment on the ISCC EU Mass Balance Guidance Document (the “Proposed Guidance”). As an ISCC Association Member whose corporate affiliates handle ISCC-certified sustainable bio-based materials, non-sustainable bio-based materials, and fossil-based materials, we appreciate ISCC’s efforts to clarify ambiguities regarding the rules for the mass balance approach. We have identified several areas, noted below, which we believe warrant further clarification. If left unaddressed, we fear that this proposed mass balance guidance will further drive misalignment between the EU and low carbon regulatory programs in other jurisdictions, such as the United Kingdom’s Renewable Transport Fuel Obligation and the Sustainable Aviation Fuel Mandate. This divergence between mass balance approaches could potentially limit the availability of renewable fuels marketed in the EU and therefore the EU’s ability to meet its greenhouse gas reduction targets. We respectfully request your consideration of the following issues: Annex I: Terms and Definitions The Proposed Guidance uses the terms “allocation” and “assignment” in relation to proportional and flexible approaches for managing sustainability characteristics. We recommend either clarifying that both “allocation” and “assignment” are used interchangeably and refer to the assignment of sustainability characteristics or using a single term consistently throughout the document. Definition of “sustainable” ISCC EU 203 System Document (page 89) distinguishes between sustainable and non-sustainable bio-based materials and implies that sustainable bio-based materials are ISCC EU certified, whereas the Proposed Guidance only recognizes sustainable materials apart from fossil-based materials. Bio-based materials may be certified under separate sustainability programs and co-mingled throughout the supply chain. For example, a Trader with Storage may store ISCC EU certified Used Cooking Oil (“UCO”) and ISCC CORSIA certified UCO within the same tank. It would be logistically and economically infeasible for such operator to implement a proportional assignment of these similar feedstocks based on differing sustainability characteristics. Therefore, we recommend clarifying that the definition of sustainable material includes any material originating from biomass-based raw material. Definition of “co-mingled storage” The Proposed Guidance narrowly defines co-mingled storage as “storages in which fuels are stored by several independent companies”, and is ambiguous with regard to the allowance of flexible assignment outside of such co-mingled storage scenarios. However in practice, an economic operator (“EO”) often stores and transports similar materials with different sustainability characteristics in common logistics assets, thereby “co-mingling” these materials. For example, an EO may move fossil-based kerosene used for heating oil, fossil-based jet fuel, and SAF through the same tanks and pipelines. As such, we request clarification that flexible assignment is allowed for final fuels in any logistics system and not predicated on having multiple independent parties using the same logistics assets. Furthermore, we recommend replacing the term “co-mingled storage” with “co-mingled logistics” and broadening the term to include transport and storage. Definition of product group (Section 2.1) The Proposed Guidance defines product groups based on “five different RED categories: food and feed crop, high iLUC risk, Annex IX A, Annex IX B, and other.” Implementing Regulation EU 2022/996 states that: “Raw materials, however, that can be used to produce biofuels, bioliquids and biomass fuels which are subject to different rules concerning their contribution towards the targets for renewable energy should generally not be considered to be part of the same product group as this would risk to undermine the objectives of Directive (EU) 2018/2001, which applies differentiated treatment of biofuels, bioliquids and biomass fuels on the basis of the feedstock they are produced from.” The Proposed Guidance would require Category 3 tallow and uncategorized tallow to be considered in a separate, ‘Other’, product group, while Category 1 and 2 tallows would be included in the Annex IX B product group. This would add complexity to the mass balance when different categories of tallow are physically mixed for trading and storage upstream of the processing facility, requiring proportional assignment of feedstock characteristics instead of flexible assignment. This approach would also conflict with Directive (EU) 2023/2413 Article 1(15) , which amends Article 25 of Directive EU 2018/2001, and permits Member States to set greenhouse gas intensity reduction targets or targets on the share of renewable energy within the final consumption of energy in the transport sector. The energy content of biofuels/bioliquids is not relevant for greenhouse gas intensity reduction targets, which are based on the amount of greenhouse gas reduction for a biofuel or bioliquid compared to the designated fossil fuel comparator. Furthermore, the proposed treatment of Category 1 and 2 tallow as a separate product group from Category 3 and uncategorized tallow, would cause ISCC’s mass balance approach to deviate from that of the UK’s RTFO and SAF Mandate and potentially limit the availability of renewable fuels in the EU market due to the added complexity. Instead, we request that product groups be defined by feedstock type, regardless of their energy content multipliers. Under this approach, used cooking oil and all categories of tallow would fall under a single product group, which would better align with other program mass balancing rules. Final fuel production to final user (Section 2.2) The Proposed Guidance states that proportional assignment is required up to and including the blend point when sustainable fuels are physically mixed with fossil fuels. The Proposed Guidance goes on to state that proportional assignment is not possible downstream of the blend point where fuels are co-mingled in pipelines and storage tanks. Instead, flexible assignment can be made based on the portion of sustainable material that was put into the pipeline or co-mingled storage. However, it is our understanding that the European Commission (“EC”) intended for EU 2022/996 Article 19(i) to allow for flexible assignment of sustainable materials to final fuels. Therefore, we request clarification that the mass balance requires tracking only the biomass content of the blend and not the blend ratio or fossil fuel content. We also recommend removing language regarding blend ratios to improve clarity, as the mass balance bookkeeping approach should consider only the sustainable material. Feedstock to final fuel production (Section 3.1.2) While the Proposed Guidance states that sustainability characteristics may be flexibly assigned to different final products during the simultaneous processing of both sustainable and raw fossil materials (co-processing), the guidance for final fuel production to final user (Section 3.2) does not explicitly address the mass balance approach for the sale of co-processed final fuels. We request clarification that flexible assignment is allowed downstream of the processing facility when co-processed final fuels are co-mingled in pipelines or storage with fossil fuels. This would align with Section 2.2 of the Proposed Guidance, as noted above. Mixing of fuels (Section 3.2.2) The Proposed Guidance in Section 2.2 recognizes the complexity of supply chains and blending in co-mingled pipelines and storage used by numerous independent organizations, which make proportional allocation not possible. In Section 3.2.2, the Proposed Guidance further recognizes that blending may also occur downstream of the initial blend point, whereby pure fossil fuel or distinctive blends of sustainable and fossil fuel blends are added. With regard to SAF blends and pure fossil-based jet fuel movements through multiple pipelines and storage locations to airports, calculating live blend ratios within logistics systems while batches may move in and out at the same time is impractical and not possible. Therefore, we request clarification that flexible assignment is allowed downstream of the initial blending point in all pipelines and storage, in alignment with Section 2.2. Biogas/biomethane (Section 3.2.3) Implementing Regulation EU 2022/996, Article 19(2)d states that “[F]uels introduced into a logistical facility or a transmission or distribution infrastructure such as the gas grid or a pipeline network for liquid fuels, stored in LNG or other storage facilities shall only be considered to be part of a mixture. . .where that infrastructure is interconnected.” By this definition, any interconnected gas grid operates as a single mass balancing system, including gas grids that operate outside of the EU. However, the Proposed Guidance only recognizes the EU interconnected gas grid, which is contrary to the EC’s implementation of the Union Database (“UDB”) and to existing ISCC EU certified co-processing/refining operations that co-process biomethane originating outside of the EU to produce co-processed diesel/petrol/jet fuel from biomethane. Certification Bodies are being considered by the EC in its UDB Gas Pilot to fulfill the role of the Transmission System Operator/Distribution System Operator (TSO/DSO) in verifying gas withdrawal/consumption from gas grids outside of the EU. We request that the Proposed Guidance’s definition of an interconnected gas grid be consistent with the definition in EU 2022/996 and recognize that interconnected gas grids outside of the EU may also operate as a single mass balance. The Proposed Guidance also introduces new requirements to biomethane that are inconsistent with the mass balance bookkeeping approach and effectively result in a requirement for physical transport. These proposed requirements add costs and limit access to biomethane for use in meeting Member State obligations. • License requirements to receive, transport and operate create artificial capacity demands, particularly with inverse flow movements, increasing costs and blocking access due to limited physical capacity access. We believe that title transfers supported by pipeline meter tickets and commercial agreements should fulfill mass balancing obligations. As such, we request the removal of licensing requirements from the Proposed Guidance. • Limitations on trade types and locations, such as allowing “inverse” transactions only at Virtual Trading Points (“VTP”), place further restrictions on biomethane access. We request that trades be allowed at all Physical Transfer Points (“PTP”) and at any commercial system point (virtual system point) in between that can be supported by the system being used (i.e. any pipeline operator’s meters). We also request clarification that physical and virtual trades (even if buy/sell) must have title transfer in order for Proofs of Sustainability (“PoS”) to be transferred. • In addition, we request clarification that movements between non-interconnected grids require physical transport and supporting documents, however intra-grid movements are allowed to leverage mass balance bookkeeping. Conclusion We greatly appreciate your consideration of our comments. If you have questions or would like to discuss any of the points discussed in this letter, please do not hesitate to contact us. Sincerely, - Andre Marquette | 31 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC EU Mass Balance Guidance Document (v1.0) | Thanks for reaching out on the Mass Balance Guidance Document recently published. We appreciate your approach. As you have already pointed out the aviation sector is characterized by a very complex downstream supply chain: most storages and pipelines cannot keep physical segregation between 100% fossil jet fuel and SAF blended fuel with different HEFA blend ratio. In this situation it is not possible the physical traceability of the product and therefore it is not possible to intentionally physically guarantee a certain ratio of HEFA. Below an example for SAF bookkeeping in storages where physical segregation is not possible. During a quarter there are several introductions and outputs to different clients/airports evenly spread over the period. Physical reality • input: 100 mt fossil jet fuel + 100 mt SAF blend (40% HEFA) + 100 mt SAF blend (30% HEFA) --> total input 300 tm / total input of neat HEFA is 70 tm • output: 300 mt sold to different clients/airports, some of that interested to SAF Bookkeeping • input: 100 mt fossil jet fuel + 100 mt SAF blend (40% HEFA) + 100 mt SAF blend (30% HEFA) --> total input 300 tm / total input of neat HEFA is 70 tm • output: 100 mt (50% HEFA) + 80 mt (25% HEFA) + 120 mt fossil jet ---> total output 300 tm / total output of neat HEFA is 70 tm For such complex system, where physical segregation is practically not possible, we ask to confirm that for bookkeeping will be acceptable to have full flexibility to allocate sustainability materials (PoS, PoC) to the outputs considering the principle: "the amount of neat HEFA goes in, the amount of neat HEFA goes out", ensuring in any case the maximum limit of 50% of HEFA as per spec, according to what is stated in the Mass Balance Guidance Document at pag. 13. With this regards we seek clarification for the definition of "co-mingled storage/system" stating that it is a storage/system where physical traceability is not possible, because physical segregation is not possible, both for logistics and/or because several independent companies store and handle fuels in the storage/system. From a practical perspective this approach should also be applied to storages/systems that, although equipped with segregation for neat HEFA, do not have the capability to guarantee and maintain a fixed blending ratio from the blending point (tank where neat HEFA is blended with jet fuel – named as “tank 1”) to the delivery points, lacking an adequate number of dedicated tanks. In this case the percentage of HEFA blended in the “tank 1” shall be considered as input for the mass balance of the depo. | 30 May 2025 |
| Eunice | Ribeiro | STX Group | ISCC EU Mass Balance Guidance Document (v1.0) | STX Group’s Position on ISCC Mass Balance Guidance Document Introduction STX Group is a leading global environmental commodities trader, operating across compliance and voluntary markets for renewable fuels, carbon credits, biogas, and other sustainability certificates. Given our active role in the European and international biofuels markets, we welcome the opportunity to provide feedback on the draft ISCC EU Mass Balance Guidance released in April 2025 for public consultation. The document is the end-product of the Mass Balance working group, initiated at the ISCC EU Stakeholder Meeting, held on the 8th of October 2024. During this stakeholder meeting, a request from the industry was put out to provide more clarification on the mass balancing rules, of which the document is the result. STX Group believes it is essential that the ISCC guidance ensures regulatory clarity, market integrity, and practical feasibility for economic operators throughout the supply chain. This response reflects STX Group’s feedback to the consultation, addressing the concerns, clarification requests and changes STX Group would like to see in the document. The topics will be addressed by different biofuels and biomass fuels covered in the guidance document. As a general remark we would like to mention that even though we appreciate ISCC´s efforts to clarify uncertainties, the issuance of an ISCC guidance instead of an amendment of the existing ISCC standard 203 bears a tremendous risk of legal uncertainty. A guidance document is not legally binding but may be made binding by auditing practice. A clarification within the ISCC 203 standard itself would be preferable, especially as we understand from the published consultation processes that the guidance is meant to be discussed with the European Commission. STX’s understanding is that if a guidance document is issued by ISCC, such guidance should per se only state clarifications, but in no case interpret or alter standard requirements that are open to legal interpretation. Especially not if interpretations/alterations stated in a guidance document could be at the disadvantage of certain market players. Otherwise, there is a significant risk that auditors will have a “choice” to follow the guidance or not and that there could be allegations against ISCC and market players using ISCC that they establish business standards and practices beyond the applicable legal framework. Biofuels/ Raw Materials/Refined oil Definition of Physical Identity of Materials Point 2.1 Mass Balance Rules from Feedstock to Final Fuel Production of the draft guidance states that “Physical identity may be assessed by referencing the most current version of the ISCC material list “ The term “physically identical materials” needs to be defined clearly. The absence of a clear and enforceable definition may result in interpretative inconsistencies, potentially undermining the integrity of material classification and traceability systems. Criteria for product groups Point 2.1 “Mass Balance Rules from Feedstock to Final Fuel Production”, Figure 1: “Criteria for product groups” of the draft guidance states “similar chemical characteristics and similar heating values.” It is imperative that the term “similar chemical characteristics and similar heating values” be defined with greater specificity and technical rigor within the applicable regulatory or certification framework l. The absence of a clear definition may result in interpretative inconsistencies, potentially undermining the integrity of material classification and traceability systems. The determination of the Lower Heating Value (LHV) of raw materials should be explicitly and comprehensively articulated. It should be defined through a harmonized methodology that allows the use of internationally recognized and standardized or at least homogeneous values, provided that the raw material is consistently identified and recognized by existing and accepted technical specification Raw materials: Physically mixed Point 2.1 “Mass Balance Rules from Feedstock to Final Fuel Production”, figure 2: “Assignment of sustainability characteristics raw material to processing to final fuels” of the draft guidance states the following: “Raw materials: Physically mixed” and “Note: Geographical boundaries: stored in the same interconnected infrastructure, processing or logistical facility, transmission and distribution infrastructure or site” It is in the legitimate interest of the operator that any physical mixing operation carried out within its premises be deemed to include, for certification and verification purposes, the mixing activities executed onboard vessels under its operational control. This approach aligns with the principles of operational continuity and traceability and should be recognized as part of the certified supply chain under the applicable scheme. Sustainable fuels: Physically mixed Point 2.1 Mass Balance Rules from Feedstock to Final Fuel Production”, Figure 4: Assignment of sustainability characteristics processed fuels to final use” if the draft guidance states the following: “Physically mixed” and “Note: Geographical boundaries: stored in the same interconnected infrastructure, processing or logistical facility, transmission and distribution infrastructure or site” It is in the legitimate interest of the operator that any physical mixing operation carried out within its premises be deemed to include, for certification and verification purposes, the mixing activities executed onboard vessels under its operational control. This approach aligns with the principles of operational continuity and traceability and should be recognized as part of the certified supply chain under the applicable scheme. Chain of Custody Methodology Communication alongside the supply chain Point 3.2.1 “Fuels Produced under Mass Balance vs. Physical Segregation” of the draft guidance states “However, this clarification presupposes that the chain of custody model (“mass balance” or “physical segregation”) shall be indicated on the Proof of Sustainability (PoS).” The mechanism through which the chain of custody is to be implemented—specifically whether via physical segregation or mass balance—must be clearly established and communicated and should not be subject to or stated in a mere guidance document. The lack of clarity on this aspect poses a risk to both regulatory compliance and certification validity, particularly in multi-operator supply chains. Currently, the “ISCC Proof of Sustainability (PoS)”-Template does not include the applied chain of custody model as a mandatory field. The “Nabisy Proof of Sustainability (PoS)” system does not reference the chain of custody model at all. To ensure transparency and auditability there needs to be a clear indication on how to proof/verify the chain of custody model that a supplier has applied. While STX agrees that there is a need to specify the chain of custody model somewhere in the documentation, the guidance itself is not the correct instrument to address this topic. While ISCC could potentially adjust its own template, it cannot adjust the Nabisy template or templates of other voluntary schemes. This specific topic should therefore be requested to be addressed by the European Commission in a separate process to ensure that the European Commission establishes harmonized and clear and unambiguous rules for all voluntary systems. Chain of Custody Methodology and scenario 5.1 application Point 3.2.1 “Fuels Produced under Mass Balance vs. Physical Segregation” of the draft guidance states that “Consequently, this description clarifies scenario “5.1 Biofuels with raw materials from different product group are kept physically separated” within the ISCC 203 “Traceability and Chain of Custody. For such cases where sustainable fuels are produced under physical segregation scenario 5.1 remains applicable.” Yet, to apply this logic, it is essential that the chain of custody model applied (whether mass balance or physical segregation) is clearly and explicitly stated in the Proof of Sustainability (PoS) or elsewhere and this declaration must serve as necessary and sufficient evidence to determine whether Scenario 5.1 is applicable. Biomethane Chapter 3.2.3 of the ISCC EU Mass Balance Guidance Document aims to provide further clarification on how the biogas/biomethane mass balance principles are intended to be used. Since all volumes that are injected into the gas grid can, in terms of molecules, no longer be separated from each other, physical traceability is not possible in the grid. Therefore, the chain of custody can only be traced by either mass balance or by a book and claim model. The exclusive applicability of the single-mass-balance principle for interconnected gas infrastructure is laid down in RED and the Implementing Regulation 2022/996. The draft guidance aims to clarify certain areas that are unclear but goes further and introduces new rules that are inefficient and unacceptable as they lack a legal basis. - The suggested changes are diametrally opposite to the ideas of an internal biomethane market and an interconnected grid. The set up of the internal biomethane market and the idea of an overall interconnected grid are key for the implementation of the free movement of goods principle within the European Union, the competitiveness of the biomethane market and the overall availability of biomethane. If the suggested changes in the draft mass balance guidance were accepted, this would not only limit the accessibility and the further development of the biomethane market; it would also reduce the overall availability of biomethane. - The suggested changes lack legal basis. - The suggested changes lack an efficient market design approach and try to impose more barriers and complexity to an already highly complex market, which will likely not incentivize the uptake or even the continuation of biomethane production and as a consequence increase biomethane prices for consumers. These above concerns are based on the following considerations: The ISCC EU Mass Balance Guidance Document states that “Traders must hold the necessary license to transport gas from the physical injection point to other parts of the grid, including the VTP. They take legal ownership of the biomethane at injection and facilitate its movement within the network.” The guidance insofar states that a biomethane trader must be “in possession of a valid license to receive biomethane from the biomethane injection point, retain a contract with the corresponding infrastructure operation (TSO/DSO), and hold a contract with the biomethane producer.” and applies the same principles equally for traders on the withdrawal side. These requirements are neither in line with applicable law, nor is ISCC or an ISCC working group legally entitled to set such additional trading requirements. ISO 22095 defines a mass balance model as a “chain of custody model in which materials or products with specified characteristics are mixed with materials and products without some or all of these characteristics resulting in a claim on all of the output, proportional to the input”. This mass balance definition clearly shows that physical traceability is not necessary within a mass balance, but only upon injection (upon withdrawal the green attribute is only traced on an accounting basis via a book out of the mass balance). Within the grid, the green attribute of the once injected physical biomethane volumes is allocated on a pure accounting basis. Yet, the mass balance principle serves to allow the free allocation of the green value after injection and before withdrawal. Limiting transfers to licensed parties or to licensed gas shippers is neither foreseen nor in line with applicable law. If relevant European laws consider the interconnected gas infrastructure as a single mass balance, ISCC or an ISCC working group are legally not entitled to limit transfers within this mass balance. Notwithstanding the question of the legal quality of the guidance, ISCC, whose “legislative competences” are conclusively laid down in the Implementing Regulation 2022/996, is not entitled to establish trading rules that limit the single-mass-balance-principle. Moreover, any limitation of market participants to participate in the single mass balance that is not explicitly stated in the law (here: limitation to parties with licenses and transport capabilities) is highly likely to violate EU competition law principles (Art. 101, 102 TFEU) as it creates market entrance barriers, and oligopolist structures and thereby not only distorts the market but also discriminates against current market participants. In case the gas shipping license were required, the prospective violation of competition laws would have to be prevented by allowing traders to not themselves have a shipping/trading license, but to have third parties provide the relevant shipping services. However, this would completely overburden the system as all these gas shippers would then need ISCC certification. Therefore, the factual bundling of PoS and physical volumes within the mass balance that the guidance requests has to be fully deleted. Otherwise biomethane trading activities will be severely and disproportionally limited without a legal basis. Otherwise, the value of the green attribute (ie the freely allocatable Proof of Sustainability - PoS) would be severely decreased. This again would overall hinder the growth of the biomethane market, which is a key pillar for Europe’s future energy independence and improved waste management practices. As per the nature of a mass balance system, traceability of injected biomethane volumes within the interconnected gas grid is sufficiently safeguarded via the transfer of PoSs between ISCC certified traders. In order to prevent any form of double claiming, the PoS could be accompanied by a Guarantee of Origin (GO), if such GO has been issued upon injection. Yet, the use of GOs should be an option rather than a hard obligation. In practice it also has to be noted that trading/shipping license requirements are not harmonized in the European Union. Not all member states require a ‘trading license’ or a ‘shipping license’ and if they do, the requirements differ. BioLNG The BioLNG scenarios laid out in 3.2.3. are clear and provide the two possible scenarios for BioLNG to be created under the physical and legal constraints present. In view of scenario 2, STX again emphasizes that a trading/shipping license requirement would heavily limit the usability of virtual liquefaction to only a few players. In addition to this, a trading/shipping license requirement, combined with the clarification note stating that: “Any “inverse” transaction, i.e., where biomethane is notionally swapped for fossil gas, may only occur at the VTP.”, would limit the usability of virtual liquefaction to only a few countries that have implemented backhaul nominations. Countries like France that have terminals that are already certified under ISCC EU, would have to shut down their BioLNG services. These limitations will severely restrict the availability of BioLNG and therefore the decarbonization of hard-to-abate sectors like heavy duty road transportation and the maritime industry. The above considerations for biomethane apply mutatis mutandis. Off-Grid and extraterritorial grids We would like to take this opportunity to ask ISCC to address the following two issues that need clarification not only from ISCC but also at European Commission level in order to: 1. not exclude biomethane producers that are not directly connected to the grid, but could contribute to the overall decarbonization efforts; and 2. not limit the international tradability of biomethane: Off-Grid installations need to be able to participate in the interconnected gas infrastructure mass balance. Grids in other countries outside the EU (E.g. US) cannot be completely excluded from being recognized by the EU interconnected grid. STX therefore sees a need to define at EU level how, based on what evidence and through what systems off-grid and non-EU biomethane quantities can be accepted as sustainable in the EU grid and mass-balance-system. | 30 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC EU Mass Balance Guidance Document (v1.0) | 2.1: Proportional vs flexible assigment. Figure 2 explains flexible and proportional assignment as dependent on same or different product group. Then according to figure 3 it depends on the scope of the system user? Or is this only an example? Unclear what is meant and which conditions apply. - 2.2 An example of ‘flexible assignment of fixed blend ratio’, as shown in figure 4, would be helpful to understand how to apply this. | 30 May 2025 |
| Rafik | Ammar | eNG Coalition | ISCC EU Mass Balance Guidance Document (v1.0) | The eNG Coalition welcomes the opportunity to comment on the draft ISCC EU Mass Balance Guidance Document (Version 1.0). We appreciate ISCC’s continued efforts to bring clarity to chain of custody requirements for sustainable fuels under the Renewable Energy Directive and the Implementing Regulation 2022/996. In particular, we support initiatives to make the mass balance system operationally viable across the EU’s interconnected gas infrastructure. However, to ensure that the mass balance framework facilitates, rather than constrains, the scale-up of the e-methane (electrical Natural Gas / e-NG) deployment across Europe, we respectfully offer the following comments and recommendations. 1. Explicit recognition of synthetic fuels (eNG/e-methane) in Mass Balance and compatibility with the Delegated Acts and the RED framework The current draft appears biomethane-centric. It’s essential that the final document: • Explicitly includes e-NG or other synthetic renewable gases as eligible under the mass balance system; • Clarifies that eNG injected into the grid and tracked via book & claim systems (like GOs) should be treated on the same footing as biomethane, provided sustainability and traceability criteria are met. • Consistency with the RED III and Renewable Fuels of Non-Biological Origin (RFNBO) delegated acts, including grid-based supply chain rules, especially Art. 27 and 28. • Avoidance of additional requirements that go beyond the EU legislative framework, which could create regulatory fragmentation and disincentivize investment in eNG. 2. Book and Claim flexibility for market expansion We want to argue for a flexible book and claim model, aligned with gas grid characteristics and existing EU GO systems (e.g. ERGaR and CertifHy) as this flexibility is essential to enable the cross-border trade of eNG and facilitate third-country integration (relevant for imports via LNG terminals). 3. Digitalization and interoperability We encourage ISCC to support digital, interoperable systems (e.g. EU UDB integration) that can manage virtual trades, allocate certificates efficiently, and ensure real-time traceability particularly critical for synthetic fuels with complex supply chains. 4. Recognition of emissions attributes ISCC should recognize that the eNG should retain its carbon intensity profile (from LCA) across transfers and clarify that renewable electricity inputs, DAC-origin CO₂, and storage-related emissions are accurately traced through certificates in mass balance systems in alignment with GHG Protocol and other emerging methodologies. 5. Recognition of Virtual Transfers and GO-based trading We are concerned that the current language in the draft guidance appears to imply a requirement for physical trading of biomethane across the VTP (Virtual Trading Point). This approach is not consistent with the operational realities of the interconnected European gas grid, which already enables mass balance through virtual transfers and book-and-claim systems, such as those linked to Guarantees of Origin (GOs). ISCC should explicitly allow for virtual transfers and GO-based trading within the mass balance framework. These mechanisms are essential for market liquidity, scalability, and inclusivity, particularly in nascent e-NG markets where physical trading infrastructure is still developing. 6. Support for infrastructure-compatible molecules The eNG Coalition emphasizes that e-methane offers a direct substitute for fossil gas, compatible with existing gas infrastructure and end-uses. Therefore, it is critical that the mass balance framework accommodates molecule-agnostic systems, allowing certified renewable gas like e-NG to be traded, stored, and consumed using existing infrastructure, without unnecessary technical segregation requirements. ISCC should ensure that flexible allocation of sustainability characteristics is possible for eNG throughout the gas value chain, consistent with the RED II definition of a single interconnected system. This includes recognition of mass-balanced liquefaction (virtual liquefaction) practices for bio-LNG and e-LNG. To unlock the full potential of e-NG in meeting Europe’s decarbonization targets, the ISCC mass balance system must reflect practical, proportionate, and inclusive rules that align with actual gas market operations. We urge ISCC to collaborate closely with standard-setters (GHG Protocol, IMO, CertifHy) to ensure mutual recognition and convergence and to build a transition framework that avoids sudden disruptions for projects already under development or pre-FID. Finally, ISCC should revise the current draft to explicitly support virtual trading, remove restrictive licensing requirements, and clarify the eligibility of e-NG under mass balance rules. We remain available for further dialogue and stand ready to support ISCC in refining this important guidance. | 30 May 2025 |
| Michael | Buffham | On behalf of the European Bulk Oil Traders' Association ("EBOTA") | ISCC EU Mass Balance Guidance Document (v1.0) | The European Bulk Oil Traders' Association ("EBOTA") welcomes the opportunity to comment on the ISCC EU Mass Balance Guidance Document. This is a much-needed document to address the inconsistencies across EOs and auditors on the interpretation of the mass balancing rules. While the Guidance Document provides some clarity there are a couple of points that are not fully addressed in the guidance. There may be some overlap between EBOTA's below comments and comments filed separately by individual EBOTA Members. 1. The guidance needs to make it clear what the difference between ‘Physically Identical’ and ‘Same Product Group’ is for raw materials and intermediate materials. The first critical decision point is to determine ‘whether the raw materials, intermediate products, and final fuels are physically identical or can be classified within the same product grouping’. While there is reference to Annex II for final fuels as well as a definition on page 7, there is no distinct set of criteria for what ‘physically identical’ is for raw and intermediate materials. Having similar densities within a tolerance range seems to be appropriate to make this determination but then it is unclear how materials could not be Physically Identical but still be in the same Product Group. We would also suggest that Figure 2 be revised to indicate OR between the ‘Physically Identical’ and ‘Same Product Group’ boxes rather than NO to reflect the statement ‘Physically identical raw materials and intermediate products, or those belonging to the same product group, may be flexibly assigned’. It is noted that it is suggested that physical identity may be assessed by referencing the most current version of the ISCC material list. However, it is unclear how this is to be done. Furthermore, it is unclear how the material list will be affected by what is included in the UDB in the future. It is particularly difficult to apply physical blend ratios once products are commingled and the mixed products are identical from a certificate of analysis and customs code perspective. The products are fully swappable, for example co-processed fuel, (bio) naphtha and (bio) LNG, and therefore it should be permissible for them to be flexibly assigned. Even in relation to jet fuel there should be a possibility for free assignment after a certain point in blending. 2. The guidance should make it clear that the RED category determination will be based on the UDB list of materials categorisation and that intermediate materials will be categorised based on the raw material they were made from. There is confusion between raw materials and intermediate products when it comes to categorization of material. Materials are only inputs and as such the fuels (for example, biodiesel) should not be considered materials in the UBD and ISCC context. The terminology should be refined accordingly. We also have feedback on the implementing regulation that we would like to see ISCC address with the EC. While we understand the concerns that led to the new mass balance rules, some of the requirements are challenging to implement in practice. • The framework acknowledges that sustainable fuels lose their molecular “feedstock identity” during the production stage and so flexible assignment is allowed for Final Fuels produced under the mass balance chain of custody model but it would seem the same logic could be applied to intermediate materials. In fact the ISCC list of materials groups intermediate materials with Final Fuels separate from raw materials. • Proportional assignment for materials that have been physically mixed is administratively burdensome as materials are constantly moving in and out of the mixing location and so determining what the proportion is at any given time is difficult. This constantly changing mix would also make it difficult to predict what proportion of materials you will have at a given time in the future and this would impair the ability to agree to sales in the future particularly if the buyer is only looking for one specific raw material. This leads to an inefficient use of storage space as small quantities may be physically separated in order to avoid proportional assignment. This is particularly relevant in the context of co-processing where, once the co-processed fuel leaves the refinery, it goes into commingled storage which often is much bigger than the proportion of the total co-processed fuel (biofuel plus fossil fuel). The purpose of mass balancing is to reduce the administrative burden and allow sustainable products to be available at any time without adding unnecessary costs to the sustainable product. It is suggested that, in an effort to combat fraud, attention is being focused on the wrong measures by restricting the producers and blenders from managing their stocks efficiently and competitively. | 30 May 2025 |
| Michael | Langenberg | Chevron Products Company | ISCC EU Mass Balance Guidance Document (v1.0) | We have reviewed the "ISCC EU Mass Balance Guidance Document" and have certain concerns regarding the topic of proportional assignment on the raw material side and the disruptive impact these proposals would have on acquiring and substituting feedstock for any facilities that are capable of running multiple feedstocks categorized by the different product groups defined by this guidance. The impact of the reporting requirements would add to the cost of certification, which could be a deterrent for growth and development. General Comments: We are under the impression that the proposal contradicts the purpose of mass balancing by narrowing product groups to individual feedstock levels in many cases. This greatly increases complexity with multiple feedstocks where proportional allocation would become infeasible. Existing mass balancing requirements are already currently complex, having to manage batch information for products with different Countries of Origin and GHG Values per Delivery. Furthermore, this will likely complicate an already delayed and difficult UDB implementation. Parties tasked with proportional allocation under the proposal may not know the feedstock groupings since they are based on a rulemaking text where: Certain feedstocks that can be classified in multiple groups. For example, the determination of Annex IX A or B placement for Intermediate, Cover crops and crops grown on severely degraded land cannot be determined in the feedstock supply chain. It is only determined when final fuel is used to meet a member state’s obligation. Annex IX Part A contains many materials with general definitions where final determination of Annex IX A (Group C) or Other (Group E) is made by the individual Member State. The proposal provides inconsistent and unequal treatment of mass balance flexibility between feedstocks used to produce renewable fuel (very restrictive) and the actual renewable fuel (flexible). The current ability to use mass balance for feedstocks should be maintained. We understand this is an ISCC specific guidance document; however, there are multiple Certification Schemes who may have different interpretations of mass balancing rules which are incompatible with feedstock proportional allocation. We understand that for that biogas and biomethane and Bio-LNG, the physical and virtual transfer domain would be within the EU interconnected has network, which implies that biogas and biomethane and Bio-LNG, if using a non-EU grid with commingled gas, cannot be certified as compliant and would not qualify. Feedstock acquisition and storage are continuous and market price-driven processes. This results in feedstocks potentially falling into different product groups, constantly disrupting and changing the ratio of product groups in the tank daily. Sustainability managers must actively manage daily inventory levels, frequently update ratios, issue declarations to ensure mix accuracy at delivery, and monitor feedstock quality characteristics to determine if a feedstock is physically identical. Those managing sustainability traceability would need to monitor the quality characteristics of individual feedstock transactions to manage mass balancing and process transactions accordingly. This will severely disrupt the feedstock supply chain, as contracts are written for specific feedstocks, well ahead of product receipt and storage, and the available amount cannot be reasonably determined. Suggestion: Until a simple reference table defines groups of known feedstocks used in the industry as "Physically Identical Raw Materials," feedstock mass balancing flexibility should be based on the defined scope of certification presented in Section 2 of incoming Sustainability Declarations. Specific to the document itself, we found some of the content unclear and confusing as presented in the current version. For example: We do not see any scenario presented for the initial transaction where a feedstock is entering the certified supply chain. An example would be a transaction between Certified Collecting Points collecting materials that fall under different product groups (under proposed guidance) and the initial trader (with storage). Are collecting points required to follow proportional assignment? It is not clearly defined. Figure 2 physical segregation terms are undefined. How are materials received by a Trader with Storage, declared under “Mass Balance” (and not physical segregation) at a single mass balance site, stored in separate individual tanks by a TRS with “Mass Balance” chain of custody handled? Our understanding is that this chain of custody indicates physical identity of a product cannot be specifically defined? Figure 3 presentation is confusing. The comparison of proportional vs flexible assignments is two different scenarios. The trading scenario (proportional vs flexible) should be presented independently from processing unit examples since there a feedstock is likely transferred multiple times through ISCC defined Mass Balance locations prior to arriving at a processing Unit. This can occur even under the same certificate holder. Summary While we agree on the need for clear definitions and rules regarding mass balancing, and we support most of the document, particularly concerning finished fuels, we have significant concerns about the proportional assignment requirements for feedstocks. These requirements could pose substantial challenges and complicate the implementation process for many companies within the supply chain, including those responsible for auditing mass balances . The complexity of large supply chains could severely compromise transparency, making it nearly impossible to maintain. We worry that the original goal of limiting fraud may be undermined by the extreme increase in complexity that needs to be managed. This complexity could have the opposite effect, creating a significant burden for companies trying to navigate and manage these intricate supply chains. The process could become so convoluted that auditors would struggle to accurately assess allocations. This could lead to additional audit cost and inconsistent auditor standards and reporting. Every movement of product changes the allocation, exponentially increasing complexity. The only way to avoid this is to segregate feedstocks, but producers lack the capacity and funds for such expansion. Running a single feedstock type appears to be the only viable solution. Additionally, this approach will make it harder to meet volume mandates, increase costs for consumers, and ultimately fail to prevent fraud, potentially making it easier for bad actors to conceal their actions within the complexity of the system. | 30 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC EU Mass Balance Guidance Document (v1.0) | As a general comment, we would like to request the inclusion of the definition of physically identical to avoid any doubt or interpretation. Regarding the attribution of sustainability in co-mingled storage and pipelines(point 3.2.2), we believe that it could be simplified as follows: The allocation of sustainability to the output streams of these sites will be limited by the proportion of biofuel in the input streams. Therefore, any proportion of biofuel between 0 and the proportion of biofuel in the input stream can be assigned to the outputs. At the end of each period, it will be necessary to establish the proportion of biofuel in the existing mixture, and this proportion will be considered as an input proportion for the next period. We believe that this proposal aligns with the published guidelines but simplifies tracking for auditors, as they will not have to calculate the proportion of biofuel at each moment, which we consider very complex in some cases, such as pipelines. Regarding the point 3.2.3 Biogas/Biomethane: - For Virtual Trading Point, it seems clear licenses are required for trader A (injection of biomethane into the grid) and for trader C (extraction of biomethane from the grid). However, it is not clear if trader B needs to hold any license to trade only the certificate, as shown in figure 12. - Regarding trader C, and according to figure 12, the PoS and the physical gas molecule are supplied together. We would like to be sure if it should be the same supplier that sells both, the physical volume and PoS, to the end-user. | 30 May 2025 |
| Anthony | Lorin | European Biogas Association | ISCC EU Mass Balance Guidance Document (v1.0) | EBA appreciates the opportunity to provide feedback on the ISCC EU Mass Balance Guidance Document. EBA is committed to a robust, clear, and fair implementation of sustainability certification. Key recommendations about biomethane trading: In general, ISCC should not add entry barriers that the EU legislation does not impose. ISCC should support credible environmental claims while supporting liquidity in the European gas market. Specifically: 1. Do not require a physical gas trading licence for virtual trading at VTPs, as long as mass balance and PoS documentation are maintained. 2. Clarify that mass balance within the EU gas grid allows virtual transfers via the VTP and without requiring physical delivery between counterparties. 3. Include practical guidance on the treatment of off-grid biomethane (whatever the initial form – compressed or liquefied) installations and biomethane injected into European third-country grids. 1/ Licensing Barrier The ISCC Guidance states that traders must hold a physical gas trading licence to engage in biomethane trading within the EU interconnected gas grid. While licensing may be justified at physical injection points, extending this requirement to all trading activities — including those at the Virtual Trading Point (VTP) — creates disproportionate barriers. The trading of the physical gas can be outsourced to third-parties with the license. It can be compared to a liquid biofuel trader that outsources its transport of the biofuel. The draft document’s approach would exclude smaller market participants and many other traders, consolidating trading power among a limited number of large, licensed companies. This would reduce liquidity, and competition in the biomethane market. 2/ Restriction to virtual trading The Guidance appears to interpret mass balance in a way that restricts virtual trading within the interconnected gas grid and prohibits virtual-only biomethane trading (e.g. swapping for fossil gas) at injection or withdrawal points. ISCC should not restrict trade and procurement pathways for biomethane as long as the mass-balance system is maintained with integrity. The mass balance system is designed to track sustainability attributes (via PoS), not physical molecules. The key is to ensure that for every unit of certified biomethane injected, there’s an equivalent unit withdrawn and sold with the associated PoS - regardless of physical flow paths. Enforcing a physical trading step would introduce unnecessary complexity and barriers, especially for smaller or virtual market participants. It adds no additional environmental benefit but increases transaction and compliance costs. 3/ Lack of Guidance for Off-grid Biomethane There is currently no guidance on how to treat biomethane produced at off-grid installations, whether biomethane is liquefied offsite or not. If compressed biomethane with PoS is transported i trucked gas containers from the biomethane production plant to an LNG terminal, then it should also be possible to utilize virtual liquefaction within EU sustainability compliance regime. This lack of guidance risks excluding valid, sustainable supply chains that use third-party verified traceability systems. The Document should expand on these distribution pathways. 4/ Lack of Guidance on Extra-EU Injection There is currently no guidance on how to treat biomethane injected into grids outside the EU but connected to the EU’s gas infrastructure. This is relevant for trade of grid-injected biomethane in UK, Switzerland, Ukraine and other European countries. Market players operate across European countries, whether EU or non-EU, and a lack of guidance would be detrimental to business continuity in that regard. 5/ Omission of Guarantees of Origin (GOs) While the document is primarily about the trading of biomethane using Proofs of Sustainability, the omission of Guarantees of Origin is problematic. GOs can be used across Member States and offer an effective and widely accepted means to document the link between injection and consumption, supporting virtual transfers. By not exploring the interaction with GOs within the Guidance, ISCC risks causing auditors or market players to take a more restrictive stance, thereby harming compatibility between sustainability certification and GO-based trade. | 30 May 2025 |
| Anonymous | Anonymous | BDEW Bundesverband der deutschen Energie- und Wasserwirtschaft e.V. | ISCC EU Mass Balance Guidance Document (v1.0) | The BDEW appreciates the opportunity to comment on the ISCC EU Mass Balance Guidance Document. We are submitting the following consolidated feedback on behalf of our association. Our statement refers to the mass balancing of biomethane. Above all, a European standard for converting the gaseous part of biomethane should be established, as there is currently a wide variety of approaches across different countries, and even within the same country. 1 Distinction between the liquefaction of biomethane All economic operators are required to fulfil the requirements of mass balancing in accordance with Art. 30. We take a cautious view regarding the fact that ISCC does not make a clear distinction between the liquefaction of biomethane using the gas grid to transport the biomethane from the biomethane production plant to the liquefaction facility (=grid liquefaction) and the virtual liquefaction at LNG terminals (=virtual liquefaction) in section 3.2.3 on bio-gas/biomethane. In our understanding, there are three pathways for the liquefaction of biomethane: Scenario 1: Direct liquefaction Scenario 2: Grid liquefaction Scenario 3: Virtual liquefaction With direct liquefaction, the transport occurs via a direct pipeline from the biogas installation to the liquefaction facility for actual liquefaction without the step of transporting the biomethane via the EU gas grid. The basis of the grid liquefaction is also the actual physical liquefaction, including the physical transfer/transport of biomethane using the EU interconnected gas grid and therefore an actual withdraw of biomethane from the gas grid at the liquefaction site. The biomethane has been injected into the gas grid at the biogas/biomethane production facility. Virtual liquefaction, on the other hand, involves a mere transfer of sustainability attributes from biomethane injected into the EU gas grid at a biogas/biomethane production facility towards fossil LNG which is imported into the EU via an LNG import terminal. These three scenarios should be distinguished more clearly by the Voluntary Schemes in order to ensure the clear and accurate calculation of Emission E within the Chain of Custody. ISCC has clarified under ISCC EU 203 Traceability and chain of custody that a virtual transfer of sustainability attributes is only permitted if a ‘conversion factor’ is included under virtual liquefaction that reflects the emissions when actual liquefaction takes place: ‘The transfer of sustainability characteristics from biomethane to Bio-LNG on a mass balance basis is possible, if plausible conversion factors and GHG emissions that would have been generated in case of a liquefaction are taken into account.’ To the best of our knowledge, this is not currently the case with virtual liquefaction at LNG terminals. Among other things, emission values of less than 0.3 gCO2eq/MJ are disclosed; we are unable to reconstruct the use of this emission values as a conversion factor for the liquefaction of methane, especially when taking into account the emission factor of the EU electricity mix. Furthermore, the emission value does not take into account the additional energy and thus the emissions that should be taken into account for the actual liquefaction of natural gas to LNG at an export terminal and its further transport by vessel to a European LNG import terminal. Consequently, in our view, the upstream emissions that are part of the chain of custody are not included in the process of virtual liquefaction. We recommend reviewing the chain of custody of virtual liquefaction. The description of the model ends with the transfer of the sustainability attributes to the fossil LNG at the LNG terminal. It is not clear to which country the ‘fossil emissions’ of the LNG upstream chain and the emissions of the fossil natural gas are allocated when the ‘virtual swap’ of the biomethane attribute and the LNG/natural gas attribute of the emissions takes place. There is a risk that the fossil emissions from the production, liquefaction, transport and utilisation of fossil LNG will not be allocated to any country in despite being imported into the EU. Such a lack of transparency could lead to virtual liquefaction being accused of ‘greenwashing’ fossil LNG by purchasing green biomethane certificates. In order to ensure credibility and regulatory integrity, it is therefore essential to define specific allocation criteria for the emission accounting. These criteria have to ensure that all greenhouse gas emissions are included completely and accurately in the national inventories. In addition, the extent to which harmonisation of the accounting mechanisms at EU level is necessary should be examined in order to close remaining loopholes and prevent the misuse of virtual liquefaction to shift and conceal emissions. Only a transparent and comprehensible regulation can ensure that virtual liquefaction actually contributes to a measurable reduction in greenhouse gas emissions. 2 Definition of economic operators trading biomethane To align with the ISCC traceability requirements and mass balance principles, economic operators trading biomethane (except final customers) shall: 1. be certified as traders under the ISCC or other recognised voluntary scheme; 2. have a status of ‘network users’ within the meaning of the EU-Directive directly or via an agent in any of the entry-exit systems within the geographic boundaries of the interconnected gas infrastructure. In practice it means that an ISCC certified trader (or trader certified under other recognised voluntary scheme) typically has a ‘shipper code’ assigned to network users in the natural gas market. The trade (sale and purchase) of biomethane involves the transfer of ownership of biomethane, including the Proof of Sustainability (PoS) and the equivalent amount of gas. This gas can be exchanged and traded at the Virtual Trading Point to comply with gas market rules, such as daily balancing. According to the Gas Directive, the Virtual Trading Point (VTP), also known as a gas hub, is a non-physical commercial point within an entry-exit system where natural gas is exchanged between a seller and a buyer without the need to book capacity (i.e. “Commercial Domain”). 3 Roles and flows in the biomethane value chain We propose the following addition to chapter “3.2.3 Biogas/Biomethane: Mass Balance System Boundaries” on page 15 instead of “VTP (1)” and “Physical Transfer (2)”: 1. Physical injection of biomethane. Biomethane producers inject biomethane into the gas Distribution System Operator (DSO) network. DSOs manage the gas network, oversee physical gas flows, and can play a role in verification of the mass balance through metering at injection points and confirming injected volumes. NOTE: if the biomethane plant is connected to the network of a Transmission System Operator (TSO), this TSO can perform the same task of metering at injection points and confirming injected volumes. 2. Operational offtake of gas injected into the grid from the biomethane plant. In cases where biomethane producers are not equipped to handle the responsibilities of network users in the gas market such as balancing in the gas grids and selling gas directly at the Virtual Trading Point (VTP), those responsibilities are transferred to gas offtakers, who manage contracts with network operators, book capacity e.g. to access VTP and balance the gas portfolio. At this point, it should be noted that due to the lack of European harmonization regarding the requirements for mass balancing, various practices emerged, potentially undermining the level-playing field. Therefore, we encourage an in-depth dialogue with the industry to develop a long-term solution for implementing mass balance in a manner that aligns with the functioning of the gas market. NOTE: In points 2 – 4, natural gas means gas of non-renewable origin (usually called ‘fossil’, ‘grey’ gas). In line with the gas market rules, contractual arrangements between biomethane producers and local natural gas offtakers require transfer of ownership for the amount of gas injected into the gas network. These arrangements do not grant any rights to make claims related to the origin, sustainability, or GHG emissions saving characteristics of the gas. This gas will be distributed down the value chain and can be resold at the VTP as natural gas (see 2a in figure 12). No environmental attributes of biomethane or sustainability documentation will be transferred to local natural gas offtakers. NOTE: Daily balancing rules applicable in the EU (see 312/2024) make network users responsible for balancing their balancing portfolios in order to minimise the need for transmission system operators to undertake balancing actions. This obligation inter alia implies a need to buy and sell gas within the gas day, thereby, requiring from the local natural gas offtaker to take ownership of gas off-taken from the biomethane producer (marked as ‘natural gas’). 3. Offtake of biomethane (PoS + gas). When a consignment of biomethane is produced and injected into transmission or distribution gas infrastructure, it enters the single mass balance system. Its sustainability and GHG emission saving characteristics can be documented via a Proof of Sustainability (PoS) and forwarded down the value chain along with an equivalent amount of gas. This volume can only be certified and claimed by the producer as biomethane once, ensuring no double disclosure or double marketing of the same attributes. To enable transfer of attributes and sustainability documentation (PoS), biomethane producers conclude contracts with certified traders. Under such contracts, the title for PoS and associated claims can only be transferred in conjunction with an equivalent amount of gas. This typically requires the biomethane producer to reacquire such amount of gas from the VTP (directly or via an agent) to restore the amount of gas in its mass balance inventory, due to the necessary operational arrangements outlined in point 2. Since the purchase of gas in the natural gas market is associated with balancing and other network users’ responsibilities (as explained in point 2), biomethane producers are allowed to arrange a so-called ‘gas swap’ as part of their biomethane offtake contract with the certified trader. In this arrangement, a certified trader (acting as both gas trader and network user) can sell the amount of natural gas equivalent to the quantities in PoS and, therefore, quantities injected into the gas grid (as described in point 1) to the biomethane producer, e.g. at the VTP. This often results in gas transfers being netted to zero, often eliminating the need to submit trade notifications to the gas TSO. Once the PoS and the equivalent amount of gas has been sold, the biomethane producers’ PoS inventory balance is reduced accordingly, and the traders’ PoS mass balance is increased accordingly. NOTE: Trade of biomethane between certified traders may follow the same princi-ples as explained in point 2 and may include contractual arrangements for the ‘gas swap’, according to which the trader down the value chain can buy biomethane as a bundled product (i.e. PoS and equivalent amount of gas) and then immediately sell gas as natural gas back to the counterparty. 4. Sale of biomethane to the final customer. In line with the principles above, the sale of biomethane to the final customer can be facilitated by a certified trader, who can sell biomethane to a final customer connected to the gas TSO or local DSO network. The final customer does not need to be certified under ISCC or any other recognised voluntary scheme. The contractual arrangement for the sale of biomethane will include the title transfer for PoS and an equivalent amount of gas. There are two possible variations at the stage: 4a. the final customer may purchase gas at the VTP and ship it to the point of physical gas withdrawal from the TSO or local DSO network (directly or via an agent); or 4b. a gas swap can be arranged at the VTP between the final customer and the certified trader if the final customer has a local gas supplier holding a gas retail licence who can ship and deliver the equivalent amount of gas to the point of physical withdrawal. 5. Physical withdrawal of gas. The final consumer offtakes physical gas from the DSO (or TSO) network to which their end-use installations are connected. DSOs and TSOs can play a role in verifying the mass balance by metering at the withdrawal points and confirming physically consumed volumes. 4 Specific proposals for Amendments › Page 5: Feedstock categories: The ISCC refers to various feedstock categories, such as food and feed crops, biofuels with low ILUC (Indirect Land Use Change) risk, high ILUC risk crops, Annex IX A (sub-target with a 2x multiplier), and Annex IX B (IX B cap with a 2x multiplier). There are also other sustainable feedstocks with no target, caps, or multipliers. It would be appreciated by the market if these categories were uniformly applied across EU Member States (MS) and their nationally implemented schemes. To support a pan-European market, a clearly defined list of feedstocks with number-codes rather than words would be helpful. › Page 13: At these points, we shall observe a physical flow of sustainable molecules. › Page 15: In Scenario 1 (Figure 13), Bio-LNG production occurs at a physical liquefaction facility, where biomethane is converted into liquefied biomethane (Bio-LNG). This applies to liquefaction units located at a biomethane plant site, for example. In this case, claims of Bio-LNG production must be directly linked to an actual, verifiable liquefaction process. The new PoS must account for conversion factors, process losses, and GHG emissions from liquefaction from atmospheric conditions to cryogenic conditions and transport emissions from the biomethane injection to the liquefaction and from the liquefaction to the end-user. › Page 16: Figure 14: The Single Logistical Facility (SLF) comprises the entire interconnected gas infrastructure within Europe. This figure is misleading as it defines the EU Interconnected Gas Network and not the SLF. It should be clarified that all facilities belong to the SLF. In our opinion, this additional definition of the EU Interconnected Gas Network is not necessary with regard to the applicability of the mass balance and leads to further ambiguities. › Page 16: The quantity of Bio-LNG or biomethane that can be claimed from a plant is limited to the amount that can physically be processed by the plant. › Page 16: Presentation of a new Scenario 2: Liquefaction of biomethane by withdrawing biomethane from the gas grid at a liquefaction facility. Scenario 2: Mass-Balancing / Grid Liquefaction. › Page 16: A European standard for converting the gaseous part of biomethane should be established, as there is currently a wide variety of approaches across different countries, and even within the same country. › There is a need for standardization regarding the document proving the injection of biomethane at the metering point. For example, in Germany, no Guarantees of Origin (GoO) is issued, whereas in other countries, a GoO is typically issued. An EU-wide system for GoO which replaces existing mass balance schemes for biomethane would be a welcome development. | 30 May 2025 |
| Tim | Eestermans | Methanol Institute | ISCC EU Mass Balance Guidance Document (v1.0) | ISCC EU Mass Balance Consultation – Response of the Methanol Institute Dear ISCC, The Methanol Institute (MI) welcomes the opportunity to provide feedback on the “ISCC EU Mass Balance Guidance Document.” MI is the global trade association for the entire supply chain of the methanol industry, representing the world’s leading methanol producers, consumers, distributors, and technology companies. MI represents its members from offices in Brussels, Singapore, Washington D.C., Beijing, and Delhi. MI recognizes the value of mass balance methodology as its use is a key facilitator of the energy transition. Mass balance is essential for determining the renewable share in fuel blends. Accounting for the separate elements in a blend of bio- and fossil-based feedstocks must be clearly enabled to meet progressively stricter GHG targets. A key matter to be addressed in the ISCC document is the recognition of non-EU gas grids for the production process. In the document, it appears that the assumption is that only EU interconnected grids are recognized, which in turn limits the availability of low-carbon fuels in the EU. Including non-EU grids in the certification is essential. This matter is widely recognized across the EU, given the current problems being caused by the Union Database (UDB) under the Renewable Energy Directive (RED). Since renewable fuels like biomethanol and RFNBO-compliant fuels depend on non-EU interconnected grids for transporting biogenic CO2 and biomethane, alternative verification options should be included in the guidance to ensure these fuels can be registered under the RED. This is particularly important for non-EU production facilities, where certification bodies should be allowed to verify biomethane injection and withdrawal volumes to maintain compliance and eligibility. Regarding the Virtual Trading Point (VTP) at p. 15, the matter, as described, creates further unnecessary complexities for traders of biomethane. In the manner described in the document, traders would need to book and pay for their physical transport capacity from the local injection point to the VTP. This not only brings increased complexity to the transaction, but also increases the costs to the mass balance process. The matter should be reviewed in light of the impact upon economic operators as the current system may make it uneconomical for biomethane traders to use pipeline grids for transport, reducing accessibility to, and the availability of, sustainable fuels. Furthermore, by limiting the ability to swap (notionally) biomethane for fossil gas to the VTP, this will also add additional complexity and increase costs for biomethane production. At present, contractual agreements are put in place using a different set of principles. The current principle posed here in limiting the swap to the VTP is going to risk cutting off significant amounts of current biomethane production, as it will not meet the RED III requirements. Such a limitation should be phased in, allowing biomethane producers, traders and consumers time to adjust physical and contractual arrangements in order to meet the certification standards. The methanol industry plays a critical role in ongoing efforts at decarbonization, and there is substantial investment in biomethanol production. As biomethanol has an important contribution to make to realizing the EU’s climate targets, recognition of the diverse pathways for production under ISCC certification is essential. The matter of non-EU gas grids creates unnecessary trade barriers, restricting access to sustainable methanol for industries seeking viable alternatives to fossil fuels. A certification process that is more in line with industry activity will help accelerate investment, ensuring a stable supply of low-carbon methanol for the EU and globally. MI asks ISCC to consider the above comments to further develop clear and practical guidelines for applying mass balance, particularly in the context of biomethane usage. Clear explanations and flexibility in the certification guidance will support the industry's ability to produce renewable fuels efficiently and in compliance with the relevant regulations. Limitations, such as the ones identified here, harm the EU’s pursuit of competitiveness by hampering innovation and investment in decarbonization. | 30 May 2025 |
| Isabella | Fat | MBP Solutions | ISCC EU Mass Balance Guidance Document (v1.0) | Dear ISCC Team, We appreciate the opportunity to provide feedback on the ISCC EU Mass Balance Guidance Document (Version 1.0). MBP Group has proudly maintained ISCC EU certification since 2012, actively supporting the development of transparent and robust sustainability systems. As a collecting point and trader with storage, managing a wide variety of raw materials across Annex IX A and B, we recognize the critical importance of maintaining traceability and integrity in the bioeconomy. However, we would like to express several concerns regarding the proposed changes and their potential implications for our operations and the broader industry. 1. Clarification of Definitions in “Mass Balance: The Basics” The document introduces the concept of “physically identical” materials as a prerequisite for flexible assignment but lacks a clear, operational definition. Section 2.1, Paragraph 1: “The application of mass balance rules begins with determining whether the raw materials are PHYSICALLY IDENTICAL OR can be classified within the same product grouping.” • Question 1: Does the use of “OR” imply that materials deemed “physically identical” can be managed under flexible assignment even if they are not in the same product group? • Question 2: What criteria define “physically identical”? The current ISCC material list does not provide thresholds or specifications. Section 2.1, Paragraph 2: “…tolerance zone of 2–5%, depending on the material…” • Question 3: Where can we find measurable, material-specific definitions for these tolerance ranges? Including this as an annex would be highly beneficial. • Question 4: What type of evidence or documentation would be required to demonstrate compliance with these tolerance ranges? 2. Administrative Burden and Operational Complexity The proposed requirement to assign sustainability characteristics proportionally based on product group, density, and LHV for each batch introduces significant administrative and analytical challenges. As a collecting point and trader with storage, MBP Group handles diverse feedstock streams. The proposed rules would necessitate batch-level tracking and analysis, which is not feasible without substantial infrastructure and system upgrades. Context: Many collecting points mix UCO and food waste in the same tank. If these materials are not considered “physically identical,” the proportional assignment would require: • Manual proportional assignment to all small batches (e.g., to all small collections of 100-600 kg of UCO from restaurants), • Delays in issuing sustainability declarations, • Increased costs for testing and documentation, • Reduced logistical flexibility, • Additional costs for segregating materials in separate tanks. Challenge: The proportional assignment approach appears incompatible with the core principle of mass balance, which allows for temporary imbalances (e.g., selling more sustainable material than available during the period) as long as the overall balance is maintained quarterly. 3. Disruption of Established Mass Balance Practices The current flexible mass balance system has enabled efficient and transparent operations. The proposed shift to proportional assignment undermines this flexibility, particularly for collecting points that mix materials for further processing. This contradicts Article 19(b) of Implementing Regulation (EU) 2022/996, which permits mixing for further processing. Collecting points are intermediaries—not final fuel producers—yet the proposed rules impose disproportionate constraints on them. Key Point: Proportional assignment does not enhance traceability or sustainability when applied to raw materials prior to processing. 4. Potential Market and Environmental Impacts The proposed changes could result in: • Market disruption: Reduced ability to trade ISCC-compliant materials due to delays and complexity. • GHG inefficiencies: Increased emissions from additional transport and segregation. • Stakeholder attrition: Operators may shift to alternative certification schemes with more practical compliance pathways. These outcomes would undermine ISCC’s mission and reduce the volume of certified materials. 5. Implementation Timeline and Feasibility The proposed changes represent a fundamental shift in mass balance implementation. Significant investments in infrastructure, IT systems, and training would be required. Recommendation: A minimum transition period of 10–15 months is essential to ensure compliance and avoid market disruption. Suggestion: Establish a working group that includes collecting points to provide practical insights into current mass balance practices. This would help ISCC understand real-world challenges and collaboratively refine the guidance. Recommendations To ensure continued stakeholder engagement and system integrity, we respectfully propose: • Clearly communicate the rationale and objectives behind the proposed changes. • Maintain flexible mass balance for raw materials managed by collecting points operating within interconnected infrastructure. • Define “physically identical” and “product group” in the ISCC material list and guidance. • Utilize the Union Database to enhance traceability and reduce reliance on proportional assignment. • Provide a clear implementation roadmap with a realistic transition period. • Engage stakeholders through a dedicated working group to collaboratively refine the guidance. We remain committed to the ISCC system and its goals. We hope our feedback contributes constructively to the development of a practical, transparent, and sustainable certification framework. Sincerely, Isabella Fat MBP Group | 30 May 2025 |
| Laurent | Hamou | Elegy | ISCC EU Mass Balance Guidance Document (v1.0) | Elengy would like to thank ISCC for organizing such a consultation, helping to clarify mass balance implementation. Globally, Elengy supports the document, that is effectively implementing precisely the regulation. Few comments : - page 14, it is specified that "credits may be carried over from one mass-balance period to the next, provided the economic operator is able to demonstrate that an equivalent amount of gas remains in stock at the end of the three-months mass-balance period". We understand that this remains true if the mass-balance is conducted over a monthly period. - Figure 12 : in the physical transfer domain, after the withdrawal point, there is usually one or several successive suppliers distributing the fuels to the end-users. They own the molecules that is distributed by tanker trucks to fueling stations or to ships, or by bunker vessels to ships. It can happen that trader C that has withdrawn the molecule is in charge of the rest of the distribution, but the bioLNG can be traded several times before before delivered to the end customer. All these transactions are of course physical transfer of the bioLNG. - p. 15 the “inverse” transaction concept should be accompanied with a more detailed example to be sure what is meant by this notion, and to clarify what is meant by this paragraph. | 30 May 2025 |
| Roland | Kok | Route to Market B.V. | ISCC EU Mass Balance Guidance Document (v1.0) | As an ISCC Association Member, Route to Market appreciates the opportunity to provide feedback on the ISCC EU Mass Balance Guidance Document (v1.0). We are committed to a strong, clear, and fair implementation of sustainability certification. Our comments aim to ensure alignment with EU legislation, preserve market access for biomethane producers, and support credible, auditable practices within the ISCC system. We are not a lobby organization but represent the practical concerns of market participants who rely on clarity and proportionality in certification. Section 3.2.3 of the guidance (pages 14–15) introduces a requirement that appears to link the right to trade certified biomethane with holding a gas shipping license or being a balancing responsible party. This interpretation creates confusion between logistical and commercial functions. Gas shippers and balancing responsible parties (BRPs) are essential to ensure grid access and system integrity, but they are not necessarily the economic operators claiming sustainability attributes. Their role is comparable to logistics providers in the liquid biofuels sector, being critical to operations, but not certificate holders by default. We recommend that ISCC confirm that shippers and BRPs facilitate transport and should only require certification if they take legal ownership of biomethane and claim its sustainability attributes. Under the current ISCC system and the rules under both RED II and RED III, biomethane producers injecting into the interconnected EU gas grid operate as certified Processing Units. Once they inject the certified biomethane, their sustainability obligation is fulfilled. At that point, the biomethane becomes part of the “big tank” described in Section 3.2.3 and Figure 11, consistent with Implementing Regulation 2022/996. ISCC should explicitly confirm that these producers may sell the associated Proof of Sustainability (PoS) and Guarantees of Origin (GOs) separately from the physical commodity. This is standard practice in many voluntary and regulatory systems, where the sustainability attributes and the physical molecule are tracked independently after injection. Responsibility for ensuring the linkage between the PoS or GO and the physical gas downstream lies with the Trader or economic operator who withdraws or resells the biomethane. These Traders must be allowed to outsource gas transport services to licensed third parties, just as liquid biofuel traders typically rely on third-party logistics providers. ISCC’s own guidance confirms that, once biomethane enters the grid, it becomes indistinguishable at the molecular level. Within this context, mass balancing allows multiple valid and auditable ways to establish linkage between documentation and physical withdrawal. Route to Market believes this linkage should be assessed on a case-by-case basis by Certification Bodies, based on existing ISCC System Documents and RED III requirements. Adding additional certification or licensing conditions for these activities and beyond what RED III requires introduces unnecessary complexity and may create market barriers. The draft guidance may unintentionally limit access to certified biomethane and restrict the ability of Traders without a gas transport license or grid operator status to participate in the Virtual Trading Point (VTP) system. This approach is inconsistent with how mass balance is implemented under Implementing Regulation 2022/996 according to us. Imposing licensing requirements beyond those required under EU law could exclude smaller and cross-border market participants, reduce market liquidity, and concentrate trading power among a few incumbents. That would undermine the objectives of RED III to create an integrated, competitive, and open renewable gas market. ISCC should clearly state that gas transport licensing is not required to participate in mass-balanced trading at VTPs, as long as sustainability documentation is valid and auditable and the link can be evidenced. The guidance does not mention GOs, despite their established use as official instruments in many EU Member States to disclose the origin of renewable gas. While PoS is central to ISCC certification, many actors use GOs for additional disclosure and tracking purposes. It is worth highlighting that a GO is only issued when physical gas is injected into the gas grid. This fact alone can support the evidence that biomethane has entered the mass balance system. We are not suggesting GOs replace PoS, but their inclusion in the ISCC guidance would improve alignment with national disclosure systems and help avoid double claiming of environmental attributes. The adjustments we propose will enhance legal clarity, preserve fair access to the certified biomethane market, and reinforce the credibility and relevance of ISCC certification in an evolving European energy landscape. We appreciate ISCC’s leadership and guidance documentations a lot and Route to Market remains committed to constructive cooperation. | 30 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC EU Mass Balance Guidance Document (v1.0) | Requirement for a trading license: The ISCC Guidance mandates that traders possess a physical gas trading license to participate in biomethane transactions within the EU’s interconnected gas grid. While such a requirement may be appropriate at physical injection or withdrawal points, applying it universally — including to trades conducted at the Virtual Trading Point (VTP) — imposes excessive and unnecessary constraints. This broad application risks sidelining smaller market actors and independent traders, effectively concentrating market access among a few large, licensed entities. Such consolidation could undermine market liquidity and stifle cross-border competition, ultimately hindering the growth and inclusivity of the biomethane sector. Requirements for physical trading within the VTP: The current interpretation of the Guidance imposes constraints on virtual trading within the interconnected gas grid by requiring physical trading activities or licensing—even at the Virtual Trading Point (VTP). The VTP is divided into multiple country level VTPs, and hence it is not practical to move and trade the gas between those country level gas-grids as it is not a European wide system. This approach effectively disregards the foundational logic of the mass balance system, which is designed to operate across a shared infrastructure where the physical connection between injection and withdrawal is abstracted through the grid’s balancing function, not direct physical flows. As such, this interpretation diverges from the widely accepted application of mass balance principles across the gas sector and may hinder market efficiency and compliance flexibility. Proof of ownership and transfer of credits Clarification is needed regarding the proof of ownership and the transfer of credits between Mass balance periods. A UDB balance should be sufficient to proof that the Mass balance volumes corresponding to the physical volumes owned or injected in and withdrawn from the grid. Ownership of the physical gas should be able to be proven when the gas is injected in or withdrawn from the grid. We see no need to show physical ownership while the gas is in the grid, as no economic operator can own physical fractions of the gas in the grid since it is the responsibility of the TSO / DSO to keep the grid balanced so that the grid pressure is maintained. The “flow” of gas in the interconnected gas-grid is not comparable to the transfer of liquid fuels. Guarantees of origin: The role of the GoOs and their connection with the PoSes needs to be clarified to assure traceability and avoid double counting, e.g. between national and coluntary schemes, keeping in mind that the GoO system is not set up in all member states. Further it should be clarified if they can be used as a proof of injection along with other documentation. Guidance would be needed to indicate how produced volumes should be handled that will not have a GoO attached due to a missing set-up as seen in Sweden. How will the UDB be used as a means to proof traceability and avoid double use of volumes. It should include the requirement to add a proof of injection into / withdrawal from the grid, that would serve as proof of the sustainability criteria in the grid when volumes are traded within the UDB. Is there a possibility to include GoO and PoS information in the UDB and will control the threat of double counting in case GoOs are not connected to PoSes in markets that have the GoO system in place. Missing guidance for non-EU grid-gas and off-grid gas There is currently a lack of regulatory clarity regarding the treatment of biomethane injected into non-EU gas grids or produced at off-grid facilities. As international trade in renewable gases—such as imports from the United States—continues to expand, this absence of guidance creates significant uncertainty for market participants. Without clear rules, there is a risk that credible and sustainable supply chains, which rely on robust third-party traceability systems, may be excluded from recognition. This could undermine both market confidence and the broader goals of accelerating the global transition to renewable energy. Our understanding is that the UDB will take this type of scenarios into account and ISCC could provide further guidance on how to account non-EU-grid gas and off-grid gas into account. We urge the ISCC to establish a new working group that includes a diverse representation of biomethane and Bio-LNG and hydrogen stakeholders to reassess the proposed EU Mass Balance Guidance Document. To ensure that biomethane flows can continue to be traded in compliance with the Renewable Energy Directive (RED) III rules, it is essential to engage in further discussions regarding the requirements for virtual trading points and gas trading licenses. | 30 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC EU Mass Balance Guidance Document (v1.0) | Feedback: Mass Balance Guidance Document Industry: Collecting Point - Lost in Translation? - As a Collecting Point we view our operations are fully aligned with Article 19 of Implementing Regulation (EU) 2022/996, which governs mass balancing. Article 19(2)(b) states: “different raw materials shall only be considered to be part of a mixture if they belong to the same product group, except where the raw material is mixed for the purpose of further processing.” All feedstocks we supply downstream go to final biofuel producers for processing into biofuels like hydrotreated vegetable oil (HVO) or sustainable aviation fuels (SAF). This permits flexible assignment of sustainability characteristics for Annex IX A and B materials, a practice consistently upheld by certification bodies currently across the ISCC value chain. If the guidance’s stricter interpretation is enforced, many collecting points may need to overhaul operations or renegotiate contracts, risking disruption. Article 19(2)(c) further allows identical or same-group materials to be stored in interconnected infrastructure. Our integrated tanks, pipelines, and blending systems comply, supporting efficient feedstock management and traceability. - Aligning ISCC with Industry Norms - The ISCC guidance, supplementing ISCC EU System Document 203, suggests that Annex IX A and B, as distinct RED product groups, require proportional outbound assignment or physical segregation unless mixed at the final fuel production plant. Yet, Article 19(2)(b) only requires mixing “for the purpose of further processing”— NO FINAL PLANT STIPLULATION. This interpretation risks restricting collecting points that blend materials for biofuel production facilities, fully compliant with EU law. Certification bodies have long supported flexible mass balancing backed by contracts ensuring HVO/SAF production next in the value chain. Inconsistent interpretations could give some operators an economic edge based on their auditor’s leniency. - Can We Afford the New Rules?- The guidance’s push for segregation or proportional assignment could burden the industry with significant costs. New storage tanks would demand substantial capital and operational expenditure, while limited dockside warehouse space would complicate logistics. Smaller batch sizes from segregation would increase transport trips, raising greenhouse gas (GHG) emissions and undermining biofuels’ environmental benefits. Losing the ability to blend materials to precise customer specifications (e.g., free fatty acids, metals, sulphur, phosphorus) could hit collecting points’ profits and inflate costs for biofuel producers. We share ISCC’s commitment to sustainability and urge a debate on balancing these goals with economic and environmental realities. How can we achieve this level of tank capacity, traceability and increased transport distances without crippling the industry? - Why Not a Unified Approach?- Differing interpretations between ISCC and schemes like REDcert and RSB create uncertainty. REDcert and RSB seem to offer more flexibility for mixing materials destined for further processing, with less administrative burden. This inconsistency could tempt operators to switch schemes to avoid economic penalties, fragmenting the industry. To ensure a level playing field, ISCC should collaborate with REDcert and RSB to align with RED III and Implementing Regulation (EU) 2022/996. We value ISCC’s rigorous standards and propose a discussion on harmonisation to support operational feasibility. Can we unite schemes standards for a fairer, more consistent framework? - Tackling Fraud Together: Smarter Solutions for All - We applaud ISCC’s drive to eliminate fraud through robust audits and RED compliance. To balance traceability and efficiency, we propose: 1. Clearer Guidance: Update the guidance to reflect Article 19(2)(b)’s exemption for mixing materials for further processing, allowing flexible mass balancing with contractual safeguards. 2. Harness the Union Database: From 1 January 2026, the Union Database will track feedstock origins, certifications, and carbon savings, addressing fraud without segregation or proportional assignment. 3. Robust Contracts: Mandate contract clauses ensuring materials go to biofuel production, verified by ISCC audits. 4. Frequent Audits: We welcome more ISCC audits to ensure compliance without operational overhauls from both CBs and ISCCs own auditors. 5. EU Collaboration: Encourage ISCC to work with the European Commission to refine legislation, minimising interpretive loopholes. - Training Gaps - Despite attending numerous ISCC training sessions, we’ve found no clear protocols within ISCCs training documents on proportional assignment for collecting points handling 0.5 to 25 metric tonne batches in 100- to 500-tonne tanks. This lack of guidance fuels administrative complexity and risks inconsistent auditing. We urge ISCC to develop a comprehensive document detailing proportional assignment procedures and auditor verification protocols to ensure compliance. We value ISCC’s training efforts and seek a debate on providing clearer roadmaps. How can operators comply without a clear guide? - Are Refiners Ready for the Change? - Some collecting points blend Annex IX A and B materials to meet refiners’ specifications before delivery to be able to meet specifications for pre-treating feedstocks. Requiring segregation or proportional assignment at our stage forces refiners to expand pre-treatment blending capacity, raising costs and risking supply chain bottlenecks. There will also be increased administration burden in raising paperwork and contracts. This could limit feedstock supply, threatening renewable energy targets. We support ISCC’s traceability goals but highlight that flexible mass balancing at collecting points optimises feedstock quality and economic value for HVO and SAF production. Let’s discuss how to maintain efficiency without overburdening refiners. | 30 May 2025 |
| Martina | Simpkins | Anew Climate | ISCC EU Mass Balance Guidance Document (v1.0) | Anew Climate Comments on the ISCC EU Mass Balance Guidance Document, Version 1.0 Anew Climate, LLC (“Anew”) is one of the largest climate solutions providers in North America, with an established track record of participating in various North American low carbon fuel sustainability programs. Through Anew Climate Europe (ACE) we are also actively engaged in the European low carbon fuels and biomethane markets. Anew Climate has held ISCC certification since April 4, 2025. We welcome the opportunity to respond to the ISCC consultation on its EU Mass Balance Guidance Document. Collaboration among regulatory authorities, voluntary schemes and industry representatives from within and outside of Europe is key to ensuring that European rules are applied in a coherent manner that avoid creating discriminatory requirements and market access barriers. We appreciate the work that has gone into version 1.0 of the ISCC EU Mass Balance Guidance Document. Multiple parts of the Guidance Document will benefit from additional clarifications and changes before ISCC adopts a final version. We therefore focus our comments here on a few high-level principles and several specific points, with the expectation that another round of stakeholder consultation will follow the issuance of a revised version of this Guidance. One key question of particular interest to Anew is whether the principles established in this Guidance Document are applicable outside of the EU as well. Our current understanding is that this would indeed be the case. Our first three comments are informed by this understanding and our request to avoid discrimination against non-European projects. 1. In the section “Downstream Scenarios: Final Fuel Production to Final User”, it is our view that the ISCC requirements with respect to documents proving the injection of biomethane at the metering point cannot mandate Guarantees of Origin (GoO). There are differences between jurisdictions in Europe and beyond with respect to GoO frameworks. Those differences should not be prohibitive to recognizing pipeline injection of biomethane. While it may be appropriate to designate GoOs as the preferred option, there should be alternatives. We recommend inserting the following passage: “Any final requirements governing ‘confirmation of injection’ must ensure that the differences between, or lack of, explicit GoO frameworks in different jurisdictions across Europe and Third Countries are not prohibitive to recognizing pipeline injection of biomethane. Accordingly, while designating GoO documentation as preferred where available is appropriate, alternative documentation options must be available.” 2. In the section “Biogas/Biomethane Mass Balance System Boundaries”, an assumption that network users are assigned “shipper codes” could create a basis for discriminating against non-European projects. In fact, in jurisdictions where “network users” are not assigned a “shipper code”, the Guidance should allow other means for demonstrating that the economic operator or their agent is able to perform the gas purchase, and sale transactions within the interconnected gas infrastructure should be permitted. This demonstration could happen, for example, by providing an example of historical transactions by the economic operators (or their agents) who intend to engage in biomethane trading or demonstrating through evidence that the necessary engagement with the applicable TSO/DSO for initiating transactions is established. Moreover, limiting swapping biomethane with fossil gas to a Virtual Trading Point (VTP) implies, in some jurisdictions, that producers should become shippers on the TSO grid, considering that VTPs are on the level of TSOs. This is disproportionate and will impose unreasonable burdens on biomethane producers. 3. Regarding Virtual Trading Points, the current text does not adequately address global market realities. We recommend inserting the following text: “Trader A must be in possession of a valid license to receive biomethane from the biomethane injection point or if a licensing process in not in place in the relevant jurisdiction, show that any applicable registration requirements with pertinent authorities for the receipt of biomethane are satisfied, retain a contract with the corresponding infrastructure operation (TSO/DSO) or show that the registration or onboarding process relied on by the infrastructure operation as a prerequisite for the execution of gas transactions (such as a “know your customer” process, online platform registration, etc. which may be used in lieu of direct contracting) is followed, and hold a contract with the biomethane producer.” In addition, we provide the following comments: 1. In the section “Mass Balance Rules: Proportional versus Flexible Allocation”, the Guidance document considers that proportional allocation for pipelines and co-mingled storages in which fuels are often used and/or stored by numerous independent organisations is not possible. In such cases, pipeline-injected biomethane and/or biofuels could be flexibly assigned throughout the value chain rather than based on the “blend” that was input into the pipeline or co-mingled storage. In this context, the formula used for this type of fixed blend ratio should only be based on the principle that the same amount that is injected is then withdrawn from the grid. 2. Regarding Figure 12, “Biomethane Physical Transfer”, the terminology used could lead to unintended interpretations about whether the PoS can move without an underlying physical title transfer within the gas grid. We therefore propose the following text: “for the avoidance of doubt, a conveyance of physical volume ownership must accompany any trade of biomethane, including trades within a Virtual Trading Point. In other words, a biomethane PoS must always be accompanied by a transfer of physical ownership”. 3. Our last comment concerns the following text: “Biomethane producers inject biomethane into the grid at metered points and sell the physical molecule in combination with the accompanying PoS to the immediately following economic operator.” It clearly constitutes an additional market access barrier in comparison to the current practice, as it requires the possession of more licenses for the same economic operator and additional operational duties and responsibilities. This request is not realistic. In biomethane markets today, biomethane producers execute agreements for the sale of gas molecules with non-ISCC certified local traders while looking to assign the attributes to other gas in the grid through PoS transferred to ISCC certified traders, which is permitted under mass balance conventions. The negative unintended consequence of such guidance is market distorting, since biomethane producers will have a much smaller pool of off-takers with whom to negotiate. This will also add inefficiencies and administrative burden to the value chain and may drive the biomethane price up for end-consumers without adequate justification. Overall, we recommend redrafting the section on biomethane (in particular, with respect to VTP processes and representation of the value chain in Figure 12). Should you have any questions about anything we have stated here or require further clarification, please contact Andrew Brosnan at abrosnan@anewclimate.com. Sincerely, Anew Climate, LLC | 30 May 2025 |
| Maria Dolores | Zafra Poves | Repsol Renewable and Circular Solutions SA | ISCC EU Mass Balance Guidance Document (v1.0) | Repsol welcomes the opportunity to provide feedback on this draft guidance. We would like to highlight that the interpretation that has been done of some of the provisions included in Article 19 of implementing regulation 2022/996 adds a level of complexity to the logistics and processing systems for the production of biofuels without enhancing the robustness of the system. Therefore, we suggest introducing amendments that facilitate implementation while maintaining the necessary guarantees to ensure traceability and to comply with existing regulations and continue building a robust system. As further explained in the detailed comments, in cases involving blends of fossil and biofuels, it is important to highlight that—in the specific context of Spain, where the logistics system for fuel products is undifferentiated—it would be inconsistent to impose significantly stricter requirements at the biofuel production site than those applied downstream in the distribution chain. In our view, increasing the complexity of the system may hinder its verifiability and introduce competitive imbalances. This could disadvantage operators who re more rigorous and legitimate, while inadvertently benefiting those with less stringent practices. Furthermore, the added complexity would significantly reduce supply flexibility, leading to higher compliance costs and increased carbon intensity. Mixture of raw materials from different product groups (p.7) The document states that the only exception to the application of proportional allocation for mixtures of raw materials or intermediate products from different product groups is if these are mixed for further processing within the boundaries of the final fuel production plant. We believe this limitation goes beyond what is indicated in Implementing Regulation 2022/996, which states that “(b) different raw materials shall only be considered to be part of a mixture if they belong to the same product group, except where the raw material is mixed for the purpose of further processing;”. We recommend maintaining the same level of flexibility as indicated in the implementing act. Limiting the exception to the boundaries of the final fuel production plant would prevent the flexible allocation in cases where pre-treatment plants, physically separated from the final biofuel production plant, perform the first step in transforming raw material (e.g. food industry waste) into a final biofuel. These cases comply with the implementing act as the raw materials are mixed for further processing. Therefore, we suggest modifying the text as follows: “Physically identical raw materials and intermediate products, or those belonging to the same product group, may be flexibly assigned (Implementing Regulation 2022/996 (IR), Art. 19, 2. (c)). However, physically non-identical raw materials and intermediates must be proportionally assigned. Only one exception remains to this rule, which occurs when materials and intermediates are mixed for the purpose of further processing within the boundaries of the final fuel production plant (IR, Art. 19, 2. (b)). In this case, a flexible assignment of sustainability characteristics to different products becomes possible. “ Sustainable fuels mixed with fossil fuels (p.8) The document indicates that according to Article 19.2.(i) of Implementing Regulation 2022/996, if sustainable fuels are mixed with fossil fuels, a proportional allocation must be made. We find this interpretation limiting and believe the text could be interpreted differently, in line with ISCC 203 “Traceability and Chain of Custody” (p. 80), which states: “The transfer of sustainability characteristics from biogenic to fossil material is not possible even if they have the same chemical composition. However, when biogenic and fossil material are mixed in a joint conversion process (co-processed in conventional oil refineries) or stored jointly in the same physical compartment (i.e., one individual tank or a pipeline), the equivalent amount of the biogenic input can be claimed as sustainable after applying the rules described above.” This more flexible approach is not reflected in the new guidance, which only allows certain flexibility for co-mingled storage or pipeline cases, but not for products stored jointly in the same individual tank. Adopting a different criterion from what is indicated in the system document would unnecessarily increase operational complexity and compliance costs within production sites (e.g., refineries) and put at risk commercial agreements already in place. This is especially relevant for existing production installations where physical segregation is not compatible with the storage capacity available that has already been optimised It is important to emphasise that, in the case of Spain -where the logistics system for products is undifferentiated- , it would be inconsistent to impose much stricter rules within the refinery than those applied downstream in the system. Moreover, this less flexible approach would complicate the auditing process and potentially increase the risk of fraud. Therefore, we believe it is of utmost importance that the criteria set in p.80 of the ISCC system document should be maintained in this guidance, allowing for flexible assignment in cases where the biogenic and fossil fuels are stored jointly in the same individual tank within refineries In addition, current production control platforms within production sites do not always allow for the level of detail required to comply with this less flexible approach. It is therefore necessary to develop or adapt digital tools capable of modelling mass balances with these new criteria. As stated above we are completely against the change of criteria introduced in this guidance. Nonetheless, if this change is implemented, we believe it is absolutely necessary to provide a transitional phase of at least 2 years for economic operators to adapt their internal systems and avoid impacting commercial contracts already in place. Sustainable fuels mixed with fossil fuels: Co-processing case (p.8) When discussing the case of sustainable fuels mixed with fossil fuels, the text in the document references blending points where both sustainable and fossil fuels are intentionally physically mixed to achieve a certain ratio. It states; “At such blending points, both sustainable and fossil fuels are intentionally physically mixed to achieve a certain ratio (blend ratio), e.g. to fulfil a technical specification requirement. In such cases, the term “blend” is used, and the sustainable fuel share is given as a percentage. For example, a “HEFA SAF (sustainable aviation fuel) blend (30%)” consists of 30% biofuel content (neat HEFA SAF) and 70% fossil fuel content. Therefore, a proportional allocation must be made up to and including the blend point.” This does not cover cases where the outcome of the co-processing unit is further mixed with other fossil streams in the refinery. As it is established in delegated regulation 2023/1640, the 14C testing shall be done before the fuels produced through co-processing are further blended with other fossil fuels or biofuels that were not part of the co-processing itself. Therefore, in these specific cases, we understand that the flexible allocation should be applicable and we would like to see it explicitly indicated in the guidelines. Similarly, our understanding is that a flexible assignment should be possible in the case of products resulting for an installation that co-processes waste-based inputs that contain a biogenic fraction. Once the biogenic fraction in the product obtained has been determined via the methods enabled in delegated regulation 2023/1640, the bio-share in the product should be considered as part of mixture and a flexible assignment should be allowed. If this is not the case, increased requirements for segregation and traceability can restrict operational flexibility. In some instances, these constraints may discourage the co-processing of HEFA if the economic benefits do not justify the additional costs associated with implementing the new mass balance system criteria, potentially impacting both the availability of SAF and its production costs and final prices. Sustainable fuels mixed with fossil fuels: Co-mingled storage case (p.8 and p.11-13) We welcome the inclusion of certain flexibility in the case of co-mingled storage but regret the artificial limitation introduced to limit the blend proportion of the output to the blend proportion of the input. This limitation would make the delivery of the blend demand to customers unnecessarily complex. This is especially relevant in the case of SAF. Maintaining a proportional allocation reduces flexibility and increases fuel costs, as it prevents assigning certificates based on customer needs. Additionally, regarding regulatory requirements, such as compliance with Refuel Aviation, it also makes it difficult to carry over certificates from one quarter to the next. In the case of Spain, where facilities are connected to a main logistics network with undifferentiated product, we also understand that it is possible to move SAF without restrictions in the consignments, as interpreted from the ISCC system document 203 Traceability and Chain of Custody document, specifically regarding interconnected facilities (p. 83). “Where liquid or gaseous fuels are introduced into an interconnected infrastructure and are subject to the same mass balancing system (i.e. can be considered to be part of a mixture), the respective sets of sustainability and GHG emissions savings characteristics shall be assigned to the consignments entering and exiting the interconnected infrastructure”. This means that the rule mentioned in the guidelines of “what goes in, goes out” should be applied to the biofuel and not to the mixture of biofuel and fossil fuel. This approach would be fully consistent with the treatment of biogas, where ownership of biomethane is transferred virtually, always accompanied by the corresponding Proof of Sustainability (PoS) to ensure traceability. Since Implementing Regulation (EU) 2022/996, Article 19, does not differentiate between biogas and biofuels in this regard, we believe the same mass balance rules should apply equally to both. Therefore, we believe the text should be amended to allow a free allocation and if any limitation is to be imposed it should be the technical specification of the product. | 30 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC EU Mass Balance Guidance Document (v1.0) | Recommend to add examples with mixed feedstock (RDF (bioportion listed in Annex IX part A of the RED), Forest residues (listed in Annex IX part A of the RED), Low-carbon H2 and RFNBO H2). From figure 2, we understand that using RDF as a feedstock to produce a biofuel and a RCF means co-processing? We beleive Bio SAF, RFNBO SAF are missing on Annex II (all upcoming low-carbon fuels will aslo need to be added). Guidance on Carbon14 test is missing (frequence, measurement location). | 30 May 2025 |
| Adrian | O'Connell | EWABA | ISCC EU Mass Balance Guidance Document (v1.0) | Dear ISCC While applauding the high level of work and detail the ISCC's Mass Balance guidance document goes into, we politely suggest there may be an error in interpretation of the permitted allocation methods during co-processing. In the ISCC document, Figure 7 describes an assignment scenario in which the sustainability characteristics of the raw materials are allocated freely to the products in co-processing (so-called "free allocation"). However the Commission's Delegated Regulation ((EU) 2023/1640) is clear in that it gives 3 methods for allocating the sustainability characteristics of feedstocks to the products during co-processing. These are (a) an energy balance method (whereby the fraction of bio energy in the feedstocks is deemed the same as the fraction of the products), (b) a yield method, whereby the share of bio content in the products is measured following a production using known inputs and assuming the production method, parameters and feedstocks stay the same, the bio-yield is assumed to remain constant. And (c) using C14 methods. Article 1 of the DR states this explicitly. Economic operators have a choice of the aforementioned three methods. And these three choices explicitly exclude the “free allocation” described in Figure 7, and we respectfully believe Figure 7 should be modified to reflect the DR. In addition, the text in section 3.1.2. of the guidance would likely benefit from a re-assessment. Establishing a product yield factor (which by definition defines the bio-content of the products), but then freely assigning different bio-yields to the products, in our opinion could be viewed as somewhat incongruous. Thus we politely suggest this section would likely benefit from being further considered. We kindly remain at your availability should you wish to discuss the above matter further, Yours sincerely, Adrian O'Connell, EWABA | 30 May 2025 |
| Anonymous | Anonymous | ENGIE SA | ISCC EU Mass Balance Guidance Document (v1.0) | ENGIE SA appreciates the opportunity to provide feedback on the ISCC EU Mass Balance Guidance Document. We believe that clear and effective mass balance rules are crucial for a level playing field within the biomethane sector. == Physical transactions at the injection and withdrawal points and transactions at the trading hub: We agree with the principle of enforcing the fact that physical gas transactions at the injection and withdrawal points shall be accompanied by the PoS. This aligns with our interpretation of the current mass balance rules. Any other practice resembles book and claim, which contradicts the principle mandated by RED. Additionally, transactions in the gas trading hub must be plausible and possible, regardless of whether a PoS is involved. Without this, a buy/sell swap of biomethane/gas in the trading hub by an economic operator that would never be able to trade gas (such as a biomethane producer or a non-gas trading entity) would resemble a disguised book and claim transaction. In conclusion, given the current regulatory framework, these principles should be applied. Any modifications should be addressed in the next review of the RED. Finally, we would appreciate clarification on whether the "inverse" transactions can be included within the same contract as the biomethane, or if it must be necessarily in a separate gas contract. == Carry Over and Capacity Demonstration: We do not agree with the need to justify having a stock of physical gas in the single mass-balancing facility at the end of the period. This obligation, which applies to the liquid biofuels sector, makes little sense when applied to "grid energy" such as biomethane. We understand that the economic operators should be able to demonstrate the capacity to buy physical gas from the single mass balancing facility at the end of the mass balancing period and that this shall be enough to carry over sustainability credits to the next mass balancing period. In the end, the essential is that an economic operator can take out of the single mass-balancing facility (or sell to another economic operator within the same single mass-balancing facility) no more than what it brings in (or buys from another economic operator within the single mass-balancing facility). We look forward to further discussions and refinements to ensure the effective implementation of mass balance rules. | 30 May 2025 |
| Adrian | O'Connell | EWABA | ISCC Guidance Document – Non-Conformities and Sanctions of System Users and CBs (v1.1) | In brief we recognise the very comprehensive nature of the ISCC's guidance document, in which there are clear steps outlined in instances of non-compliance. However we would like to enquire as to whether or not there are guidelines or controls to counteract a company which has for example been found to be at the highest level of non-compliance by the ISCC, and which tries to continue to operate within the ISCC system using a different name. Possibly this eventuality has indeed been accounted for, but it does not appear to be clearly defined in the guidance. Thank you | 30 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC Guidance Document – Waste and Residues from Food and Food Processing (v1.1) | Section 3.2.3 Biogas/Biomethane Current description of the market is not accurate and does not follow REDII regulations Overview of trading is as follows 1. Sustainable biomethane trading falls into two categories - biomethane with gas grid as transport and biomethane with gas grid as storage. 2. In trades falling under "gas grid as transport" the biomethane is accounted for in the following way, 2.1. Biomethane injection (physical) is defined by the injection report (issued through metering equipment of the DSO/TSO in and reflected in the issuance of a Guarantee of Origin by relevant national authority). 2.1.1. Gas injected into the grid as biomethane is sold and accounted for as gas (all natural gas and biomethane is shared - there is only gas). 2.1.2. Quality analysis takes place at injection - no outturn quality analysis is possible or feasible. 2.2. Withdrawal of gas is done at any connection point connecting the end consumer with the grid, measured by the DSO/TSO who in turn issue invoices for the gas consumed (as gas, irrespective of the quantity of natural gas or biomethane in the withdrawn gas) 2.3. Biomethane withdrawal and the ability to claim consumed gas as biomethane is possible by redemption/cancellation of relevant Guarantees of Origin 2.4. Biomethane with grid as transport requires parties to purchase Guarantee of Origin with the corresponding proof of sustainability originally issued by the producer to the subsequent supply chain actor. 2.5. Completion of transport is finalized with the point of withdrawal (point 2.2) and the cancellation of the GO with the final PoS containing the corresponding sustainability characteristics and is issued to the final user with the point of injection, point of withdrawal and GO/redemption information listed on the proof – linking production (physical gas and injection) with withdrawal (consumption by final user). 2.6. Additional purchases of gas in the grid are not appropriate for this type of transaction. 2.6.1. Biomethane is being allocated to gas which has already been injected and withdrawn. This would mean a VTP purchase of gas would require the gas purchased at that moment to be transported through time to be applied to the biomethane withdrawn by the final user. 2.6.2. Requesting VTP transactions from market participants for "grid as transport" deals, would require market participants to issue invoices and credit notes which net-out (add up to zero). Despite the end result being zero, the issuance of invoices is still accounted for on revenues. This means committing revenue fraud by making trades of gas at a virtual exchange (which is defined as non-physical transactions) to "prove" one is not committing product fraud. 3. Biomethane trades with “gas grid as storage” do require the physical exchange of gas in the grid. 3.1. When transacting biomethane with "grid as storage" a trader has or wants a position of physical gas in the grid, and they are seeking to allocate a portion of biomethane to that physical gas position - then a VTP transaction is required. 3.2. There is no physical withdrawal of gas from the system (redemption of GOs e.g. for EU market), and a measured exchange is required to establish the point in time and the quantity entering or leaving the relevant supply chain actor's mass balance. 3.3. The same applies to physical sales of biomethane into the German market specific case where a Biomethane Balancing Group is present. In this case, the physical gas injected and the sustainability declaration are sold simultaneously and no GO is necessary as the Biomethane Balancing Group supposes the role of the biomethane registries to account for the injection of biomethane. 3.3.1. In this scenario the biomethane is in storage, and the process of exchanging the biomethane follows the VTP structure when exchanged between trading parties or when a withdrawal of biomethane is desired by a final consumer. 3.4. In both of these cases a “green/gray exchange” agreement is required to allocate the biomethane to the relevant gas which is being traded or withdrawn. 4. The above is the process by which the biomethane market can work within the existing framework, is traceable and fits within the requirements of the REDII/III, IR2022/996, FuelEU Maritime and is in line with the future adoption of the UDB. Current mass balance proposal requires market participants to risk other forms of fraud, to allocate additional purchases of gas by bending the fabric of time and space, force biomethane producers into a monopolistic trade relationship with their point of injection (discouraging production) and to impose purchases of gas which function only to further to drive up prices and boost revenues to the fossil industry. This structure is against everything this entire industry is striving to achieve. Please review and adjust the guidance accordingly. | 30 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC Guidance Document – Waste and Residues from Food and Food Processing (v1.1) | - 3.1.1: UCO can also mean oil that renders out of food while cooking? This is not compliant with the description in the material list and the common use of the term - 3.1.1: REDII is mentioned, shouldn’t it be RED III? - 3.1.4 ‘household kitchens may also be points of origins in some countries’, how does this work? Do they deliver a self-declaration? As I understood the waste facility or public container is seen as the PoO. - 3.2.4 Grease traps are not point of origin, the owner is. - What is the difference between brown grease and grease trap fat? - 3.4.3: The composition of food waste very much depends on the type of food. Maybe giving a general composition isn’t the best. - 3.4.4 should households bee seen as point of origin? How does this work with the self-declaration? - Can food processing residues also be classified under food waste? If not, how should they be classified if they do not mainly consist of oil? - Will there be other materials explained in the guidance document? | 30 May 2025 |
| Jana | Vášová | nergy Regulatory Office Czech Republic | ISCC EU Mass Balance Guidance Document (v1.0) | We very much welcome the opportunity to comment on the proposed "ISCC EU Mass Balance Guidance Document" In our comments we focus only on section 3.2.3 Biogas/Biomethane The document makes no mention of the guarantees of origin system. In order to prevent one MWh of biomethane consumed from the gas system from being counted twice, the link between GOs and PoS should therefore be incorporated. If methane (CH₄) molecules are injected into the interconnected gas grid, they cannot be distinguished from fossil molecules and are treated under the same trade rules as fossil gas under the VTP. However, if the trading balance between injection and withdrawal points within the VTP is on a „one gas day“ , but the mass balance is over three months, we acknowledge that these are two different principles, i.e. separating commodity trade from trade with PoS attributes. In this case, we see no difference to the guarantees of origin system under RED III Article 19, which can be characterised by the same simple formula: 'what goes in, goes out'. In our view, the principles for cross-border trade are not sufficiently detailed and we recommend that these rules be described in a very clear manner. We recommend adding a process for cases where the member state in which the biomethane was produced and injected into the interconnected gas system in accordance with the SHARES methodology allocates the produced biomethane for consumption within its territory (VTP), e.g. to fulfil the NECP. To prevent double counting, no cross-border transfer of GO and PoS may be possible in this case. We welcome the introduction of a requirement for traders to hold a gas trading licence within a given VTP. We only note that there is a need to distinguish between a gas trading and balance responsibility licence (trade flow ) and a gas distribution licence (DSO/TSO) (physical flow). | 30 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC EU Mass Balance Guidance Document (v1.0) | 1. General concept of mass-balance & verification of the chain of custody: the verification of the chain of custody should make sure that transactions of biomethane occur between certified economic operators (producers or traders). Consistently, the key the necessary conditions are: a. That all economic operators who trade biomethane are certified (see also point 6a). b. That all transactions ensure the contractual transfer of molecule accompanied by PoS. c. That what an economic operator takes out of the single mass-balancing facility (or sells to another eco-nomic operator within the single mass-balancing facility) does not exceed what it brings in or buys from another economic operator within the single mass-balancing facility. Deficits in mass balances for gas and gaseous fuels injected in a transmission and distribution infrastructure must not occur (see ISCC EU Guidance Document 203, Ch. 4.4.2). d. That at the end of the mass-balancing period, an economic operator is able to demonstrate that it owns, or can take ownership of surplus gas and PoS in the single mass-balancing facility (if relevant). 2. It should be made immediately clear that bioLNG and biomethane belong to the same product group, as they have similar chemical properties, even if they don’t have similar physical properties. This is in line with IR (EU) 2022/996 definition of “product group”. Confusion must be avoided. 3. We recommend drafting a separate Guidance for Biomethane and establishing a dedicated WG within ISCC to address biomethane mass balancing. 4. The “interconnected infrastructure”, which works as a single mass balancing system, is not limited to the “grid” – as it includes LNG terminals and storage facilities – nor to the “EU” territory – as there is no such explicit reference in the relevant Implementing Regulation (EU) 2022/996 definition. We suggest avoiding references to “EU interconnected gas grid” and replacing with “interconnected gas infrastructure” instead. 5. We recommend avoiding references to “virtual transfers”, which may give rise to misunderstandings and divergent interpretations of the system described in this Guidance, ultimately calling into question the principle of the non-separability of the molecule and the PoS. 6. On the requirement for traders to hold a “license”, under para (2) of Section 3.2.3., we argue that there should just be two conditions for economic operators to be allowed to trade biomethane in the single mass balancing unit, and these are: a. being certified under the ISCC or other recognised voluntary schemes; b. having a status of “network users” within the meaning of the Gas Directive (EU) 2024/1788 or relying, via a service agreement, on an agent able to operate as a network user in any of the entry-exit systems within the geographic boundaries of the interconnected gas infrastructure. However, recognising the high complexity and significant variations across Europe, we believe that the de-scription of the underlying physical reality should remain outside the scope of the ISCC Guidance and, more broadly, of the rules set by voluntary schemes. Therefore, to avoid introducing unnecessary and harmful restrictions, a broad range of scenarios should be both acknowledged and accepted. These may include, but are not limited to: When the producer is a shipper and manages the nomination independently and then sells at the hub (or at the withdrawal). When the producer relies on a shipper, as a service provider, for the nomination but keeps the title to gas which it transfers within the hub (or at the withdrawal). When the producer sells directly at the injection point. When the producer sells the molecule to a local shipper, retain the PoS and ahead of the sale of biomethane, purchases from the hub a grey molecule and associates it to a PoS for the sale to a trader. In light of this, the requirement according to which “traders must hold the necessary license to transport gas from the physical injection point to other parts of the grid, including the VTP” results inaccurate and harmful. It should therefore be removed from the Guidance. 7. DSOs and TSOs should not act as “additional verifiers” of mass balance and should not be required to be ISCC- or VS-certified. This would create an unnecessary administrative burden on the entire system. As a general principle, we emphasise the importance of standardizing the documentation that verifies biomethane injection at the metering point. 8. Liquefaction a. In light of the upcoming adoption of the recast Implementing Regulation (EU) 2022/996 and its crucial role in enabling mass-balanced liquefaction, we stress that no new requirement should result in higher factored GHG emissions, as this would be displacing what is currently the most efficient liquefaction pathway. While liquefaction, whether physical or mass-balanced, should be supported by clear and plausible conversion values, these should be evidence-based. b. While the total absence of such values might raise concerns about greenwashing in some cases, the use of virtual, outdated, or groundless default values (e.g. outdated GHG intensity of the electricity mix) would undermine the efficient use of gas infrastructure with the addition of non-existing emissions. In either case, the development of the bioLNG market would be hindered, posing significant and unnecessary challenges to the decarbonisation of the transport sector. c. The quantity of Bio-LNG or biomethane that can be claimed from a plant should be limited to the amount that can physically be processed by the plant, or the maximum daily send-out capacity of the corresponding certified LNG terminal. Capacity should not be thus limited to onloading capacity. d. The BOG liquefaction based on a condenser is not addressed –Is it to be considered as physical or mass-balance-based? Views on how this pathway should be treated be welcome. | 30 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC EU Mass Balance Guidance Document (v1.0) | In the European Union (EU) most of the infrastructures, which are part of the natural gas and LNG logistics, have a physical connection to the network. However, there are also other infrastructures (es: small scale LNG deposits), which are not physical connected to the grid, but which could be part of the interconnected infrastructures with alternative modalities. These plants are important to allow the supply of LNG to the ships and to the road transport vehicles. Furthermore, they could give an important contribution to the decarbonisation of these two sectors if they are considered part of the EU mass balance. According to the current definition of interconnected infrastructure in IR 996/2022 “‘interconnected infrastructure’ means a system of infrastructures, including pipelines, LNG terminals and storage facilities, which transports gases, that primarily consist of methane and include biogas and gas from biomass, in particular biomethane, or other types of gas that can technically and safely be injected into, and transported through the natural gas pipeline system, hydrogen systems as well as pipeline networks and transmission or distribution infrastructures for liquid fuels”. The definition above clearly mandates that the LNG terminal must be connected to the grid, but it does not explicitly prescribe a physical connection, even if it is the easiest way to ensure compliance. Notwithstanding the fact that regulatory requirements do not explicitly mandate a physical connection, in the document under consultation by ISCC there is a clear reference to that requirement to participate in the EU mass balance. However, this approach seems to be in contrast with the ISCCs’ acceptance of the “equivalent liquefaction” model, that essentially assumes that the LNG tanks of a terminal are connected to the grid, even if from a technical point of view: • the tanks are not connected to the grid, as the sole section of the LNG facility actually connected is eventually the regasifier; • the liquefaction of biomethane into BioLNG is not real because there isn’t a real flux of gas from the grid to the LNG tank (in LNG terminals the only real flow is from the tank through the regasification plant to the network). So, if the underlying logic to qualify the regasification terminals as interconnected infrastructures is based on an extensive interpretation which already entails a virtual connection of the LNG tanks to the grid, we would therefore suggest to also extend such an interpretation solely to SSLNG coastal deposits, to ensure a level playing field between small scale liquefaction units/LNG deposits and LNG terminals. For this reason, our purpose is to call for the application of the principles of the “equivalent liquefaction” model to non-interconnected LNG infrastructure. In particular we suggest to ISCC to consider accepting, within the concept of a single mass balancing facility, exclusively small-scale liquefaction units and LNG deposit that are not physically connected to the grid. In this case the connection could be guarantee through a virtual point recognized by the NRA. This approach could ensure the full use of infrastructure that supports decarbonisation, without prejudice to the need to guarantee biomethane and BioLNG traceability along the chain of custody, which could be ensured even if the connection to the grid is not physical, as long as: • the biomethane is physically injected in the grid; • all operators trading the biomethane are certified; • the non-physically connected terminal can guarantee the certified metering of the LNG it manages; • the establishment by the NRA of a virtual point, simulating the connection to the grid, aimed at ensuring that the traded biomethane quantities are tracked, to avoid double counting by registering a withdrawal of biomethane from the grid to the LNG terminal at the VP, corresponding to the initial injected quantity. This mechanism would provide for the traceability of the biomethane along the whole chain without a physical connection, ensuring that all infrastructures available are used for the decarbonization targets. With a specific reference to the text of the consulted document we we would suggest modifying paragraph 3.2.3 (pp. 13-14) as follows: “LNG terminals are part of the interconnected infrastructure system if they are connected to the gas grid. Infrastructure without a connection to the gas grid is excluded from the EU’s interconnected gas grid framework.”; since, from our point of view, the proposed formulation excludes small LNG deposits from the mass balance without any clear regulatory reason. | 30 May 2025 |
| Henrik | von Storch | DHL Express | ISCC EU Mass Balance Guidance Document (v1.0) | We propose to revise the statement that proportional assignment must always be applied at blend point/by trader with storage in section 3.2.2. Traders often use same tanks for different customer batches according to contractual arrangements. It is often not practically feasible store these in different tanks. Therefore, traders will not be able to deliver specific batches to specific customers if proportional assignment is mandatory. In practice this will either lead to construction of more, currently unnecessary, storage tanks or reduced options by end customers to select the sustainable fuel according to their preferences (sustainability criteria, blend ration, etc.). We recommend clarifying that in storage and blending tanks and specifically at airport storage tanks (even if not defined as co-mingled) flexible allocation can always be applied. | 30 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC EU Mass Balance Guidance Document (v1.0) | The ISCC mass balance guidance suggests that biomethane traders must be licensed gas shippers or balancing responsible parties, which, in our view, exceeds the proper role of traders and limits trading activities. In the liquid biofuels sector, traders are not required to own transport assets but can contract logistics experts to move fuels, and the same approach should apply to the gas sector: traders should be allowed to engage licensed gas shippers or balancing parties for physical transport. Restricting this flexibility would create an uneven playing field, disproportionately favouring large market participants (gas suppliers and major oil/gas companies) over other participants, and would stifle the growth of the biomethane market. As traders operating and supplying across multiple countries, making such licensing mandatory would require considerable time and financial investment to set up, ultimately hindering market participation, decreasing liquidity, and slowing down future growth. | 30 May 2025 |
| Jamie | Seymour | BP Oil International Limited | ISCC EU Mass Balance Guidance Document (v1.0) | BP response to public consultation on the ISCC-EU-Mass-Balance-Guidance-Document The team at BP want to express our thanks to ISCC for the collaborative process they instigated post the European stakeholders meeting in October and welcome the opportunity to respond to this public consultation. BP are concerned that rules for mass balancing mixtures of biofuel and fossil proposed in section 3.2.2 of the mass balance guidelines limit supply flexibility, increasing the cost and carbon intensity of supplying the biofuels needed to meet obligations under the Renewable Energy Directive - 2023/2413 (RED) and ReFuelEU Aviation 2023/2405 (ReFuel). Our response suggests changes to the guidance that we believe will help deliver SAF more cost effectively across the EU, as envisaged by the ReFuelEU Aviation SAF Flexibility Mechanism Report. EU member states have shown they have significantly different approaches to implementing articles 30 of the RED and 19 of the implementing act (2022/996). For example Spain allows full flexibility when assigning biofuel molecules within the Exolum system, whereas in the Netherlands C14 testing and molecule tracking of biofuel molecules is required. We recommend that ISCC clearly state in the document that member states may have different mass balance requirements, and where there is a conflict, economic operators must follow the member state’s rules. BP’s comments on specific sections of the guidance document: • Section 2.1, figure one. Clarity is needed on how feedstocks not explicitly listed on Annex IX A, but included in member states advanced feedstock lists (often under Annex IX Ad) will be treated. Including the “x2 multiplier” under “Same RED category” is unclear as multiple counting doesn’t apply to fuel suppliers in all member states. • Section 2.2, figure five. “The blend point” should be defined as the blend ratio at egress into comingled infrastructure as blends of biofuels and fossil materials can occur at multiple points in the supply chain. • Section 3.2.2 Figure nine: Proportional allocation should not be obligatory in this scenario. ISCC document 203 allows for the transfer of sustainability characteristics from biogenic to fossil material where they are stored jointly in the same tank or pipeline. • Section 3.2.2, figure ten. The “what goes in, goes out” concept should track only the amount of biofuel that ingress and egress the pipeline and not the fossil component. The interconnected infrastructure definition in the implementing act includes liquid fuels such as jet fuel. Requiring members of the ISCC EU system to track live blend ratios poses significant administrative challenges and doesn’t align with promoting cost-effective SAF delivery via comingled infrastructure in line with the ReFuelEU Aviation SAF Flexibility Mechanism Report. | 30 May 2025 |
| Geoffrey | Dietz | RNG COALITION | ISCC EU Mass Balance Guidance Document (v1.0) | RNG COALITION welcomes and supports ISCC’s efforts to align understanding across stakeholders regarding the rules of mass balance structures in its ISCC EU Mass Balance Guidance Document consultation. However, the proposed guidance lacks clear definitions for biomethane and puts in place new requirements that will drive up costs and create significant trade barriers for many market participants. We believe a level playing field is essential to enable scalable biomethane uptake across the EU and third countries, which is why we are calling on ISCC to reconvene a biomethane-specific working group. By reopening the working group to a larger, diverse set of biomethane market participants, we can ensure ISCC’s goal of aligning understanding of the mass balance rules while guaranteeing biomethane can continue to be traded in accordance with the RED. The following issues must be addressed to avoid confusion among ISCC EU biomethane participants and unnecessary trade barriers that will hinder biomethane utilization: 1. Limitation of flexible allocation of sustainability criteria via connection of mass balance to the virtual trading point and transport capacity. In accordance with RED, flexible allocation of sustainability criteria is accepted within an interconnected gas infrastructure. Limiting transactions of biomethane to a virtual trading point undermines the current RED criteria. The current practice of mass balance of gaseous fuels in the EU and US (which does not include physical movement of bio-gases in the grid, but allows the allocation of sustainability criteria to any gas quantity in the grid, provided that the allocated sustainability criteria match volumes that were injected) is widely understood and applied within the industry. A proposed guidance that misrepresents the norm creates confusion in the market. 2. Gas trading licenses are not uniform across countries. The proposed guidance currently implies every trading party must hold a “gas trading license”, however, in many countries this type of license does not exist. It is not possible to put in place such a general requirement when no harmonized trade license exists across countries. Further, we believe if this requirement remains, it disproportionately benefits market participants with established gas trading infrastructure and effectively excludes smaller producers and traders without said infrastructure. This setup risks creating an oligopoly, where only players with infrastructure or access to pipeline capacity can buy biomethane, reducing liquidity and price competitiveness. 3. Clarification on applicability to third country grids is needed. The current framing around trading requirements also raises concerns in the context of international biomethane trade. In many countries outside of the EU, equivalent licensing structures may not exist, and applying uniform requirements could unintentionally limit participation and market access. These issues merit further discussion within the working group to ensure that international trading challenges are adequately addressed, and that the framework supports a diverse and competitive market environment. Thank you for your attention to this matter. We are available at your convenience to discuss further. | 30 May 2025 |
| Tim | Hamers | ERGaR - European Renewable Gas Registry | ERGaR - European Renewable Gas Registry | ERGaR (European Renewable Gas Registry) welcomes the opportunity to provide feedback to the ISCC consultation on its EU Mass Balance Guidance Document. Mass balancing is an essential element of trading biomethane with a Proof of Sustainability. Therefore, it is critical clear, transparent and consistently applied rules for everyone to create a level-playing field for all market participants. To create this clarity and align the mass balancing document with the situation in practice at the moment, we would like to provide some suggestions to allow on the following topics: - Allow the use of third parties to trade biomethane Biomethane with a PoS is currently often traded by traders that don’t have the appropriate license to operate in the Virtual Trading Point or gas hub. The trading of the physical gas is in that case outsourced to third-parties with the license. It can be compared to a liquid biofuel trader that outsources its transport of the biofuel. ERGaR believes the use of third-parties for gas transport should be allowed to avoid limiting the market and putting large administrative burdens on biomethane traders. Also the use of so-called gas swaps should be allowed. Therefore, we made a more detailed proposal which can be found as annex to this paper. - More practical implementation of rules regarding biomethane injection A very limited number of players in the market can follow at the moment the scenario outlined in the draft guidance, where ISCC requires the first trader in the value chain to offtake both PoS and gas at the injection point into the DSO network. In practice, companies that can offtake gas at the injection point into DSO network are the local gas companies who are not in the ‘biomethane business’. They are not certified traders and do not trade certificates. Those companies who can trade certificates are usually not set up in all of the local markets and for operational reasons cannot offtake biomethane at the injection point. They can do it only at the VTP. To avoid disruptions on the market it would be beneficial to provide more clarification would help to align the guidance with the situation in practice. A detailed proposal can be found in the annex. A more thorough discussion should take place on the best solution in the medium and long-term. - Clarification regarding bio-LNG ERGaR supports the clarification regarding biomethane liquefaction. However, to reduce discussion on the implementation, it is proposed to clarify in more detail the following terms: o Show the different concepts of liquefaction, being Direct Liquefaction, Grid Liquefaction and Terminal liquefaction , in order to ensure the clear and accurate mass-balancing, calculation of emissions o The inputs taken into account for calculating the "plausible conversion factor and GHG emissions that would have been generated in case of a liquefaction” to increase clarity and trustworthiness on the emissions calculations by LNG plants and LNG terminals o The limits to the amount that can physically be processed by the LNG Terminal (i.e. in form of “re-condensation”) o Relevance of the maximum daily onloading capacity of the corresponding certified LNG terminal for the process We hope these points can be considered when developing the final draft of the mass balance guidance document. Finally, ERGaR suggests to start a more fundamental debate on how the principles of mass balancing can be achieved within the EU interconnected gas infrastructure. Mass balancing is mostly an administrative procedure and it can be debated if this type of mass balancing provides any additional value to the market and energy transition. We would welcome a more thorough discussion at a later stage as part of a revision of this document and other ISCC guidance documents what is the best approach. | 30 May 2025 |
| Beatriz | Álvarez | SARIA International GmbH | ISCC Guidance Document – Waste and Residues from Food and Food Processing (v1.1) | Please find below our feedback regarding ISCC Guidance Document – Waste and Residues from Food and Food Processing (v1.1): UCO: - According to section 3.1.1 of the document, “UCOs are treated as waste under the RED II and are widely accepted as waste by EU Member States with some restrictions. For example, Germany only accepts UCO entirely of vegetable origin.” This part of the document is unclear as there is apparently no direct relationship between the consideration of UCO as waste and the fact that Germany only accepting UCO of vegetable origin. They appear to be different issues and should not be put together. To improve clarity, it is recommended to remove “For example,” and separate the two ideas more distinctly. - According to section 3.1.3, “strict limitations on FFA content are most relevant to biodiesel producers”. Although indeed strict limitations on FFA are relevant for some biodiesel producers, this is not the general situation, as most biodiesel plants have implemented technologies to be able to process high FFA contents. So, the sentence should be changed to highlight that these limitations only apply to some plants: “Strict limitations on FFA content are relevant to some biodiesel producers”. Brown Grease: - The precision in section 3.2.4 that the grease traps may serve several different wastewater producing sites could be improved in clarity indicating whether the greases separated as a first step in an industrial wastewater treatment plant can be considered as brown grease. - It would be useful if section 3.2.6 included information about the plausible amounts of untreated BG generated in the Point of Origin (PoO). - The figure for the example of supply chain (3.2.7) for BG could be modified to improve its clarity and be consistent with the text, as explained below: · It includes “wastewater (WW) treatment plants” and an “industrial BG collection terminal” that are not mentioned in the text, which creates confusion about the elements of the supply chain of BG. These should be either mentioned in the text or removed from the example figure. · Also, it is not clear where the “specialised treatment plants that generate the treated BG” are in the figure neither the type of economic operator that they are (collecting points or processing units). This should be clarified and properly included and placed in the figure according to the classification at the bottom. · For clarity, the biofuels and biogas plants could be included in the figure as processing units before the final product. - According to section 3.2.8, “the sources of the grease trap contents should be randomly sampled, and the specialised treatment plants/processing units should be audited”. Instead of “should”, “shall” must be used both for the randomly sample of the sources and the audits of the specialised treatment plants/processing units. For greater clarity, it is also recommended to define what the “sources of the grease trap contents” mean and, if appropriate, specify it refers to “PoO”. Food Waste: - The precision in 3.4.1 that all wastes –not only food waste in the framework of ISCC certification– must be unsuitable for other non-energy uses seems out of place. The wording should be more precise, e.g., “Under ISCC EU, food waste can only be considered as waste material if it has no further use (other than for energetic applications) in other markets”. - The document states in 3.4.6 that “For restaurants and food processing facilities, the ratio between input raw ingredients and resulting food waste must be checked using historical data such as production reports, invoices, waste disposal or collection rate, etc.” More detailed and practical documentation templates developed by ISCC would be highly beneficial. Additionally, clarification would be needed on how restaurants are expected to implement these measures in practice, as well as on the specific requirements that collecting points would need to meet. - Although included in the example of supply chain in 3.4.7, it is not described if the food waste collecting center does any treatment to the input material or any indications of plausible yields of output material that will be used by the biogas/biomethane plant or the biorefinery plant. We recommend including this information. - In section 3.4.8, a precise reference to where in the EU legislation the separation of food waste streams from businesses (restaurants, shops) and households is defined would be advisable, together with a mention that national legislation may apply. - The paragraph in section 3.4.8 on the differentiation of industry food waste oil and crude oil (food waste) together with the examples 1 and 2 are not clear and create confusion, as they are not consistent with the example of supply chain in 3.4.7. Therefore, we propose removing the first paragraph of page 23 and the examples 1 and 2. If the examples remain, consistency with figure in 3.4.7 should be sought by adding the “food waste collecting centre or pre-treatment” in example 2 and the biogas or biorefinery plant at the end of the chain, and by removing the mentions to intermediate products. Also, retailers (e.g., supermarket) could be added. Sewage sludge: - According to section 3.5.2, sewage sludge can be converted into various types of biofuels, being the most established route anaerobic digestion to produce biogas, that can be upgraded to biomethane. Other mentioned pathways are hydrothermal liquefaction, pyrolysis and gasification. However, the example of supply chain for the sewage sludge in section 3.5.7 includes HVO and FAME as final fuel, which is not consistent with the pathways in 3.5.2. This inconsistency should be corrected. | 29 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC EU Mass Balance Guidance Document (v1.0) | Dear ISCC Association, We appreciate the opportunity to share with you our feedback on ISCC EU Mass Balance Guidance Document. Clarifications on permissible chain of custody options are absolutely necessary and timely. On this basis we welcome the publication and generally receive its content well. Physical segregation is described in a way that reflects market conditions and well-established market practises. Unfortunately, we cannot state the same with respect to mass-balance, in particular for the sections dedicated to biogas/biomethane and bioLNG. We, therefore, strongly recommend treating these in a separate document to avoid the continuation of confusion and misleading interpretations, or at least giving more emphasis to the differentiating features. The guidance should build on the definition of “interconnected infrastructure” in article 2 of Implementing Regulation 996/2022 and accept that EU law recognises such interconnected infrastructure, including the entirety of connected LNG terminals, as a single mass balancing facility. As gaseous biomass fuels and LNG share similar chemical characteristics, once mixed in the same single mass balancing facility, the two become formally indistinguishable and should therefore be treated as such, merely based on accounting evidence. As ISCC recognises, a fixed mixture ratio can be summed up in the simple formula “what goes in, goes out”. This is pretty much what economic operators active in this space must ensure. Such verification should occur exclusively at the point of injection of and at the point of withdrawal from the single mass-balancing facility. In this context we note that the word “blend” is inappropriate. Blending does not happen in case of homogenous products but rather to enhance the quality of a given fuel. In addition to these general considerations, there are a few specific points in section 3.2.3 which may benefit from additional clarity: - The definition of LNG terminal should refer explicitly, exclusively and univocally to the relevant definition contained in art. 2 of DIRECTIVE (EU) 2024/1788 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL. The same should hold true for any term identifying a gas or an LNG infrastructure; - Referring to biomethane trading once this has been injected in the single mass-balancing facility as “virtual” is unnecessary and misleading. The only key and important note here should be that there is no trade of biomethane when a molecule of CH4 is sold without a Proof of Sustainability and vice versa; - Where the text says that credits may be carried over from one mass-balance period to the next, provided the economic operator is able to demonstrate that an equivalent amount of gas remains in stock at the end of the three-months mass-balance period, it must be clear that the stock may be evidenced within ANY part or component of the single-mass balancing facility; - In the description of the requirements necessary to prove the chain of custody within the single mass balancing facility, it should be clear that all economic operators should be certified entities; - The section on the virtual trading point is unnecessary and may be misleading, therefore it can be easily disposed of. The single mass balancing facility contains more than one virtual trading point. The delimitation of each of them is absolutely irrelevant for the verification of the simple formula “what goes in, goes out”; - The references to licensing requirements are factually wrong and at best imprecise. The section on physical transfer should make no reference to licensing requirements. In fact, these are not relevant for the scope of voluntary schemes and any imprecise and/or incorrect reference may simply lead to unintended consequences. Who ships the gas is irrelevant in the context of the verification of the chain of custody, the service being outsourceable by an economic operator to a third party which has the rights and the operational competences necessary for physical shipping activities in a gas system; - The reference to “any “inverse” transaction, i.e., where biomethane is notionally swapped for fossil gas, may only occur at the VTP” is unclear and at best redundant. How the trading of biomethane should happen within the single mass balancing facility is sufficiently covered in other sections; - With respect to mass-balanced liquefaction the limitation to the maximum liquefaction capacity should be linked exclusively to the maximum outgoing capacity of the terminal; - Finally, it is unclear whether liquefaction happening on the back of the re-condenser capacity of a terminal should be deemed as physical or mass-balanced liquefaction. Making this clear would help identifying the carbon intensity attributable to the different liquefaction path and base it on the actual evidenced emissions. While we hope that our comments and reflections will be taken into account, we remain available for clarification you may deem necessary to complement our comments. | 29 May 2025 |
| Jill | Talbot | Phillips 66 Limited | ISCC EU Mass Balance Guidance Document (v1.0) | Phillips 66 has global offices which hold ISCC EU certifications for Trader with Storage, co-processing and processing units. As such we welcome the opportunity to comment on the ISCC EU Mass Balance Guidance as this is a much-needed document to address the inconsistencies across EOs and auditors on the interpretation of the mass balancing rules. Having thought and received guidance from ISCC on several points we feel we understand the correct interpretation of the rules however, this is unclear from the current draft guidance & examples and there is a risk of misinterpretation by auditors, therefore clarification is required on the following: (1) Based on the statement ‘whether the raw materials, intermediate products, and final fuels are physically identical or can be classified within the same product grouping’ our understanding is that as long as the raw or intermediate materials in the mixture are physically the same, they can be freely allocated even if they are not of the same Product Group. The guidance needs to make it clear what the criteria is for ‘Physically Identical’ for raw materials and intermediate materials. While there is reference to Annex II for final fuels as well as a definition on page 7, there is no distinct set of criteria for what ‘physically identical’ is for raw and intermediate materials. Having similar densities within a tolerance range seems to be appropriate to make this determination but then it is unclear how materials could not be Physically Identical but still be in the same Product Group. We would also suggest that Figure 2 be revised to indicate OR between the ‘Physically Identical’ and ‘Same Product Group’ boxes rather than NO to reflect the statement ‘Physically identical raw materials and intermediate products, or those belonging to the same product group, may be flexibly assigned’. (2) It is our understanding that the RED category determination will be based on the UDB list of materials and that intermediate materials will be categorised based on the raw material they were made from. This should be stated clearly in the guidance document. We also have feedback on the implementing regulation that we would like to see ISCC address with the EC. While we understand the concerns that led to the new mass balance rules, some of the requirements are challenging to implement in practice. • The framework acknowledges that sustainable fuels lose their molecular “feedstock identity” during the production stage and so flexible assignment is allowed for Final Fuels produced under the mass balance chain of custody model but it would seem the same logic could be applied to intermediate materials. In fact the ISCC list of materials groups intermediate materials with Final Fuels separate from raw materials. • Proportional assignment for materials that have been physically mixed is administratively burdensome as materials are constantly moving in and out of the mixing location and so determining what the proportion is at any given time is difficult. This constantly changing mix would also make it difficult to predict what proportion of materials you will have at a given time in the future and this would impair the ability to agree to sales in the future particularly if the buyer is only looking for one specific raw material. This leads to an inefficient use of storage space as small quantities may be physically separated in order to avoid proportional assignment. | 29 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC EU Mass Balance Guidance Document (v1.0) | Good Afternoon All, Below is our feedback/response to the ISCC EU Mass Balance Guidance Document New proposals outlined in 3.2 (in particular 3.2.2) have a detrimental effect and our rationale for this is as follows: 1. Increase in cost will be passed to airlines 2. Inability to deliver SAF in most cost-efficient way possible 3. SAF supply chain is still in its infancy to cope with any immediate change to guidelines 4. Increase in reporting requirements/documents on fuel suppliers and airlines Any questions do not hesitate to reach out | 29 May 2025 |
| Sascha | Wüstenhöfer | Shell | ISCC EU Mass Balance Guidance Document (v1.0) | We thank ISCC for its work compiling the ISCC EU Mass Balance Guidance document and we very much appreciate the opportunity to give feedback as part of the public consultation. We have the following general suggestions for the document: • Provide links between the scenarios on assigning sustainability characteristics from the ISCC EU 203 document to the scenarios in the guidance document to clearly address the “ambiguities surrounding scenarios” mentioned in the introduction. • Include legal references to the applicable articles and definitions from Implementing Regulation (EU) 2022/996 (in the following the IR) (e.g. put legal references in footnote). • Throughout the document, examples should refer to both road and aviation. We have the following suggestions for specific chapters: Chapter 2 Mass balance: The Basics • Explain the concept of “being part of the mixture” as this is at the core of the mass balance requirements according to Art. 19 IR (i.e. materials being part of a mixture=flexible assignment of sustainability characteristics possible; materials not being part of a mixture = proportional assignment required). • Figure 1: Product group definition only covers biofuels, bioliquids, non-gaseous biomass fuels but should also cover gaseous biomass fuels, and LNG. • Explain and distinguish the concepts of i) assigning sustainability characteristics to outgoing batches of purely biogenic materials, ii) assigning the bio-share to a blend of biogenic and fossil material, iii) assigning sustainability characteristics to a blend of bio and fossil material, iv) assigning sustainability characteristics to fuels taken out of an interconnected infrastructure (e.g. gas grid, liquid fuel pipeline) or (comingled) storage, and v) the determination of the share of biofuels in co-processed fuels. • Include a definition of blending, such as “mixing of neat biofuel with fossil fuel”, indicating that the blend point is exclusively the point where neat biofuel is mixed with fossil fuels. At the blending point a certificate of analysis is usually available as evidence. Storing finished grade blends with different physical bio content in the same tank downstream to the blend point should not be considered blending. • Page 5: Clarify the sentence “Physical identity may be assessed by referencing the most current version of the ISCC material list.” Add examples. Are there other options available (as indicated by the word “may”)? Chapter 2.1 Mass balance rules from feedstock to final fuel production • Page 5: “Density tolerance zone of 2-5%, depending on the material”. Unclear, how the tolerance differs per material. Giving a range seems impractical to verify. Suggestion: Only refer to max. tolerance of 5% irrespective of material. • Figure 2: On boxes “sustainable-only” and “co-processing”: We understand the intention in differentiating the two boxes to distinguish between “biogenic-only” and “co-processing” (i.e. simultaneous processing of biogenic and fossil material). In both cases the producer is still allowed to process both sustainable and non-sustainable biogenic materials, the wording seems to imply that this is not the case. This should be clarified. The word “raw material” may be used like on the left-hand side. In the sense of the IR this is referring to the sustainable input. • Page 6: “all outgoing batches must reflect an identical ratio as the mixture contained in the tank.” Clarify if this means that ISCC is requesting tank-specific mass balances (not requested by RED/Implementing Regulation). Chapter 2.2: Mass balance rules after final fuel production to final user: • General: Separate (in different sub-sections) and explain the concepts of i) blending (including a definition of the blend point, neat biofuel producer), ii) (co-mingled) storage and iii) interconnected infrastructure (i.e grids and pipelines). • Page 7: “Sustainable fuels produced under mass balance chain of custody model can be considered as physically identical”. It needs to be explained that the fuels still need to be differentiated according to the type of fuel as specified in the ISCC material list (e.g. Biodiesel, Bioethanol, HVO, etc.). • Page 8: Art. 19, 2. (i) IR refers to the place where (neat) biofuel is blended with fossil fuel (“where biofuels (…) are blended with fossil fuels”). The IR does not suggest that this “in principle, is valid up to the final user”. Proportional assignment of the bio-content is required at the blend point, but not downstream. Within the bio-content, flexible assignment of sustainability characteristics can be applied. This also needs be reflected in figure 4. • Page 9: “a proportional allocation must be made up to and including the blend point.” See above, reference to “up to” does not seem correct. • Chapter 3.2.2: Mixing of fuels: Blend point, pipeline and co-mingled storage • Last paragraph in chapter 3.2.2: Suggest adjusting the wording to better distinguish and explain the different options. Include examples to clarify that the options apply for all transport sectors. Examples for both road and aviation could be provided. | 29 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC EU Mass Balance Guidance Document (v1.0) | Thank you for the opportunity to comment on the ISCC Mass Balance Guidance Document v1.0. We (a large airline group) welcome efforts to clarify mass balance implementation, however we have significant concerns regarding the mandatory proportional allocation approach for sustainable aviation fuel blends outlined in Chapter 2.2 and Figure 4. We are concerned that the proposed requirements may inadvertently create barriers to industry operations and SAF deployment, as they appear to go beyond what is explicitly required by EU RED II or the Implementing Regulation 2022/996. The proposed guidance mandates proportional allocation for all fuel blends, as shown on page 8, Figure 4. This approach creates fundamental commercial distortions in aviation fuel markets where customers pay premiums specifically for SAF sustainability attributes. Consider this (simplified) scenario: • Customer A contracts for 100MT of HEFA SAF at €1,500/MT premium • 100MT HEFA SAF is delivered to shared blend tank with 900MT fossil fuel (creating a 10% blend) • Under ISCC's proportional allocation requirement: o Customer A lifts 100MT but receives only 10MT of "sustainable" fuel benefits o Remaining 90MT of Customer A's paid-for SAF benefits are allocated to non-premium customers o Customer A pays €150,000 premium but receives only €15,000 worth of sustainability benefits The operational reality is that depot operators will only be able to guarantee a customer receives all of the SAF they have paid the premium for by maintaining a dedicated tank with the blend held exclusively for that customer. However, tanks cannot be brought into service only when the premium paying customer (who will be one of many users) sends a road tanker, train or vessel to be loaded. This creates significant operational inefficiencies and cost burdens that will ultimately discourage SAF deployment. We question whether this proportional allocation requirement has proper regulatory foundation. Implementing Regulation 2022/996 Article 19(2)(i) states that "information about the sustainability and greenhouse gas emissions saving characteristics assigned to the blend shall correspond to the physical share of the biofuels, bioliquids or biomass fuels in the blend". This provision addresses the information assigned to the blend itself, not the allocation methodology for individual withdrawals from that blend. There is a critical distinction here that appears to have been overlooked. RED II Article 30(1) establishes the core principle that "the sum of all consignments withdrawn from the mixture be described as having the same sustainability characteristics, in the same quantities, as the sum of all consignments added to the mixture." This "what goes in, goes out" principle requires overall system balance but does not mandate proportional allocation at every intermediate mixing point. Furthermore, ISCC EU 203 Section 4.4.1 establishes that mass balance allows "physical mixing of sustainable and non-sustainable materials" with flexible assignment of sustainability characteristics, provided overall balance is maintained. The regulation does not mandate proportional allocation at individual mixing points - this requirement appears to be newly introduced in the guidance without regulatory precedent. The guidance document must remain subordinate to RED II and cannot impose requirements beyond those in the underlying regulation. Any sector-specific restrictions require explicit legal basis. EU regulatory practice requires that implementing measures be proportionate to their objectives. The current proposed approach may fail this test by imposing disproportionate administrative burden, limiting operational flexibility without any corresponding environmental benefit, and creating further barriers to SAF deployment contrary to EU climate objectives on what is the most difficult sector to decarbonise. It would inevitably lead to a reduction in SAF adoption in the aviation industry and/or higher costs for the consumer neither of which is in anybody’s interests. While we support the objective of clarifying mass balance rules, the current approach to proportional allocation creates unnecessary barriers to SAF deployment without clear regulatory justification. We urge ISCC to reconsider this provision and align the guidance with both RED II flexibility principles and aviation industry operational realities. We welcome the opportunity for further engagement on these critical issues and look forward to a constructive dialogue that supports accelerated SAF deployment while maintaining regulatory compliance. | 29 May 2025 |
| Liesbeth | Smitten | AIB - Association of Issuing Bodies | ISCC EU Mass Balance Guidance Document (v1.0) | AIB welcomes the opportunity to contribute to the public consultation and appreciates ISCC's comprehensive approach to traceability and mass balance in the biomethane supply chain. However, in the chapter “Biogas/Biomethane. Mass Balance System Boundaries,”the current text overlooks an important aspect related to energy source traceability, the use of Guarantees of Origin (GOs). As defined in Article 19 of Directive (EU) 2018/2001 (RED III), GOs are the official instrument to disclose the origin of energy to end consumers and are essential for ensuring the integrity of energy claims across the interconnected gas grid. Excluding reference to GOs in the context of biomethane transported via this grid opens the risk of double-counting, particularly where GOs are issued and used for disclosure alongside separate mass balance certification schemes. 1 PROPOSED WORDING ADDITION We propose that the following paragraph be added to the section titled “Biogas/Biomethane. Mass Balance System Boundaries”: “Where issued for the respective consignment of gas, Guarantees of Origin (GOs), as defined under Article 19 of Directive (EU) 2018/2001, should be used to support energy source claims related to the consumption of biomethane. This ensures transparent and consistent disclosure and helps avoid double-counting of renewable attributes between the target accounting system (following mass balance tracking rules) and the energy disclosure system. The traceability of physical flows and the tracking of attributes must be aligned, especially when GOs are used in parallel to mass balance certification. This prevents that the same environmental attributes are double counted in a parallel system.” This input reflects the technical expertise of AIB in managing GO systems. It may represent not all members' views, as some may not have decision-making authority on this topic. 2 JUSTIFICATION • The RED II delineates GOs as the only instrument for disclosure of the source of the energy supplied to final customers; thus, their omission could lead to regulatory inconsistencies. • When GOs are issued for biomethane, they represent a claim pathway which should not be separated from mass balance chain of custody tracking. Ensuring consistent claims for chain of custody tracking across multiple purposes is critical to market integrity. • GOs may be used in multiple chain of custody tracking mechanisms, including book-and-claim and mass-balancing. They are a unique Transferable Instrument that Entitles for a Claim, which should be included in the applicable chain of custody tracking method, in this case mass balancing. • This clarification supports harmonisation with the EU’s energy disclosure framework and reduces the risk of double-counting of the same biomethane volume, which should not lead to separate claims via GOs and via mass balance claims. • This proposed amendment is aligned with the latest AIB position paper on GO System Improvement Pillars (2025), which highlights the importance of integrating the GO framework into broader energy attribute tracking systems. 3 ABOUT AIB The Association of Issuing Bodies (AIB) is a non-profit international organisation that develops and maintains the European Energy Certificate System (EECS) standard. AIB enables the reliable cross-border transfer of energy attribute certificates such as Guarantees of Origin, in line with Article 19 of the Renewable Energy Directive (RED II). The AIB comprises national issuing bodies from more than 30 countries across Europe and it operates a central IT hub to facilitate the secure exchange of certificates between national registries. More information is available at www.aib-net.org. | 29 May 2025 |
| Robin | Askey | Double Helix Tracking Technologies Pte Ltd | ISCC EU Mass Balance Guidance Document (v1.0) | I would like to challenge the guidance in the mass balance guidance document regarding 3.2.3. It is an unrealistic requirement for all of the trading entities to 'be in possession of a valid licence to receive biomethane from the biomethane injection point, retain a contract with the corresponding infrastructure operation (TSO/DSO)'. Only very few traders will have this license, or be able to obtain this license, and in a lot of cases this will become a huge barrier to trade in the biomethane sector, with only a fraction of the traders being able to operate in alignment with RED III. | 29 May 2025 |
| Anonymous | Anonymous | STX Commodities B.V. | ISCC EU Mass Balance Guidance Document (v1.0) | At the end of April, the ISCC EU Mass Balance Guidance was published for public consultation. The document is the end product of the Mass Balance working group, initiated at the ISCC EU Stakeholder Meeting, held on the 8th of October 2024. During this stakeholder meeting, a request from the industry was put out to provide more clarification on the mass balancing rules, of which the document is the result. This document is a response to consultation, addressing the concerns, clarification requests and changes STX Group would like to see in the document. The topics will be addressed by different biofuel and biomass fuel covered in the guidance document. As a general remark we would like to mention that even though we appreciate ISCC´s efforts to clarify uncertainties, the issuance of ISCC guidance instead of an amendment of the existing ISCC standard 203 bears a tremendous risk of legal uncertainty as a guidance document is not legally binding but may be made binding by auditing practice. A clarification within the ISCC 203 standard itself would be preferable, especially as we understand from the published consultation processes that the guidance is meant to be discussed with the European Commission STX’s understanding is that if a guidance document is issued by ISCC, such guidance should per se only state clarifications, but in no case interpret or alter standard requirements that are open to legal interpretation. Especially not if such guidance interpretations/alterations could be at the disadvantage of certain market players. Otherwise, there is a significant risk that auditors will have a “choice” to follow the guidance or not and that there could be allegations against ISCC and market players using ISCC that they establish business standards and practices beyond the applicable legal framework. Biofuels/ Raw Materials/Refined oil Definition of Physical Identity of Materials Point 2.1 Mass Balance Rules from Feedstock to Final Fuel Production of the draft guidance states that “Physical identity may be assessed by referencing the most current version of the ISCC material list “ The term “physically identical materials” needs to be defined clearly. Whilst the tolerance zone, density and Lower Heating Value (LHV) are clearly defined with a tolerance zone of 2-5%, the dependency on the material introduces an element of uncertainty. The absence of a clear and enforceable definition may result in interpretative inconsistencies, potentially undermining the integrity of material classification and traceability systems. Criteria for product groups Point 2.1 “Mass Balance Rules from Feedstock to Final Fuel Production”, Figure 1: “Criteria for product groups” of the draft guidance states “similar chemical characteristics and similar heating values.” It is imperative that the term “similar chemical characteristics and similar heating values” be defined with greater specificity and technical rigor within the applicable regulatory or certification framework or be defined as being subject to auditor approval. The absence of a clear definition may result in interpretative inconsistencies, potentially undermining the integrity of material classification and traceability systems. The methodology and parameters for the determination of the Lower Heating Value (LHV) specifically of raw materials must be explicitly and comprehensively articulated. Raw materials: Physically mixed Point 2.1 “Mass Balance Rules from Feedstock to Final Fuel Production”, figure 2: “Assignment of sustainability characteristics raw material to processing to final fuels” of the draft guidance states the following: “Raw materials: Physically mixed” and “Note: Geographical boundaries: stored in the same interconnected infrastructure, processing or logistical facility, transmission and distribution infrastructure or site” It is in the legitimate interest of the operator that any physical mixing operation carried out within its premises be deemed to include, for certification and verification purposes, the mixing activities executed onboard vessels under its operational control. This approach aligns with the principles of operational continuity and traceability and should be recognized as part of the certified supply chain under the applicable scheme. The proposal here would be to, upon the mode of transport connecting to the interconnected infrastructure or another mode of transportation, the vehicle or tank be considered part of the interconnected infrastructure, with the condition that physical goods movements must take place to avoid jetty kissing. This evidence should be checked during the annual audit of the economic operator. Sustainable fuels: Physically mixed Point 2.1 Mass Balance Rules from Feedstock to Final Fuel Production”, Figure 4: Assignment of sustainability characteristics processed fuels to final use” if the draft guidance states the following: “Physically mixed” and “Note: Geographical boundaries: stored in the same interconnected infrastructure, processing or logistical facility, transmission and distribution infrastructure or site” It is in the legitimate interest of the operator that any physical mixing operation carried out within its premises be deemed to include, for certification and verification purposes, the mixing activities executed onboard vessels under its operational control. This approach aligns with the principles of operational continuity and traceability and should be recognized as part of the certified supply chain under the applicable scheme. Chain of Custody Methodology Communication alongside the supply chain Point 3.2.1 “Fuels Produced under Mass Balance vs. Physical Segregation” of the draft guidance states “However, this clarification presupposes that the chain of custody model (“mass balance” or “physical segregation”) shall be indicated on the Proof of Sustainability (PoS).” The mechanism through which the chain of custody is to be implemented—specifically whether via physical segregation or mass balance—must be clearly established and communicated and should not be subject to or stated in a mere guidance document. The lack of clarity on this aspect poses a risk to both regulatory compliance and certification validity, particularly in multi-operator supply chains. Currently, the “ISCC Proof of Sustainability (PoS)”-Template does not include the applied chain of custody model as a mandatory field. The “Nabisy Proof of Sustainability (PoS)” system does not reference the chain of custody model at all. To ensure transparency and auditability there needs to be a clear indication on how to proof/verify the chain of custody model that a supplier has applied. While STX agrees that there is a need to specify the chain of custody model somewhere in the documentation, the guidance itself is not the correct instrument to even address this topic. While ISCC could potentially adjust its own template, it cannot adjust the Nabisy template or templates of other voluntary schemes. This specific topic should therefore be addressed towards the European Commission in a separate line to ensure that the European Commission establishes harmonized and clear and unambiguous rules for all voluntary systems. Chain of Custody Methodology and scenario 5.1 application Point 3.2.1 “Fuels Produced under Mass Balance vs. Physical Segregation” of the draft guidance states that “Consequently, this description clarifies scenario “5.1 Biofuels with raw materials from different product group are kept physically separated” within the ISCC 203 “Traceability and Chain of Custody. For such cases where sustainable fuels are produced under physical segregation scenario 5.1 remains applicable.” Yet, to apply this logic, it is essential that the chain of custody model applied (whether mass balance or physical segregation) is clearly and explicitly stated in the Proof of Sustainability (PoS) or elsewhere and this declaration must serve as necessary and sufficient evidence to determine whether Scenario 5.1 is applicable. Yet, as noted before, the guidance is not the correct document to address or to solve this issue. Biomethane Chapter 3.2.3 of the ISCC EU Mass Balance Guidance Document aims to provide further clarification on how the biogas/biomethane mass balance principles are intended to be used. The main clarification focuses on Implementing Regulation 2022/996 (IR, Art. 19, 2. (d)). Single mass balance The single-mass-balance principle for interconnected gas infrastructure is laid down in RED and the Implementing Regulation 2022/996. ISO 22095 defines a mass balance model as a “chain of custody model in which materials or products with specified characteristics are mixed with materials and products without some or all of these characteristics resulting in a claim on all of the output, proportional to the input”. Since all volumes that are injected into the grid and can, in terms of molecules, no longer be separated from each other, physical traceability is therefore not possible in the grid. The mass balance definition clearly shows that physical traceability is not necessary within the mass balance, but only upon injection or withdrawal, with the reports (either as an independently verified report or for EU contexts or another physical link to account for the mass balance). Within the grid, until withdrawal of the bio volumes are allocated on a pure accounting basis, as the physical volume of gas (combination of fossil natural gas and biomethane) is either in the grid, requiring withdrawal, or has been withdrawn already by the end client who seeks the ability to classify the gas withdrawn as biomethane (with a proof of physical link). Limiting transfers to licensed parties to VTP transfers is neither foreseen nor in line with applicable law. If relevant European laws consider the interconnected gas infrastructure as a single mass balance, ISCC or an ISCC working group are legally not entitled to limit transfers within this mass balance. Notwithstanding the question of the legal quality of the guidance, ISCC, whose “legislative competences” are conclusively laid down in the Implementing Regulation 2022/996, is not entitled to establish trading rules that limit the single-mass-balance-principle. Moreover, any limitation of participating in the single mass balance that is not explicitly stated in the law (here: limitation to parties with licenses and transport capabilities) is highly likely to violate EU anti-competition law principles (Art. 101, 102 TFEU) as it creates market entrance barriers, and oligopolist structures and thereby not only distorts the market but also discriminates against current market participants. Off-Grid and extraterritorial grids The guidance unfortunately does not include two key elements addressed in the ISCC 203 system document, namely how: Off-Grid installations and handling of the regulation currently not covered - guidance is needed. Grids in other countries outside EU (E.g. US) are not covered in this guidance - or how they should be treated The proposed approach by STX is to clearly define what the differences are between the EU and extraterritorial grids, and therefore what kind of evidence is accepted to prove the methods of mass balancing in these interconnected grids which comply with the ISCC and REDII guidelines. This clarification is also requested when biomethane is imported from outside the EU grid through interconnected pipelines, and what is required to fulfill the mass balancing criteria. This can, for example, be the same as the scenario described (in this particular case where VTPs are absent) or by defining how the mass balancing can be guaranteed to conform to REDII guidelines as per the ISCC 203, for example by allowing the auditors to determine the criteria for the physical link. Physical biomethane trading When describing the scenario in figure 12 of the guidance, the condition is set that the injected biomethane needs to be sold bundled with PoS to the immediately following economic operator, with the TSO/DSO records allowing for verification of the mass balance through their injection and withdrawal point monitoring. The bundled purchase of physical gas and PoS in the interconnected European Grid, whilst possible, is currently not the standard way the market operates. The physical gas is most commonly sold separately to a physical gas trader with the physical gas trading license, with the renewable origin encompassed in the Guarantee of Origin (Article 19 of REDII) and the environmental attributes, outlined on the PoS. The proof of physical link, like the Guarantee of Origin with the corresponding Sustainability declaration are being sold separately for the physically comingled gas injected in the interconnected grid. Limiting the trade of biomethane to only when the physical biomethane is injected into the grid, would therefore be severely limiting to the producer, who can now only sell to a select few counterparties, creating an oligopoly for potential participants who can trade the biomethane under ISCC. This is unfavorable for the market whilst providing no additional security. As for physical transfers of biomethane within the interconnected grid, requiring a gas trading license as a mandatory requirement for operating in this market introduces a high barrier to entry, which does not create a level playing field. Moreover, such rule does not consider that trading license requirements are not harmonized in the European Union. Not all member states require a ‘trading license’ or a ‘shipping license’ and if they do, the requirements differ. If the requirement of a licensing requirement were to be kept, this needs to consider the option to use third parties as service providers to not actively exclude players from the market. Many players in the current biomethane market are not set up and also don’t need a gas trading license if required for network access in the country of operation. In such cases a third party can be used to provide network access and transport. However, in the context currently described, the gas shipper would have to take the physical gas, as well as the PoS, which would imply that the gas shipper would have to get ISCC Certified. This goes against the functioning of the market and against the role of the shipper, which would again create an unlevel playing field. We would request that ISCC clarifies this option to comply with the mass balancing rules. BioLNG The BioLNG scenarios laid out in 3.2.3. are clear and provide the two possible scenarios for BioLNG to be created under the physical and legal constraints present. The main concern lies with scenario 2, which described the possibilities for virtual liquefaction. Whilst we agree with the main topics, the clarification related to the biomethane contradicts both ISCC 203’s system document, as well as the prior guidance provided for biomethane trading. By stating that the interconnected grid and LNG tank are seen as the same mass balance, where through virtual liquefaction the processing emissions and conversion losses of the terminal must be taken into account, it allows for the creation of BioLNG without physical gas shipping or a gas trading license as described before. STX would like to have this point clarified, whereby the current described situation for virtual liquefaction can persist but shouldn’t include physical gas movements to allow for the mass balance principle, as described in IR2022/996 is maintained. Request for ISCC related to the biomethane guidance Given the comments provided in this document related to biomethane, STX would prefer that ISCC install a working group specifically for the biomethane sector, especially given the particularities of the industry and framework. | 28 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC EU Mass Balance Guidance Document (v1.0) | We thank ISCC for publishing this useful guidance document on mass balance. Furthermore, we welcome the opportunity to provide feedback on the document published. We remain at ISCC disposal to help improving the document. Our comments seek to provide clarity in the section 3.2.3 Biogas/biomethane in order to avoid any confusion. First remarks are about Figure 12 - suggestion to give a number to each transaction and show virtual trading point only for transaction 2a and 2B - worth highlighting LNG Terminals are located within the MB system (and upstream of LNG tanks) and that trucks can also take CNG gaseous - End Users are in a very different situation if they are FIXED GAS GRID CONSUMERS = directly withdrawing from the interconnected ensemble (= subject to TSO/DSO metering) or MOBILE CNG or LNG truck or ships consumers = buying from a retailer (the fuel supplier– owner of the filling station - is the one withdrawing from the interconnected system and subject to TSO/DSO metering). The transaction between the fuel supplier and the truck or ship consumer is fully outside the mass balance system. - TSO/DSO does not VERIFY MASS BALANCE, they are not in the chain of custody, proposed rewording : “provide metering data to economic operators that are in the chain of custody (who are the ones subject to mass balance requirements)” Then, we would like to comment Figure 14 - Figure 14 is too simplified and misrepresents several aspects (LNG terminal is within the EU interconnected network and not outside + LNG tank is downstream the LNG terminal and not upstream + fuel supplier and consumer are not shown). Suggestion is to reuse the same scheme as in Figure 12 pages - Precise that in this scheme ECONOMIC ACTOR C who performs the physical transaction with the Fuel Supplier has to be certified as processing unit/liquefaction in order to proceed with the transfer of sustainability characteristics from gas to liquid and update the PoS accordingly, or alternately use a toll in service agreement with another system user certified as such. - The LNG terminal does not need to be certified in this scheme since it is not in the chain of custody, neither performing any physical liquefaction. Terminal is an infrastructure operator like the TSO that is not certified either. Infrastructure operators provide metering information to the economic operators that are in the chain of custody for them to justify their mass balance.(Then as discussed terminal can propose virtual liquefaction service as a virtual toll in and in such case he needs to be certified, but it is a separate commercial initiative / not mandatory in the base case). Final comment is about the "link to physical" requirements in biomethane : - The regulatory requirements for « LINK TO PHYSICAL » were originally written for liquid biofuels like biodiesel.For those products, the link to physical is a very robust and straight forward requirement : it means that all over the custody chain, from production to consumption, it shall be the physical molecule of biodiesel that is traded. The certificates cannot be virtually unbundled from the molecule and attached to a fossil diesel molecule. A testing methodology exists (carbon 14) allowing authorities to check all along the chain that the biodiesel is not of fossil origin. - For biomethane, the « real » LINK TO PHYSICAL is lost at the very beginning of the custody chain (at injection of biomethane in the gas grid, the biomethane is mixed with the fossil gas from the grid).From this point on, all the next transactions are based on mass balance -> it is not the physical biomolecule that is traded, but another fossil molecule « rebundled » with the certificates at each step. Carbon 14 testing cannot be used. - Still, for biomethane, there are LINK TO PHYSICAL requirements that were maintained after the injection step.Depending on their interpretations, those requirements create artificial complexity and commercial issues that are hindering biomethane development, more precisely : i) Liquid biofuels like Biodiesel are mainly distributed by ships or trucks so commercial competitiveness comes naturally (economic operators can easily split or divert their sales from one buyer to another). For biomethane on a gas grid several aspects are drastically different (very limited number of local gas grid suppliers, time to change of gas supplier is long (minimum one year commitment and often more), impossible to split the sales of gas because one metering is managed by only one DSO gas supplier). ii) The model of requirements of renewable power are much more adapted to grid biomethane than those of liquid biofuels. iii) The proposal is therefore to make the « LINK TO PHYSICAL » requirements for biomethane more adapted to grid based scheme and more differentiated from the liquid biofuel requirements. | 28 May 2025 |
| April | Arbour | Electrochaea Gmbh | ISCC EU Mass Balance Guidance Document (v1.0) | We welcome and support ISCC’s efforts to align understanding across stakeholders regarding the rules of mass balance structures in its ISCC EU Mass Balance Guidance Document consultation. However, the proposed guidance lacks clear definitions for biomethane and gaseous RFNBOs and puts in place new requirements that will drive up costs and create significant trade barriers for many market participants. We believe a level playing field is essential to enable scalable biomethane and gaseous RFNBOs uptake across the EU and third countries, which is why we are calling on ISCC to reconvene a biomethane-specific working group. By reopening the working group to a larger, diverse set of biomethane market participants, we can ensure ISCC’s goal of aligning understanding of the mass balance rules while guaranteeing biomethane can continue to be traded in accordance with the RED. The following issues must be addressed to avoid confusion among ISCC EU biomethane participants and unnecessary trade barriers that will hinder biomethane utilization: 1. Limiting transfers to the virtual trading point conflicts with the principle of a single mass balance grid. In accordance with RED, flexible allocation of sustainability criteria is accepted within an interconnected gas infrastructure. Limiting transactions of biomethane and gaseous RFNBOs to a virtual trading point undermines the current RED criteria. The current practice of mass balance of gaseous fuels in the EU and US (which does not include physical movement of bio-gases in the grid, but allows the allocation of sustainability criteria to any gas quantity in the grid, provided that the allocated sustainability criteria match volumes that were injected) is widely understood and applied within the industry. A proposed guidance that misrepresents the norm creates confusion in the market. 2. Gas trading licenses are not uniform across countries. The proposed guidance currently implies every trading party must hold a “gas trading license”, however, in many countries this type of license does not exist. It is not possible to put in place such a general requirement when no harmonized trade license exists across countries. Further, we believe if this requirement remains, it disproportionately benefits market participants with established gas trading infrastructure and effectively excludes smaller producers and traders without said infrastructure. This setup risks creating an oligopoly, where only players with infrastructure or access to pipeline capacity can buy biomethane, reducing liquidity and price competitiveness. 3. Clarification on applicability to third country grids is needed. The current framing around trading requirements also raises concerns in the context of international biomethane trade. In many countries outside of the EU, equivalent licensing structures may not exist, and applying uniform requirements could unintentionally limit participation and market access. These issues merit further discussion within the working group to ensure that international trading challenges are adequately addressed and that the framework supports a diverse and competitive market environment. | 28 May 2025 |
| Luca | Zeroli | EY S.p.A. | ISCC EU Mass Balance Guidance Document (v1.0) | In Section 2.1 – Mass Balance Rules from Feedstock to Final Fuel Production (Page 5), the document states: “A product group comprises feedstocks and fuels which share similar physical and chemical properties and fall under the same category, as defined by the RED. Density and lower heating value (LHV) are similar if the values are within a tolerance zone of 2-5%, depending on the material.” This phrasing, supported by Figure 1, may unintentionally suggest that physical similarity is defined only by density, and chemical similarity only by LHV. This may lead to an oversimplified assessment and result in inconsistencies across the supply chain. To improve clarity and ensure consistent application, we recommend: • Clearly distinguishing physical parameters (e.g. density, viscosity, phase state, cloud point) from chemical ones (e.g. LHV, moisture, FFA, sulphur content). • Defining tolerance ranges for each parameter to avoid subjective interpretation. • Providing a technical definition of “physically identical” materials, which should require stricter, near-identical values across key physical attributes. Lastly, while the use of “AND” clearly implies that both conditions—similarity in properties and classification under the same RED category—must be met to be part of the same product group, it would still be helpful for the document to state this explicitly. Even a brief clarification would help preventing any misinterpretation and ensure consistent application across the supply chain. | 28 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC EU Mass Balance Guidance Document (v1.0) | We appreciate the effort ISCC has taken to generate a guidance document and to provide clarity to the industry. Moreover, we welcome the opportunity to provide feedback on the document published. We are not in agreement with mass balance rules laid down for pipeline systems in chapter 2.2 and 3.2.2, especially on the rule of proportional assignment as this is conflicting with market conditions to the disadvantage of airlines under ReFuelEU Aviation. As an example, the Central European Pipeline System (CEPS) network needs to be considered as a big storage system. Contractual framework with CEPS manages the cost charge to the supplier. Ingress volume corresponds to egress volume, but there is no physical traceability of volumes which are injected and later egressed. Consequently, suppliers should have full flexibility to allocate sustainability material (including POS and POC) to any egress location (storage or airport) where they have line rights as long as the ingress volume is considered. Any other rule (such as the one laid down in the current process document) will force suppliers to allocate sustainable materials even to airports where they or the airline do not want to have sustainable material. This will harm decarbonization efforts and subsequently increase SAF prices for airlines. Numeric example to highlight importance of flexibility: • A supplier has a contract with CEPS to pump o 200.000 cbm from Gent to FRA and o 100.000 cbm from Rotterdam to Kehl • The supplier ingresses in Gent a 50% SAF blend and a 0% SAF blend in Rotterdam • The volumes pumped to FRA are fueled in FRA, the volumes pumped to Kehl are fueled 50% in ZRH and 50% in Stuttgart (STR) • That means that the supplier should be able to have the following rights: o 100.000 cbm neat SAF allocated to FRA or o Max 25.000 cbm neat SAF allocated to ZRH (max 50% blending ratio) and the remainder to FRA and/or STR (75.000 or more, taking max. blending ratio into account) o Max 25.000 cbm neat SAF allocated to STR (max 50% blending ratio) and the remainder to FRA and/or ZRH (75.000 or more, taking max. blending ratio into account) | 28 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC EU Mass Balance Guidance Document (v1.0) | We would like to provide our feedback on ISCC’s Mass Balance Guidance as follows: Mass balance on the gas grid Raw materials coming into the methanol facility are identical (biomethane) and only one output is created (biomethanol). Therefore, this isn’t considered as a co-processing pathway, hence there is no need for a bio-content measurement and flexible assignment from the raw material (e.g. MSW) and intermediate material (biomethane) to the end product (biomethanol) is sufficient. Bio-content measurement of biomethanol also wouldn’t make sense as the biomethane is blended with grey methane on the gas grid. This is confirmed via the Commission Delegated Regulation (EU) 2023/1640 on co-processing: in the case of a production unit that uses biomethane as a feedstock withdrawn from the interconnected infrastructure, which is certified and traced through the mass-balancing system of the interconnected gas infrastructure, is not considered as a type of co-processing in the meaning of this delegated regulation. If ISCC wants to measure bio-content, it must so do at the point of biomethane injection into the gas grid, as this is the point where biogenic molecules are created and injected into an interconnected energy system. These molecules will of course be mixed with grey molecules on the interconnected grid, through which a bio-content measurement at point of withdrawal will result in a mix of molecules. Thanks to the current mass balance approach on an interconnected gas grid, the metering data check at point of injection and withdrawal already provides the auditors that a certain amount of biomethane is produced and injected. This in combination with a physical audit of the biomethane production/upgrading facility will provide the auditor with enough evidence that a certain amount of biomethane is captured/produced, upgraded and injected into the gas grid. Mass balance on non-EU gas grids The Mass Balance Guidance document only seems to refer to EU gas grids, whereas RED only refers to ‘interconnected grids’ not to ‘EU interconnected grids’ in particular. On page 14 only TSO’s and DSO’s are mentioned to be able to perform a second verification on the biomethane volumes injected into an interconnect gas grid, not Certification Bodies for non-EU Gas grids. This is needed to ensure that biomethane injection and withdrawal volumes on non-EU gas grids can be verified and linked to the UDB in due course. For now, as the Implementing Regulation 996 is still in development, it would be useful to allow for ‘alternative verification options’ to be included in this document, as this option is currently being discussed with DG ENER and the different EU Member States. It is also important to note that it is not only biomethane-based fuels (SAF, bio-MTBE, marine fuels etc) which need to use non-EU interconnected grids to produce these needed renewable fuels, also RFNBO compliant fuels need interconnected grids to transport their biogenic CO2. Hence, if this option is not included, both biofuels and RFNBO fuels produced outside the EU will not be eligible under the RED due to the inability to register these volumes under the UDB. Biomethane to different types of biofuel For biomethane to biomethanol/bio-LNG/bio-MTBE etc production we do not always use a trader or broker. Sometimes we buy biomethane directly from the biomethane producer. What is meant with that ‘traders must hold the necessary license to transport gas’? Which ‘license’ is the document referring to? Normally traders and bio-LNG/biomethanol producers 1) know the amount of biomethane created and injected and have their contracts and documentation + checks to proof these amounts of biomethane injected, 2) hence have a paper trial which ‘follows’ these molecules to the bio-LNG/biomethanol production facility and 3) have a matching amount withdrawn from the interconnected gas grid which matches the volume injected based on the contract. Furthermore, biomethane to biomethanol/SAF/bio-MTBE production route isn’t mentioned. These pathways are largely similar to the bio-LNG route, but worth mentioning separately or to only mention the first feedstock part (biomethane mass balance on an interconnected gas grid) and then explain that this biomethane can be used for multiple renewable fuels. Finally, the last paragraph on page 15 reads “Note on contractual coherence: Any “inverse” transaction, i.e., where biomethane is notionally swapped for fossil gas, may only occur at the VTP. This form of transaction may not occur at the point of physical injection or withdrawal. This ensures that each transaction aligns with actual grid flows and license requirements.” Currently, this ‘swap’ happens at point of injection and point of withdrawal, as the biogenic and fossil volumes need to be balanced on these points. Could you explain why this needs to change in the future or why this requirement is included in the Mass Balance Guidance? | 28 May 2025 |
| Mariachiara | Zennaro | Centrica Energy Trading A/S | ISCC EU Mass Balance Guidance Document (v1.0) | Centrica Energy Trading’s response to ISCC consultation on the mass balance approach Centrica Energy Trading (CET) is a certified trading company under the ISCC EU Certification Scheme (EU-ISCC-Cert-DE102-24060131). Thank you for the opportunity to respond to the above consultation. Executive summary We welcome ISCC’s initiative to clarify the mass balance rules for trading biomethane via the gas grid. Our comments are entirely focused on section 3.2.3 of the draft guidance, entitled ‘Biogas/Biomethane’. For many years we have found these rules unclear and open to individual interpretation. This has meant that economic operators as well as auditors have had to operate under uneven market conditions, due to different views and interpretations of the mass balance requirements. We believe this guidance provides an opportunity to clarify and strengthen the rules and to ensure they are implemented in a consistent manner by all market participants. This will enable economic operators to operate under equal market conditions and to ensure the chain of custody approach followed by market participants is in line with the rules of the Renewable Energy Directive (ie a mass balance rather than a book and claim approach). Our proposal is that the ISCC should amend the draft guidance to reflect the following requirements: Trading at injection level A physical gas offtake license should be an option to prove legal ownership of the gas at injection but not the only one. Paper based SWAPs should not be allowed as they do not prove the ownership of the physical gas and therefore don’t live up to the mass balance requirements under RED. Physical SWAPs, which include gas nominations to prove legal ownership of the physical gas should be allowed Physical SWAP agreements with the local gas offtakers should be allowed for this purpose. Trading at a hub level Once the gas has entered the single mass balance facility this allows for contractual trades of PoS that includes a link to the physical volume injected to the grid. A general framework agreement for gas trading (ie an EFET standard agreement) and physical gas nominations should not be needed at a hub level when the gas grid is considered as one single transport facility. Because nominations are not needed, a gas shipper license should also not be required. Trading at withdrawal level An approach like that adopted for trading at a hub level should be followed at withdrawal with the main difference will be that the POS sales agreement should include reference to the underlying physical gas volumes withdrawn from the gas grid. The nature of a natural gas supplier is to supply gas to end consumers and not to be a certified economic operator in the biomethane supply chain. Also, the chain of custody stops with the final certified company (normally Trader C), which is why it should not be required to do physical SWAPs with a natural gas supplier that is not involved in the sustainable supply chain. It is crucial that trading companies are not required to become physical (natural) gas suppliers as this requirement would significantly reduce the number of economic operators that are engaged at the withdrawal level. Only larger companies that are already involved in gas supply would be able to operate under this setup. We have explained these points in further detail below. Comments on specific sections of the draft guidance, section 3.2.3 Trading at injection level “Physical Transfer (1)”, page 14 This paragraph refers to the injection and offtake from the biomethane producer to the first trader (offtaker) in the supply chain. Excerpt: “Biomethane producers inject biomethane into the grid at metered points and sell the physical molecule in combination with the accompanying PoS to the immediately following economic operator.” We understand this text means that the PoS and the physical gas must be sold to the same trader (offtaker). In our view the guidance should state this unequivocally. “Virtual Trading Point (VTP) (2)”, page 15 Excerpt: "Traders must hold the necessary license to transport gas from the physical injection point to other parts of the grid, including the VTP. They take legal ownership of the biomethane at injection and facilitate its movement within the network, while maintaining mass balance. For example, as outlined in Figure 12, Trader A must be in possession of a valid licence to receive biomethane from the biomethane injection point, retain a contract with the corresponding infrastructure operation (TSO/DSO), and hold a contract with the biomethane producer. We understand this draft text means that: To be able to transport physical gas from physical injection to other parts of the grid, including the VTP, the following is required: 1) a shipper license, and 2) for injection, also a physical gas offtake license, including an agreement with the TSO/DSO to offtake from the producer and an offtake agreement with the producer. Taking ‘legal ownership’ at injection level requires a license to manage the gas also at DSO level for a production site connected to the DSO grid. In our view this approach is too burdensome and should not be the only option allowed, as it will discourage the trading of biomethane and undermine the market. An additional option, which is a middle ground between the strict position above (where the trader must always hold a gas offtake licence) and so called ‘paper trading’1, which in our view is a book and claim approach should be allowed. Our proposed approach is explained below under section entitled ‘Physical buy/sell “SWAPs”. Physical buy/sell “SWAPs”2: There are currently different practices for doing SWAPs in the market: when two gas trading companies do a SWAP, in most cases the TSO needs to be informed through nominations. To be able to trade gas, the two parties need to sign an EFET (framework agreement for gas trades) and under this, an agreement of buying and selling an amount of gas. E.g. in case of injection of biomethane, Trader A and the physical gas offtaker (third party) need to sign an EFET and a buy/sell agreement. Some TSOs require to nominate the actual volume traded e.g. +/-1 MW, even if the trade through the netted position is zero. Other TSOs require both traders to nominate 0 MW for such trade. Finally other TSOs may not require any nominations at all. We believe that SWAPs that are purely paper based (i.e. without gas nominations) should not be regarded as evidence of mass balance as they do not prove the ownership of the physical gas and therefore don’t live up to the mass balance requirements under RED. A paper swap is typically made between the biomethane producer (who is normally not a shipper) and a trading company that is not a shipper and is also not a gas offtaker). Under this scenario the trader is not licensed to buy/sell the gas, nor to perform a gas nomination, but a contractual SWAP can still be performed (entirely paper based). In our view this is not a credible way to evidence legal ownership of the physical gas under a mass balance approach. We believe this is book and claim and not mass balance. We believe a physical gas offtake licence and offtake of physical gas and PoS is one way to demonstrate ownership and link between the two commodities, but in a case Trader A does not have a gas offtake license, they should have a shipper licence. Furthermore, Trader A needs to make a SWAP agreement with the local gas offtaker (which also a shipper) and then perform the actual nomination in relation to the TSO requirements in the respective country of production. We believe that under this setup ownership of both PoS and physical gas can be demonstrated, and the mass balance rules of RED can be met. Trading at hub level: “Virtual Trading Point (VTP) (2)”, page 15 In this section VTP refers to biomethane trading at hub level i.e. trading after the injection and delivery to the first trader, and before withdrawal and last delivery from trader to end-user (as per Figure 11). The gas is being contractually traded. Excerpt: "The VTP (often referred to as the gas hub) serves as a marketplace where gas is traded contractually, rather than physically transferred. Trades must align with mass balance principles, ensuring that every unit of biomethane bought and sold correspond to a physical volume injected into the grid." The guidance should state clearly that this means that a general framework agreement for gas trading (ie an EFET standard agreement) and physical gas nominations are not needed at a hub level. The certificate sales/purchase contract should still refer to a volume injected into the gas grid. We agree that once the gas has entered the single mass balance facility, nomination from one trader to another is not required. The single transfer facility allows for contractual trades of PoS that includes a link to the physical volume injected to the grid. A shipper license should not be necessary for this if nominations are not required. Trading at withdrawal level “Virtual Trading Point (VTP) (2)”, page 15 Excerpt: "…. Trader C has similar requirements, but instead of operating at the point of injection, it operates at the point of withdrawal." This paragraph is unclear. If this means that Trader C must hold a gas supply licence, this would be really challenging as normally gas suppliers that supply gas at the meter of the end user are those parties holding a gas supply licence, and they are normally not the ISCC EU certified parties. The draft text above implies a trading company would be required to become a physical (natural) gas supplier to be able to sell sustainable biomethane to an end user in a respective country. Becoming a gas supplier is a highly complicated process as the supplier is the taxable entity, which requires the trader to be registered with the national tax authority, and this process is likely to involve a national subsidiary in the relevant country. In addition, if a trader wishes to sell biomethane into more than one country, the process will have to be replicated, and this will become too expensive and onerous for most trading companies. It would become a huge barrier to the sale of sustainable biomethane. Finally, the scope of a gas supply licence is also much broader than selling biomethane only. If implemented, this requirement would significantly reduce the number of economic operators that are engaged at withdrawal level. Only larger companies that are already involved in gas supply would be able to operate under this setup. More economic operators would be able to be active at hub level as shipping of gas is less complicated than the management of physical gas at injection or withdrawal. In summary, in our view, this requirement is disproportionate and would be detrimental to the biomethane market. “Physical Transfer (3)”, page 15 This paragraph refers to the withdrawal of gas from the grid to be supplied to the end user. Excerpt from the draft guidance: Off-taker or downstream gas suppliers (Trader C within Figure 12) withdraw gas at exit points in the system, and transfer it to the market end-users or for further processing (e.g., liquefaction). They must hold the appropriate license to operate in the VTP and to withdraw biomethane from the interconnected infrastructure and further ensure PoS documentation accompanies biomethane transfers. We understand this text means that Tracer C would be required to hold 1) a shipper licence and, for withdrawal, 2) a license to withdraw gas and deliver it to end consumers. For the reasons explained above, we do not support this requirement. Excerpt: Note on contractual coherence: Any “inverse” transaction, i.e., where biomethane is notionally swapped for fossil gas, may only occur at the VTP. This form of transaction may not occur at the point of physical injection or withdrawal. This ensures that each transaction aligns with actual grid flows and license requirements. The text states that physical gas buy/sell agreement (so called SWAP) is not allowed at the point of injection or withdrawal. Please see our recommendation about SWAPs above. In our view paper SWAPs should not be deemed sufficient to prove ownership of the physical gas and comply with the mass balance rules of RED. However, physical SWAPs accompanied by nominations should be allowed. Market participants that cannot manage physical gas should be allowed to use licensed service providers (shippers) to perform the physical nomination on the behalf of the trader. Difference between the treatment of injection and withdrawal We believe that withdrawal should be treated differently from injection. This is mainly because of the involvement of the physical gas supplier on the withdrawal side. As explained above, this is typically an uncertified company, regulated in a different way from a shipper, and operating outside of the scope of trading sustainable biomethane. On the injection side, on the other hand, the biomethane producer is a certified party in the middle of the certified supply chain. This is why believe it is crucial to have physical nomination rather than a paper SWAP, in order to deliver a credible and robust mass balance approach. In addition, end users are also typically uncertified, which means the certified supply chain ends with the final trader (in ISCC guidance, Trader C). The ISCC should make it clear that the mass balance chain of custody stops with Trader C selling to the end user/gas supplier. It is important not to replicate at withdrawal the same approach as at injection. The same approach as that used for trading at a hub level should be followed at withdrawal, as follows: If trader C sells sustainable biomethane to an end user that is also a shipper, this would be a similar setup as trading at hub level, but with a reference, in the biomethane sales agreement, to an equivalent amount of gas which must be withdrawn from the gas grid. If trader C sells sustainable biomethane to an end user who is not a shipper, the same applies i.e. in the PoS sales agreement trader C states the equivalent amount of physical gas that will be withdrawn from the gas grid. The physical gas will be supplied through the local gas supplier. I hope you find these comments helpful but please contact me if you have any questions. We look forward to future engagement with you and other industry parties. Yours faithfully, Dr Mariachiara Zennaro Regulatory Affairs Manager – Biomethane, Hydrogen and GB Gas Centrica | 27 May 2025 |
| Adrian | O'Connell | EWABA | ISCC Document - Carbon Footprint Certification (v1.3) | We just wish to make a general point, which may be useful to the ISCC's work in this area. It relates to the treatment of captured CO2 under the ISCC’s CFC system. Each year there is a considerable volume of CO2 produced as a result of ammonia production. It would be worthwhile checking if newly captured CO2 sources which are being credited under the ISCC scheme are infact stopping the production of CO2 from another source. Or does the newly captured CO2 simply cause higher CO2 emissions from (for example) an ammonia production system. This could occur as the ammonia production (and thus the associated CO2 emissions) will continue, regardless of whether or not another company is capturing CO2 elsewhere. | 27 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC Document - Carbon Footprint Certification (v1.3) | On the requirements for application of CCS credits: 1) Why must the same company operate both the production units where CO2 is captured and the product to which credits are allocated are made? It should also be possible that the same company has equity in both PUs, since there are so many complicated commercial arrangements out there. 2) Similarly, the definition of a ‘site’ is not clear. There are so many different industrial configurations, with cross-site integration and material/utility flows, and there should be flexibility to include these in consideration. | 27 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC Document - Carbon Footprint Certification (v1.3) | The allocation hierarchy is not clear. How is the ‘ratio of economic values between the products’ defined? Absolute value ($) or unit value ($/tonne)? Is it any one co-product relative to all other products: or only one product relative to any other co-product? Why is the threshold ratio defined as 5? This is an arbitrary number. | 27 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC Document - Carbon Footprint Certification (v1.3) | Section 4.2.2. Page 33, 34, Recommend to align this section with the TfS methodology on Data Quality Rating. Previously this was based on 5 categories - "reliability", "completeness", "temporal correlation", "geographic correlation", and "further technological correlation". Now this has been simplified to 3 categories - Technology Representativeness (TeR), Geography Representativeness (GeR) and Temporal/Time Representativeness (TiR) and an overall Data Quality Rating. | 27 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC Document - Carbon Footprint Certification (v1.3) | Section 7.2.3 and 7.4. Potential inconsistency between page 47 (stating that credit can only go downstream of the PoO, suggesting PU III and PU IV only), while in page 49, seems to allow also PU II (emissions of PU II and PU II for product of PU II, while the PO is upstream in PU III) | 27 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC Document - Carbon Footprint Certification (v1.3) | Section 6.2.1. "Attribution of CFC input material (input feedstock) to products (output) needs to follow chemical reaction of the production. This means that the share of CFC material in the product is limited to that part of the product which is derived from specific CFC input material (no overcompensation allowed)". This deviates from the ability to do such "overcompensation" on attribute, and may create a methodological difference between PLUS and CFC. | 27 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC Document - Carbon Footprint Certification (v1.3) | Section 3.1. Page 20, The certificate is valid for one year (validity period of the certificate). The PCF calculation (PCF in kg CO2e) is reviewed every three years (validity period of the PCF calculation). Does this mean that after an initial CFC certification the PCF calculation needs to be reviewed at the third re-certification audit? | 27 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC Document - Carbon Footprint Certification (v1.3) | Section 7.2.3. Page 47 mentions the words “pipelines, ship, or truck” three times in conjunction with transport of CO2 to a storage or use site. Seems a bit inconsistent that transport could be considered in this case for waste disposal but not in the supply chain itself. Will the consideration be extended for multiple site connected by pipeline approach? | 27 May 2025 |
| Andres | Saldivia | HYSYTECH SRL | ISCC EU Mass Balance Guidance Document (v1.0) | Recommendation: Prioritizing Physical Liquefaction for BioLNG Production under ISCC EU Mass Balance Framework Objective To support the strategic and operational preference for physical (on-site) liquefaction of biomethane into BioLNG, rather than relying on virtual (mass-balance-only) liquefaction, within the scope of ISCC EU certification and RED II compliance. 1. ✅ Credibility and Transparency Physical liquefaction establishes a direct, verifiable link between: Sustainable biomethane injection, On-site liquefaction processes, Certified BioLNG output. By contrast, virtual liquefaction relies on administrative transfers that may reduce supply chain visibility and increase reputational risk due to perceived "greenwashing." Why it matters: Improves traceability for clients (e.g., transport operators, heavy-duty fleets). Aligns with rising demand for physical verification of carbon intensity claims. Enhances auditor and market confidence. 2. ⚖️ Regulatory and Policy Readiness Physical liquefaction is more likely to: Comply robustly with GHG reduction thresholds under RED II and national incentive schemes; Satisfy stricter fuel credit systems (e.g. Germany’s THG-Quote, Italy’s CICs, the Netherlands’ HBE system). Why it matters: Future EU revisions may restrict virtual-only pathways in favor of physically verifiable production; Certain MS-level (Member State) incentives explicitly prefer or require physically liquefied BioLNG. 3. 📊 Market Differentiation and Premium Positioning BioLNG physically produced and liquefied on-site can be sold as: High-quality, traceable fuel for ESG-driven customers; Carbon-negative or ultra-low-GHG fuel with documented provenance. Why it matters: Stronger value proposition in voluntary carbon markets and for international shipping (e.g., FuelEU Maritime); Supports premium pricing over "virtual" BioLNG. 4. ⚙️ Operational Control and Risk Management Operating a physical liquefaction facility provides: Control over gas quality, pressure, and liquefaction conditions; Ability to measure and reduce actual GHG emissions — improving lifecycle metrics; Reduced reliance on third-party injection/delivery schedules and registry reconciliation errors. Why it matters: Mitigates risk of compliance failure due to administrative mismatches; Enables technology optimization and cost control. 5. 🌍 Alignment with Sustainability Standards ISCC and other certification bodies favor scenario-based traceability and physical linkages; Physical liquefaction aligns more closely with principles of the circular economy and local value creation. Why it matters: Builds stronger cases for grants, subsidies, and green financing; Contributes directly to regional decarbonization targets. 🔚 Conclusion Physical liquefaction of biomethane into BioLNG is strategically superior to virtual mass-balance-based production for any operator seeking: Stronger market credibility, Greater policy alignment, Operational autonomy, Higher economic and environmental value. Recommendation: Invest in and prioritize certified on-site liquefaction infrastructure, and position virtual mass-balance as a secondary, transitional tool where physical constraints exist. | 27 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC EU Mass Balance Guidance Document (v1.0) | On point 2.1 it says: Physical identity may be assessed by referencing the most current version of ISCC material list. We think this is not clear enough. For example, in the intermediate and final products, we can see refined oil category. Does it mean a refined UCO and a refined soybean oil are physical identical?? We would like to have a better definition of physical identical. Then we have 2 more requests of clarification: Page 6: when it says: Only one exception remains to this rule, which occurs when materials and intermeditates are mixed for futher processing within the boundaries of the final fuel production plant. Question: is the flexible assigment possible also considering the materials that have not gone to processing but are still in stock as raw materials to be processed in the future? Of should be only consider the materilas that already went into processing? Figure 8. Could you do physcial segregation because of a quality request, but apply mass balance from the credits point of view? | 27 May 2025 |
| Mark | Havel | Anew Climate | ISCC Document - Carbon Footprint Certification (v1.3) | Section 2, Evaluation (page 18) - Please confirm whether the PCF of natural gas could be evaluated under ISCC CFC. This section refers to Part II which, in turn, specifies CCS as an eligible activity. Section 4.1.3 System Boundary (page 24) and Section 4.2.1 Data Categories (page 32) - The system boundary appears to include “extraction of primary raw materials.” Certifying a PCF to reflect a CCS investment in gas processing is one of the best opportunities for decarbonizing the natural gas supply chain. If the gas processor investing in CCS must obtain primary data from potentially dozens of gas producers (raw material extractors) for whom it processes the gas to remove CO2 or purchases the gas, it will not be viable. Can you confirm that the intent of the secondary data provisions in Section 4.2.1 would allow the use of default LCA factors for production segments that are upstream of the PU? Section 4.2.1 Data Categories, On-Site Data Gathering (page 32) - Please confirm whether the 45Q regulation under the US Inflation Reduction Act would qualify as an EF source. Section 4.2.1 Data Categories, On-Site Data Gathering (page 32) - Please confirm whether the R&D GREET model published by the US Department of Energy would qualify as an EF source. Section 6.1 Trader - Please confirm that trader certification also extends to traders of pipeline-injected (CCS-enabled) natural gas, leveraging that same mass balance principles for delivering gas through an interconnected infrastructure as ISCC PLUS or EU. Section 6.2.1 Certification Requirements and Handling of CFC certified material (page 42) - This states that the “downstream PU needs to have an own CFC Certificate as ‘Processing unit processing ISCC CFC Material.’” Can you confirm whether a natural gas pipeline might be considered a PU, thereby requiring certification? If there is no further processing of natural gas after the gas processor removes the CO2 from the gas and sequesters it, is it reasonable to assume that only the only entity downstream of the gas processor that needs to obtain certification is the gas consumer taking natural gas off the common carrier pipeline and making the low-CI claim associated with the product from the downstream process? Section 7.1 Introduction (page 45) - Suggest including “such as natural gas” in the last sentence of the paragraph following the three process steps. Section 7.2.3 PU allocating the CO2 credits (page 47) - Can injection into a regulated common carrier natural gas pipeline network demonstrate a “physical link” between the PU capturing CO2 and a downstream PU if it can be demonstrated that the gas from the PU flows to the downstream PU? Section 7.2.3 PU allocating the CO2 credits (page 47) - We propose that the requirements in bullets 2 (same corporate structure) and 3 (same site) do not need to be met if the downstream PU is physically linked to the PU capturing the CO2 (see above comment) and the downstream PU is also certified under ISCC CFC. We believe this approach is consistent with Section 7.4 requirements for allocating CCS credits as it applies to CCS in natural gas processing: a) A natural gas processor typically processes gas for multiple producers. The processor often processes this gas for a fee and does not take ownership of the gas. It does take responsibility and ownership of the CO2 and other material removed from the gas. b) The gas processor is in control of the CO2 removed from the gas produced and is the only entity positioned to undertake an investment in CCS of this CO2. c) If the gas producer who retains ownership of the gas downstream of the gas processor and injects it into the common carrier pipeline is considered a ‘Downstream PU,’ the CCS project would not qualify for a PCF as written. Likewise, if a natural gas consumer such as a gas utility is ultimately making the low-CI claim, it would be a different company and therefore ineligible. This would remove the incentive for most gas PUs. d) Even if the utility purchasing the gas or the gas producer who retains ownership downstream of the CCS unit can be a different company than the PU owner, it is important that the gas processor retain exclusive rights over the CCS credits. A gas processor will not undertake the investment to store the CO2 it removes from the gas if it needs to negotiate with multiple gas producers to retain the value of the CFC claim. e) It is for this reason, amongst others, that the Inflation Reduction Act in the US established that the right to claim the 45Q tax credit rests with the owner of the CO2 capture equipment. Section 7.8 Double claiming of CO2 credits (page 51) - Can an entity that is receiving a credit based on CO2 injection volumes, such as the 45Q tax credit in the US Inflation Reduction Act, receive CCS credits under ISCC? This appears permissible because the CCS credits under ISCC are based on the storage of CO2 in the CCS unit. | 27 May 2025 |
| Volker | Weber | Gre-EN-ergy Consult GmbH | ISCC EU Mass Balance Guidance Document (v1.0) | Hello, if it is allowed to regard LNG imported via LNG terminals equal to locally and domestically produced Biomethane / BioLNG regarding environmental emissions it will open the doors for fraud and betrail and will certainly not help the inevitable energy transition towards renewable gases. Fossil originated gases will continue to come into Europe regardless of origin, production method, etc. Carbon emissions will continue to rise, the reputation of en entiree local and sustainable industry will continue to suffer if there is no clear cut and differentiation. We will continue to depend on geopolitically questionable countries and regions like the Middle East or the US. Fossil originated gases will hide under the unspoiled image of locally produced BioLNG. Again carbon molecules which have not seen the face of the earth for the last million years will be spilled into the athmosphere not to mention the emissions during processing and transport. Imported LNG, non EU produced LNG should clearly be out of this consideration. Virtual liquefaction is just absurd. | 23 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC Guidance Document – Waste and Residues from Food and Food Processing (v1.1) | Dear WG, 1. A specification of oil between the brackets for SBE will be beneficial. And this information should be available from PoO (audit) since plausible yield assessment depends on oil type. 2. Reference to Eural code good to have; this code also required for transporting waste withing EU | 23 May 2025 |
| Karlijn | Arts | OCI | ISCC EU Mass Balance Guidance Document (v1.0) | ISCC EU Mass Balance guidance document- Consultation- Response OCI Dear reader, On behalf of OCI we would like to provide our feedback to ISCC’s Mass Balance Guidance. We are happy to continue the conversation on this document and support ISCC with their efforts to strengthening their certification practices. Mass balance on the gas grid Raw materials coming into the methanol facility are identical (biomethane) and only one output is created (biomethanol). Therefore, this isn’t considered as a co-processing pathway, hence there is no need for a bio-content measurement and flexible assignment from the raw material (e.g. MSW) and intermediate material (biomethane) to the end product (biomethanol) is sufficient. Bio-content measurement of biomethanol also wouldn’t make sense as the biomethane is blended with grey methane on the gas grid. This is confirmed via the Commission Delegated Regulation (EU) 2023/1640 on co-processing: in the case of a production unit that uses biomethane as a feedstock withdrawn from the interconnected infrastructure, which is certified and traced through the mass-balancing system of the interconnected gas infrastructure, is not considered as a type of co-processing in the meaning of this delegated regulation. If ISCC wants to measure bio-content, it must so do at the point of biomethane injection into the gas grid, as this is the point where biogenic molecules are created and injected into an interconnected energy system. These molecules will of course be mixed with grey molecules on the interconnected grid, through which a bio-content measurement at point of withdrawal will result in a mix of molecules. Thanks to the current mass balance approach on an interconnected gas grid, the metering data check at point of injection and withdrawal already provides the auditors that a certain amount of biomethane is produced and injected. This in combination with a physical audit of the biomethane production/upgrading facility will provide the auditor with enough evidence that a certain amount of biomethane is captured/produced, upgraded and injected into the gas grid. Mass balance on non-EU gas grids The Mass Balance Guidance document only seems to refer to EU gas grids, whereas RED only refers to ‘interconnected grids’ not to ‘EU interconnected grids’ in particular. On page 14 only TSO’s and DSO’s are mentioned to be able to perform a second verification on the biomethane volumes injected into an interconnect gas grid, not Certification Bodies for non-EU Gas grids. This is needed to ensure that biomethane injection and withdrawal volumes on non-EU gas grids can be verified and linked to the UDB in due course. For now, as the Implementing Regulation 996 is still in development, it would be useful to allow for ‘alternative verification options’ to be included in this document, as this option is currently being discussed with DG ENER and the different EU Member States. It is also important to note that it is not only biomethane-based fuels (SAF, bio-MTBE, marine fuels etc) which need to use non-EU interconnected grids to produce these needed renewable fuels, also RFNBO compliant fuels need interconnected grids to transport their biogenic CO2. Hence, if this option is not included, both biofuels and RFNBO fuels produced outside the EU will not be eligible under the RED due to the inability to register these volumes under the UDB. Biomethane to different types of biofuel For biomethane to biomethanol/bio-LNG/bio-MTBE etc production we do not always use a trader or broker. Sometimes we buy biomethane directly from the biomethane producer. What is meant with that ‘traders must hold the necessary license to transport gas’? Which ‘license’ is the document referring to? Normally traders and bio-LNG/biomethanol producers 1) know the amount of biomethane created and injected and have their contracts and documentation + checks to proof these amounts of biomethane injected, 2) hence have a paper trial which ‘follows’ these molecules to the bio-LNG/biomethanol production facility and 3) have a matching amount withdrawn from the interconnected gas grid which matches the volume injected based on the contract. Furthermore, biomethane to biomethanol/SAF/bio-MTBE production route isn’t mentioned. These pathways are largely similar to the bio-LNG route, but worth mentioning separately or to only mention the first feedstock part (biomethane mass balance on an interconnected gas grid) and then explain that this biomethane can be used for multiple renewable fuels. Finally, the last paragraph on page 15 reads “Note on contractual coherence: Any “inverse” transaction, i.e., where biomethane is notionally swapped for fossil gas, may only occur at the VTP. This form of transaction may not occur at the point of physical injection or withdrawal. This ensures that each transaction aligns with actual grid flows and license requirements.” Currently, this ‘swap’ happens at point of injection and point of withdrawal, as the biogenic and fossil volumes need to be balanced on these points. Could you explain why this needs to change in the future or why this requirement is included in the Mass Balance Guidance? | 22 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC EU Mass Balance Guidance Document (v1.0) | Dear ISCC Team, the draft mass balance guidance document suggests that biomethane traders needs to be a licensed gas shipper or balancing responsible party. We believe that this is going beyond the scope of the trader. In liquid biofuels traders also don't have to own the trucks or ships but contract logistics experts in moving the fuels. This is how it should be seen in the gas infrastructure as well. Traders should be able to contract licensed gas shippers or balance parties to move the gas for them. Restricting access to licensed gas transport companies would create an uneven playing field and does not support the biomethane market and its future growth. | 22 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC EU Mass Balance Guidance Document (v1.0) | 1. Requirement to hold valid license for shipping of gas is a substantial handicap for small EO / Traders like ourselves. We're active with small volumes in various countries (trading Biomethane only) and if this were to become binding, that would lead to exploding costs in terms of personnel, know-how acquisition and monetary. Big players (e.g. fossil giants) are given significant advantage in this regard if this comes through. It should be allowed to task shipping service providers for handling physical gas. 2. Proof of injection of biomethane is regarded as enough to proof a link of a POS to the physical sustainable material. If a GO from a national registry is issued based on injection metering data gathered by TSO/DSOs (as is the case with all registries/GOs we know of), then jointly transferring GOs with corresponding POS should also be considered sufficient to prove a link to the physical material. This should be stated clearly in the mass balance guidance and other ISCC system documents. | 22 May 2025 |
| Rand | Dueweke | Verbio | ISCC EU Mass Balance Guidance Document (v1.0) | We call for ISCC to convene a new working group with diverse biomethane stakeholder representation to reassess the proposed EU Mass Balance Guidance Document. To ensure flows of biomethane can continue to be traded in accordance with Renewable Energy Directive (RED) III rules, further discussion is needed regarding requirements for virtual trading points and gas trading licenses. We welcome and support ISCC’s efforts to align understanding across stakeholders regarding the rules of mass balance structures in its ISCC EU Mass Balance Guidance Document consultation. However, the proposed guidance lacks clear definitions for biomethane and puts in place new requirements that will drive up costs and create significant trade barriers for many market participants. We believe a level playing field is essential to enable scalable biomethane uptake across the EU and third countries, which is why we are calling on ISCC to reconvene a biomethane-specific working group. By reopening the working group to a larger, diverse set of biomethane market participants, we can ensure ISCC’s goal of aligning understanding of the mass balance rules while guaranteeing biomethane can continue to be traded in accordance with the RED. The following issues must be addressed to avoid confusion among ISCC EU biomethane participants and unnecessary trade barriers that will hinder biomethane utilization: 1. Limiting transfers to the virtual trading point conflicts with the principle of a single mass balance grid. In accordance with RED, flexible allocation of sustainability criteria is accepted within an interconnected gas infrastructure. Limiting transactions of biomethane to a virtual trading point undermines the current RED criteria. The current practice of mass balance of gaseous fuels in the EU and US (which does not include physical movement of bio-gases in the grid, but allows the allocation of sustainability criteria to any gas quantity in the grid, provided that the allocated sustainability criteria match volumes that were injected) is widely understood and applied within the industry. A proposed guidance that misrepresents the norm creates confusion in the market. 2. Gas trading licenses are not uniform across countries. The proposed guidance currently implies every trading party must hold a “gas trading license”, however, in many countries this type of license does not exist. It is not possible to put in place such a general requirement when no harmonized trade license exists across countries. Further, we believe if this requirement remains, it disproportionately benefits market participants with established gas trading infrastructure and effectively excludes smaller producers and traders without said infrastructure. This setup risks creating an oligopoly, where only players with infrastructure or access to pipeline capacity can buy biomethane, reducing liquidity and price competitiveness. 3. Clarification on applicability to third country grids is needed. The current framing around trading requirements also raises concerns in the context of international biomethane trade. In many countries outside of the EU, equivalent licensing structures may not exist, and applying uniform requirements could unintentionally limit participation and market access. These issues merit further discussion within the working group to ensure that international trading challenges are adequately addressed and that the framework supports a diverse and competitive market environment. | 22 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC Guidance Document – Non-Conformities and Sanctions of System Users and CBs (v1.1) | The draft guidance document for NCs and Sanctions of SUs and CBs states, "During the suspension period, the SU is not allowed to handle material." Does this mean no credits of sustainable material can be acquired by purchasing ISCC-declared material? Or should "handling" be considered as no (outgoing) declarations by the SU can be made? A SU could not address a NC finding of a negative balance of sustainability mat. credits during the suspension period if they could not acquire credits in that time. | 19 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC EU Mass Balance Guidance Document (v1.0) | Section 2.1 o Paragraph 1 – “Physical identity may be assessed by referencing the most current version of the ISCC material list” . However, the ISCC material list lacks definitions or criteria which must be met for a fuel to fall under a certain product type. We suggest adding the definition of the biofuel to the guidance document, e.g. when is a fuel considered a Biodiesel, renewable diesel, HVO, bio gasoline or Bio Heating Oil. o Paragraph 2 and Figure 1 – “Density and lower heating value (LHV) are similar if the values are within a tolerance zone of 2-5%, depending on the material.” . This definition is broad and doesn’t specify how to determine, based on the material, whether to use 2% or 5%. Additionally, will create too much workload on maintaining the mass balance since for each batch it will require registering which batches will be part of the same product group and which ones not. Also, it is not clear if the density and LHV of the batch immediately after production should be considered or if it can also be of a mixture that was purchased. Additionally, could "Refined oil" be included in the Annex II of the Mass Balance Guidance? | 19 May 2025 |
| Cassio | Xavier Silva | SHV Energy | ISCC EU Mass Balance Guidance Document (v1.0) | SHV Energy welcomes the opportunity to comment on the ISCC EU Mass Balance Guidance Document. As a company handling ISCC-certified volumes of bioLPG, we appreciate the clarifications this document provides but would like to highlight a few areas where further guidance is needed: 1. Interconnected Infrastructure as Single Mass Balance System: We suggest clarifying that separate LPG depots can qualify as a single mass balance system under the definition of “interconnected infrastructure.” can also be considered as a single mass balance system, as Regulation 2022/996 does not restrict its application to methane or LNG terminals. 2. Non-Identical Molecule Blending (e.g., bioLPG and rDME): Annex II lists both bioLPG and rDME as physically identical, but it is unclear whether this applies across all listed products. These fuels have different physical properties (e.g., density, LHV) yet can be blended. The document should clarify if and how conversion factors and PoS requirements apply in such blends. 3. Responsibilities for Blend Ratio Updates: Section 3.2.2 does not specify responsibility for updating blend ratios. Further guidance is needed for terminal operators on how to update and document live blend ratios at storage and depot levels - especially in more granular, customer-facing operations. Also, further clarification on whether third-party validation is required for these changes throughout the value chain. 4. Eligibility of Feedstocks for Renewable DME and Recycled Carbon Pathways: Bio-LPG, bio-DME, and renewable DME are listed in Annex II as final products, as they are certified renewable and low-carbon fuels already on the market. However, the eligibility of feedstocks for renewable DME production remains unclear, especially in what differentiates the classification of renewable DME from bio-DME. Both LPG and DME can be produced from recycled carbon fuels and renewable electricity, and guidance is needed on how these pathways are treated under the ISCC EU system. We appreciate ISCC’s efforts to increase transparency and usability of the system and encourage the inclusion of further clarifications to support consistent implementation across the sector. | 15 May 2025 |
| Qiujin | Lin | CM Green Energy Technology (SHENZHEN) Co. | ISCC Document - Carbon Footprint Certification (v1.3) | Dear ISCC Team,We have reviewed the updated ISCC 205 document and have the following feedback: 1、Can the link to the State Grid emission factor be included in the document? 2、Does the calculation formula for 205 refer to the entire lifecycle of biofuels? Can it be considered equivalent to WtoW in IMO? 3、Missing annotations for efd and efm in the formula on page 22. Could you please clarify what these parameters represent? Thank you for your attention and prompt response. | 7 May 2025 |
| Francisco José | Ayala | AXPO Iberia | ISCC EU Mass Balance Guidance Document (v1.0) | Regarding Biomethane Trading in the Guidance Document. It is still unclear what are the licenses the biomethane trader has to hold. It is clear that in the injection/extraction operation the trader has to hold a shipping license for the gas (being contractually propietary of the gas). However in the given case of Trader B in figure 12. (buying and selling in VTP) it is not clear if the trader must be a shipper or hold a permit to handle natural gas in the gas grid. Please clarify, if all traders have to hold this license in all cases. | 5 May 2025 |
| Anonymous | Anonymous | Anonymous | ISCC Guidance Document – Waste and Residues from Food and Food Processing (v1.1) | In the document ISCC GUIDANCE WASTE AND RESIDUES FROM FOOD AND FOOD PROCESSING referred in the system update of april 30th there is the following statement "Under ISCC EU, the risk level must always be high for all audits (certification and surveillance audits) of individually certified Points of Origin, Collecting Points, and Central Offices 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. General and specific requirements as listed in the document ISCC EU 203 – Traceability and Chain of Custody forms the basis of audit requirements for different supply chain elements handling wastes and residues." The statement doesn't mention Trader W or W/O storage and Processing unit Question: what risk level as to be considered for a trader w/O storage or a Processing Unit that trades/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? | 30 April 2025 |
| Alexandre | Arnout | tereos | ISCC Document - Carbon Footprint Certification (v1.3) | I don't agree on allocation recomended. A lot of stakeholders have products concerned by REDII with and energetic allocation as an obligation. Then if an other allocation is used to calculate CFC for coproducts of RED II ones, some CO2 is missing and can imply green washing. Actors having RED II product HAVE TO use energetic allocation to avoid double coutnig. if energetic allocation is not mandatory not all actors will play with same cards and will imply distortion of competition | 29 April 2025 |
| Karl | Mustafa | OMV Downstream GmbH | ISCC Guidance Document – Non-Conformities and Sanctions of System Users and CBs (v1.1) | In our view, the document is missing one important aspect: deadlines. ISCC must implement clear deadlines, following an integrity assessment: - When the integrity assessment report is issued - When the classification of non-conformities is issued - When the sanctions for both SU and CB are issued Those cannot/should not take more than several months in a properly functioning certification scheme. | 17 April 2025 |
| Patrick | Lynch | Bioledger | ISCC Guidance Document – Waste and Residues from Palm Oil Mills (v3.2) | Quantity of POME should be compared to previous 5 years, not previous 12 months. Auditor should verify that the change over 5 years should be plausible based on proportional increases in the same period of quantity of FFBs received and capacity of required processing infrastructure. - Quantity of sterliser condensate throughput should be compared to previous 5 years. Auditor should verify that any change is proportional to increased quantity of FFB & output of the sum of all products. Auditor should verify that the ratio of condensate production compared to all other products has not changed over the 5 years. - The Palm Oil Mill being certified as Point of Origin should prepare evidence to demonstrate all of the indicators in 6.2. to the auditor in advance of the audit. The POM should propose a calculated Maximum estimated sustainable capacity per year of POME and other wastes or residues. This calculation must be verified by the auditor. The verified maximum estimated sustainable capacity per year should be recorded in the Union Database account of the POM. Recertification audits should verify the quantity of UDB POS issued from the POM in the UDB to customers. If this quantity exceeds the maximum sustainable capacity verified in the previous audit, evidence should be presented to justify the revised calculation of Maximum sustainable capacity and adjusted in the POM account in UDB. If the quantity of POME UDB POS exceeds the maximum estimated sustainable capacity and cannot be justified by accompanying evidence to revise the capacity, this should be considered a major non-compliance. - If the yield of POME:FFB exceeds the most convervative (0.5-2.1kg) auditor must record the physical processing elements from Annex 7. observed which justify higher output. | 25 March 2025 |
| Adrian | O'Connell | EWABA | Guidance Document for the Certification of Co-processing (v2.0) | The new (version 2) draft Guidance for the Certification of Co-Processing from the ISCC marks an expanded set of guidelines compared to the previous version, and is a very welcome development. We as EWABA kindly would like to submit our following recommendations to the ISCC for their consideration, as we believe they will help the robustness and accuracy of the auditing system. Recommendation 1; deoxygenation via hydrogen or carbon The requirement in the document for a “Proof of operating performance” (p13) is especially important, as it will help ensure a co-processing operation which has been set-up using specific operating parameters has continued to work in the same way, especially with respect to bio-yield claims. This is especially important when considering if the vegetable oil or fat has been deoxygenized either by the hydrogen input (hydrodeoxygenation, HDO), or to the extent of which this may have taken place by some of the carbon in the bio-feedstock itself ((i.e. by decarboxylation or decarbonylation). We therefore recommend auditors note net hydrogen consumption levels along with claimed bio-outputs for this reason, and confirm close similarity to the hydrogen levels noted when the yield factor was being finalized. Recommendation 2; provide feedback to MS if “drift” noted from actual v claimed bio-yields In the cases whereby a yield factor has been established by a MS at a national level, if the audit confirms these do not represent the actual yields being claimed by a co-processing facility, it would be useful from the point of view of enhancing overall accuracy and trust in the system, for the MS to be provided with feedback showing there may be a discrepancy. In such a case it is recommended the MS consider they re-calibrate or adjust their yield factor. Recommendation 3; positively interpret the Delegated Act regarding 14C testing There appears there may be some unintentional incongruity in the legislation itself (Delegated Regulation (DR) 2023/1640) with regards the degree of necessity for 14C testing. The legislation (and which is quoted by the ISCC document) states that “the radiocarbon 14C testing method shall be carried out every time that there is a change by more than 5 %, compared to the baseline conditions, in ……. the product composition” (2023/1640, Article 6, point 5). This is indicating a 14C test should be carried out if a change in the composition of the products changes by more than 5%, which could in theory include a change in yield of a bio-fuel by 5% which is highly significant. EWABA therefore recommends this “more than 5%” indication in Article 6, point 5, be interpreted alongside the article directly before it which aims for an overall upper limit in the difference between 14C test results and other methods of 1%. While the DR states “in all cases, the radiocarbon 14C testing method shall be carried out at least once every 4 months”, it also clearly states that Economic Operators should “regularly use radiocarbon (14C) testing of the outputs to verify the correctness of the main testing method used”. We therefore firmly believe the “regularly” the DR refers to with respect to 14C testing means a frequency greater than 3 times in a year. Recommendation 4; more positive action when main method incorrect In section 3.5.4 of the ISCC document, there are two tables which describe allowable differences between 14C results and alternative (or “main”) methods for calculating bio-yields. We question what would the actual approach in a scenario whereby the 14C result is 3% lower than the result given by an alternative method? Or to give an example; 14C result 3%, alternative method result; 6%, claimed bio-content: 6%. In this scenario, and following from the indications of Table 1 in the ISCC draft guidance, it appears that a review of the main calculation method (by the ISCC, the auditor, or the company) would not be required, at least during the first 12 months of operation of the co-processing facility. EWABA believes while this may be numerically possible, it confirms a serious issue with the main method, or more simply, that the main method is incorrect and a critical review of the main method should be expedited, and not left run for a year. Indeed it calls for the other text of the DR to be acknowledged which clearly states that “Economic Operators should “regularly use radiocarbon (14C) testing of the outputs to verify the correctness of the main testing method used”. Recommendation 5; GHG emissions calculation When considering GHG emissions, EWABA recommends that if bio-LPG is removed from a co-processing system and replaced by natural gas, that this replacement is taken into account in the GHG calculation. Our understanding of the default GHG calculation in the RED, is that there is some use of off-gases assumed to happen within the refinery to heat the system. Thus if these gases are now taken out of the system (and sold as bio-LPG for example), the gas used to necessarily replace the bio-LPG in the refinery, and which is most likely natural gas, is reflected in the GHG calculation. Or in other words, a co-processing (or indeed HVO plant) which benefits from sale of bio-LPG out of its system, cannot use a typical or default value which assumes the bio-LPG is used internally in the refinery, as this would “mask” or “hide” the true situation, which sees a new, additional natural gas requirement due to the external use of the bio-LPG. Secondly, if a co-processing facility has been set-up using a low hydrogen input scenario (which results in greater loss of bio-carbon), but in reality operates in a higher hydrogen use scenario (thus maximising bio-yields) this should be clearly reflected in the higher hydrogen demand, and thus higher GHG emissions of the biofuel. For more information on this, please consider (Vásquez et al, 2017, and indeed sections 6.1 and 7 from O’Connell et al, 2022). This states that an effect on hydrocarbon yield and on hydrogen requirement resulting from the choice of method to deal with the carboxyl group can be seen. Propane yield remains constant; HDO provides a higher hydrocarbon yield, but at the highest hydrogen requirement. Finally, and similarly to the above, if a co-processed fuel requires isomerisation following co-processing, this of course must be reflected in the GHG calculation and in any possible reduction in yield of final fuel(s). References Commission Delegated Regulation (EU) 2023/1640 of 5 June 2023 on the methodology to determine the share of biofuel and biogas for transport, produced from biomass being processed with fossil fuels in a common process. O’Connell, A.; Su, J.; Ringsred, A.; Prussi, M.; Saddler, J.; Scarlat, N. Tracking the Biogenic Component of Lower-Carbon Intensive, Co-Processed Fuels — An Overview of Existing Approaches. Appl. Sci. 2022, 12, 12753. https://doi.org/10.3390/app122412753 Vásquez et al, 2017. Hydrotreatment of vegetable oils: A review of the technologies and its developments for jet biofuel production. Vásquez M.C., do Silva E.E., and Castillo E.F.. https://www.sciencedirect.com/science/article/pii/S0961953417302295 *** | 7 March 2025 |
| Anonymous | Anonymous | Anonymous | Guidance Document for the Certification of Co-processing (v2.0) | 3.1 Record keeping and overall mass balance (page 7) Please specify whether each delivery in case of municipal waste or other non-bio origin needs to be tested by 14C. 3.5.4 General considerations for using a method other than radiocarbon 14C testing as the main calculation method (page 13) Please specify how can we take into consideration product composition changes. Please specify how can we take into consideration a potential change in biomass feedstock chemical characteristics. How should we account if incoming feedstocks are stored into the same store tank? | 7 March 2025 |
| Patrick | Foody | iogen corporation | Guidance Document for the Certification of Co-processing (v2.0) | Our company, iogen corporation, has extensive experience integrating bio-hydrogen into refinery operations to make RED compliant fuels and we have access to extensive data to demonstrate operating results. We also have patents relating to this field. Pg 4. Sec 1 Introduction. Section 1 (Introduction) correctly recognizes co-processing as a broad category: “co-processing refers to a method of producing liquid or gaseous fuels wherein bio-derived and fossil-derived materials are physically mixed and processed simultaneously in a same production unit.” The DR does not cover all co-processing situations, but the guidance document should also cover situations where co-processing occurs but the DR does not apply. For operations excluded from the DR, we recommend specifying that use of the “energetic determination” is acceptable. Pg 5. Figure 2: Hydrogen is commonly used as a feedstock in refinery operations. Our data demonstrates that most every hydrotreating operation contributes atoms to the fuel, and thus hydrogen is a feedstock. Hydrogen should not be depicted as a separate category of input or called out for separate consideration. We recommend removing the “hydrogen” box and clarifying that “bio-feed” can be “bio-oil” and/or “bio-hydrogen”. Likewise, “fossil-feed” can be “fossil-oil” and/or “fossil-hydrogen”. Pg 5. Last paragraph. “Bio-content” is defined in the document as “the percentage by MASS of a biomaterial in a material that is derived from both biomass and fossil feedstocks” and is defined as being related to the 14C ratio. This definition is good for bio-material that contains 14C measurable content, but is not appropriate for bio-hydrogen-containing materials. Hydrogen is appropriately characterized by its energy content, not its mass. References to hydrogen should not use the mass definition of “bio-content” – a different term should be used. The DR uses “biological origin.” This should be based upon the % renewable energy content within the fuel. Pg 6, Sec 2 Scope, first sentence relating to bio-hydrogen incorrectly references sec 3.7. It should refer to 3.3. In addition, the term “bio-content” should be changed to “biological origin” to address the above point, and to align with section 3.3. Pg 6. Section 2. Scope, second full paragraph, identifies co-processing exclusions where the DR does not apply (in particular where methane feedstock is withdrawn from interconnected infrastructure as biomethane and used in a process). We recommend adding another exclusion, namely for the situation where inputs to a co-processing operation are made by an excluded process. (example: where biomethanol made from grid-supplied biomethane is used a coprocessing feedstock (for instance with fossil methanol) to make SAF.) Pg 6. Section 2. Scope, third paragraph, provides that “co-processing outputs must contain a bio-content that is measurable using 14C radiocarbon analysis”. We suggest adding “unless such co-processed outputs are subject to the exclusions above”. Pg 7. Sec 3 Requirements. Second paragraph says “requirements of this document are applicable for all processes … with a bio-content that is measurable using radiocarbon 14C testing.” See the first comment above. Pg 12, Sec 3.1.1 Energy balance methods. In the third sentence, inclusion of energy from processing in the total energy for the purposes of yield calculation is an incorrect method. Only energy from feedstocks should be included in the bio-content method. Energy for the processing of the feedstock should accrue to the EP of the fuel (in the GHG emissions calculations), not affect the yield of fuel. PG 17, Sec 3.3 Hydrogen, last paragraph. The DR says “may use” but the document has changed this to “should use”. This should revert to the DR requirements. We recommend adding the following: “The system user may also determine hydrogen atom contribution to the fuel by using analytical methods on inputs and outputs, and by measuring the difference between the a) the input hydrogen and b) the unreacted hydrogen removed (such difference being the hydrogen chemically consumed), and further subtracting c) reacted hydrogen lost in the form H2S (sulfur removal), NH3 (nitrogen removal) H2O (oxygen removal), and further subtracting d) hydrogen added to off gas such as methane, ethane, propane, or butane or any other lost component.” This method improves accuracy because using a difference between two ratios can impart error, and measuring the consumed hydrogen by difference is inherently more accurate”. Further, we would suggest adding the following for allocation of incorporated hydrogen among products : “For fuel production processes involving hydrotreating with biological hydrogen as a feedstock (i.e. hydrogen that is reacted and which contributes atoms to the fuel), system users may determine the bio-fraction of all outputs (i.e. fuel products and co-products) to be equal to the bio-fraction of the combined feedstocks, on a percentage energy basis LHV.” This method is reasonable given that hydrogenation of products would not be expected to be selective among products. We would be happy to provide more information to the EC in resolving appropriate procedures. | 7 March 2025 |
| Anonymous | Anonymous | Anonymous | Guidance Document for the Certification of Co-processing (v2.0) | Page.11: 3.5.1 Yield model methods There are two different yield methods that a system user can choose to use as their main calculation method. (1) Yield Method A. To use this method, a system user first performs their desired process with only fossil feedstocks or for specific applications on a pilot scale that is accurately representative of their intended commercial scale operations. Then, the bio-content of the input is gradually increased and the effect of this increase on the total yield of outputs is observed and recorded and then attributed to each product in proportion to the observed increase in production. These are the determined yield factors (YF), and they are only valid for the measured reference inputs and specific process conditions. These yield factors must be verified or calibrated using 14C analytical testing. System users may use different yield factors for different processes or operating conditions, as long as they validate or calibrate the YF with 14C analytical testing. If different YF are used, radiocarbon (14C) testing shall be performed and checked against inputs and process - If the crude oil being processed is constantly changing, on average twice a month or even more frequently, and according to this article, the yield factors should be redefined for each set, I believe this method becomes unsuitable for use. Page. 18: Such an evaluation is required as often biomass-based feedstocks have a high oxygen content and more hydrogen is consumed to deoxygenate it compared to a fossil-based feedstock. – What amount of oxygen and hydrogen would be considered high?? Percantage is missing | 7 March 2025 |
| Anonymous | Anonymous | Anonymous | Guidance Document for the Certification of Co-processing (v2.0) | We fully support comments already provided by FuelsEurope; 1) Application of the Two-Step Approach for Co-Processing of Waste-Based Inputs, 2) Flexibility in the Determination of Bio-Content, 3) Use of Default Yield Factors Set by Member States, and 4) Practical Considerations for Sample Storage Requirements. In addition, we see some room for clarification as listed below: • The need to test streams that are known to be entirely fossil every test round have no meaning. This would only cost unnecessary lab and personal resources for the extra sampling. • We find that a section on how to handle indirect measurement of Carbon-14 results would be helpful. Example 1: Are we obliged to change our yield model if one sample has more than 1% difference, even if the previous nine are within limits? We assume the answer is no. Example 2: Should we adjust the model if an average of ten samples is within limits but all the results are -0,8% to -1,1%? We assume the answer is yes. • We would ask for more clearly defined normal operating windows for the facilities, is it 5% of what? Is it feed, temperature etc. • The rounding off of deviations to the nearest whole number can be very problematic at low blending/percentages, but less significant at high blending. We would like clarification on the reasoning behind the rounding. • We would wish for instructions on how to handle streams that cannot be sampled, such as streams with too high moisture content, gas that cannot be tested or samples that have too dark colour. • The ISCC draft guidelines require samples to be stored for two years for verification purposes. This is not possible for gaseous samples, where degradation over long periods may affect accuracy. We recommend adapting storage requirements to match physical reality. • In section 3.6 it is mentioned that any increase in processing input shall be attributed to the biomass fraction, how about decrease in inputs, for example steam? A refinery unit can go from net consumer to net producer of steam with increased bio-based feedstock. | 7 March 2025 |
| Timmi | Tuutti | Neste | Guidance Document for the Certification of Co-processing (v2.0) | Neste’s feedback on the ISCC Document 203-01 – Certification of Co-Processing Neste welcomes the ISCC draft guidance on bio-coprocessing, here are our comments and proposals. We suggest to clarify already in the headline that the guidance is applicable only for “co-processing of biobased feedstocks”: Biofuel samples and data storing (chapter 3.5) Neste is concerned with the proposed two years’ storage requirement which would lead to very big amounts of samples. Currently jet fuels are stored for 6 months and other fuels for 3 months. Neste proposes 3 months storage for liquid samples and no storage for gaseous samples because of concern on sample representativeness after storing them. In addition, there would not be enough storage-ability / capacity resulting in increased investments and costs. GHG calculation (chapter 3.6) The ISCC draft co-processing guidance is proposing to define biofeedstock specific inputs and allocating the involved emissions to co-processed biofuels. It seems straightforward and is aiming for more realistic processing emissions for co-processed biofuel. However, in practice, the implementation of the proposal is not simple and results may not be realistic. Defining the fossil scenario is challenging in a complex refinery. Refining processes are not operating in a constant manner. All of the processes are under continuous optimization: maximising product yield and quality while minimising costs in ever changing atmosphere and varying feedstocks. There will always be some kind of unexplainable variance in the inputs to the process. According to our analysis, the normal variance of the process may result in irrational processing emissions for the biofuel (orders of magnitude higher), or neglect all of the actual additional emissions resulting from the additional conditioning required by the biofeedstock when the share of bio in the feedstock is low. Annexes Table 4 is missing EN 16640 method (alternative for ASTM D6866). Last row on Table 5 contains outdated information. Up-to-date version: Testing procedure: Neste Method: DIN 51637 Features: Direct count of the number of scintillation flashes (approved by Finnish authorities) Confidence Interval: Limit of Quantification for diesel 1.8 w-%, for gasolines 2.9 w-% and for jet fuel 1.6 w-% Source: Neste Biofeedstock used: Biocontent range of 0-100 for diesels, gasolines and jet fuels | 7 March 2025 |
| Anonymous | Anonymous | Anonymous | Guidance Document for the Certification of Co-processing (v2.0) | We recommend to add in this introduction (pg. 4) that this methodology and the concept of co-processing can also be applied to installations co-processing wastes of bio and non-bio origin. This is later on mentioned in the document but we believe it would be better if it is included in the document already in the introduction. Delegated regulation 2023/1640 in recital 1 (and across the articles) also indicates that the methodology may be also applied in ther cases of installations treating bioliquids and fossil oil or in installations co-processing wastes of bio and non-bio origin. On the paragraph referring to the Definition of a batch/consignment (pg. 7), we believe that to avoid misinterpretations of this paragraph it should be clarified that the batch refers to a given quantity of output with biocontent as determined using one of the methods described in this document without prejudice of the definition of batch inlcuded in the ISCC EU Document 203. When defining the sampling in 3.4 Radiocarbon 14C testing for bio-content determination (pg. 10), we believe this provision together with the provision included in Article 1.2 of Delegated Regulation 2023/1640 : " "The radiocarbon (14C) testing shall be done before the fuels produced through co-processing are further blended with other fossil fuels or biofuels that were not part of the co-processing itself. " would imply to have a dedicated tank to store the output of each co-processing unit. This doesnt seem a practical approach and may require in many cases mayor investments at the refinery. An alternaive woould be to require operators to take several samples at the exit of the unit and create a combined sample to be analysed by 14C. On the paragraph referring to the Defined reference operating conditions (pg.12) we believe a note should be included to address potential alternative methods to 14C verification in the case of gas samples if this are recognised in a member state. On the General considerations for using a method other than radiocarbon 14C testing as the main calculation method (pg.13) we believe this document should not add requirements to those included in the delegated regulation as these would add an unjustified burden to economic operators that are already conducting considerable efforts to comply with the legal text Article 4.5 of the delegated regulation does not make reference to the obligation of economic operators to demonstrate which operating parameters influence the bio-content of outputs but only makes reference to:- "Unless a method is applied that can map the operating conditions related to carbon content in the output for each batch or consignment, the radiocarbon 14C testing method shall be carried out every time that there is a change by more than 5 %, compared to the baseline conditions, in the feedstock composition in terms of the share of biogenic input or the amount of hydrogen and catalyst inputs in the total mass, the process parameters in terms of process temperature in absolute [K] or process pressure in absolute pressure [Pa] or the product composition. An elemental analysis of carbon, oxygen and nitrogen, together with an analysis of the water and solids content, shall be provided as a basis for assessing the parameters of the product composition. In all cases, the radiocarbon 14C testing method shall be carried out at least once every 4 months." • biomass feedstock chemical characteristics, This parameter is not included in the DR, we believe we shouldn't be added to the already demanding list included on the Delegated Act. • hydrogen pressure, As in the DR it refers to amount of hydrogen, we suggest to add as an alternative the H2/feed ratio, as it is a more accurate parameter to be evaluated. • catalyst characteristics, As the DR refers to the amount of catalyst inputs in the total mass, not to catalyst loading or characteristic, we strongly recommend to use the catalyst amount. Moreover, catalyst characteristc are not posible to monitor on a continous basis (in operation). Therefore it would be not possible to monitor if the catalylist characteristic have changed 5%, 10%.... • process temperature, We suggest to specify that is temperature in absolute K • product composition, We suggest to indicate that product compositions is refered to: "product composition. An elemental analysis of carbon, oxygen and nitrogen, together with an analysis of the water and solids content, shall be provided as a basis for assessing the parameters of the product composition." For better understanding, in that same section, the paragraph below Figure 5 (pg. 14) we suggest to move this paragraph below Figure 6 to make sure this is treated as a separate case from the general rule of yield factor establishment. And for the paragraph over Figure 6 (pg. 14), we believe wording should be including to make clear that this is just an example of how this should be done. In the Annnex I- Technology overview (pg. 24), as indicated earlier, In the DR there is only reference to the need to monitor a number of defined parameters. This additional requirements is a considerable burden on the Economic Operator. Demonstrating which operating parameters influence the bio-content can be extremely difficult. Therefore we strongly recommend to limit the parameters to those indicated in the delegated regulation. In any case this annex is maintained it should be considered that these parameters indicated in the list may or may not impact the bio-yield, therefore we would recommend to indicate "Parameters that may affect the bio-yield...." Please find below the extract from the delegated act that we are referring to: "Unless a method is applied that can map the operating conditions related to carbon content in the output for each batch or consignment, the radiocarbon 14C testing method shall be carried out every time that there is a change by more than 5 %, compared to the baseline conditions, in the feedstock composition in terms of the share of biogenic input or the amount of hydrogen and catalyst inputs in the total mass, the process parameters in terms of process temperature in absolute [K] or process pressure in absolute pressure [Pa] or the product composition. An elemental analysis of carbon, oxygen and nitrogen, together with an analysis of the water and solids content, shall be provided as a basis for assessing the parameters of the product composition. In all cases, the radiocarbon 14C testing method shall be carried out at least once every 4 months." | 6 March 2025 |
| Rosa (Yoonju) | Kim | Control Union Korea | Guidance Document for the Certification of Co-processing (v2.0) | GHG emissions calculation for co-processed fuels] 1) When calculating Delta according to Bio Co-processing, is the change in hydrogen consumption calculated based on process operation performance? Is there a minimum operating period that is accepted as an operation for the co-processing? (ex. Only at least 10 days of driving are recognized) If co-processing is done all year round, how should Delta be calculated if there is no 100% Fossil raw material input process performance? Or can it be used based on the theoretical hydrogen usage calculated from Elemental Analysis, etc? 2) In the case of the catalyst process, the product yield and process power ratio changes according to the catalyst deactivation over time. Can the corresponding yield/power ratio be arbitrarily corrected by utilizing past operation performance? Ex. Based on 100% Fossil process performance in the past, hydrogen is consumed 1.2 times more in the second half of the year compared to the first half of the year. During the second half of the year, the increase in hydrogen consumption (1.2 times) due to the characteristics of the existing process was also estimated to have increased hydrogen consumption due to co-processing, which can be excessively GHG calculation. Therefore, shouldn't the increase in hydrogen consumption according to the characteristics of the general process be arbitrarily corrected based on past performance? 3) Like Hydrogen, factors that can affect GHG emissions during Co-processing (such as Wastewater) should also be included in Delta, how do you think? 4) In our case, the renewal review is scheduled from April to May, but if this guidance is officially announced after the certification renewal, should we submit the GHG Calculation results again? Or should I submit it at the next renewal review? 1. There would be some issues because the ISCC Co-processing Standard excessively reflects the contents of the EU Delegation Regulation ("DR"). - If the ISCC Co-processing Standard is prepared in a way that is overly dependent on the EU Delegated Regulation ("DR"), its application outside the EU may be restricted. - Setting standards in line with EU standards may be appropriate for markets in Europe, but problems may arise that are difficult to apply in Asian markets or non-EU countries. - Therefore, standards tailored solely to EU regulation can reduce flexibility and inclusion in global markets, and require the adoption of neutral and universal standards applicable in various regions. - In addition, the ISCC CORSIA and PLUS, which is not recognized under RED, should be voluntarily applied. 2. ISCC Co-processing Guidance v2.0 (dra ft) does not include the entire content of Co-processing. - [2 Scope and normal references describe the requirements for biomass co-processing and the requirements for compliance with the ISCC EU Scheme, and if revised, it should be an ISCC EU Document rather than an ISCC System Document. - For example, because waste plastic pyrolysis oil Co-processing does not have 14C, the corresponding Document will not be applicable, which cannot be considered as ISCC Co-processing Guidance. - In addition, ISCC EU 203 (Traceability and CoC), ISCC CORSIA 203 (Traceability and CoC), and ISCC PLUS Document each have definitions of Co processing, so it is not known which documents will be applied as a priority, and if ISCC Co-processing Guidance documents are applied at first, they should be comprehensively written to include all three certification contents. * I would like to inquire about the relationship between the ISCC Co-processing Guidance document and the ISCC EU 203 / ISCC CORSIA 203 / ISCC PLUS document. 3. The 14C-Test method of performing the 14C-Test in the final product has clear limitations, so 14C-Test recognition is essential for each production process unit. - In petroleum products, various oils produced in various processes are blended to produce products that meet the standards set by each country. - For example, in the case of 1% Co-processing of biomaterials in the aviation oil production process, the semi-finished product produced in the process may contain 0.5% bio-carbon, but in the final aviation oil product tank, it may be diluted to less than 0.01% because it is combined with other blending stocks. In addition, the 14C-Test measurement error will be very large because sample sampling errors can occur. - Therefore, 14C-Test must be performed in units of production process to accurately reflect the contribution of bio-materials, and even if the Co-processing Standard is further revised in the future, the 14C-Test method at the process unit must be effective. 4. Due to the nature of the refinery process, there are frequent changes in the operating conditions of the process, but it is unreasonable to perform 14C-Test and verify it every time. - Depending on market conditions, process operating conditions such as throughput control by process and reaction temperature/pressure control by catalyst aging are bound to change from time to time, and if 14C test is required every time, procedure/cost/record maintenance is also a big burden. In addition, if the Yield is changed through 14C test every time the operating conditions are changed, there will be great confusion in credit management. - Therefore, if the Indirect Calculation Method is applied, it is desirable to keep the Yield verified by the 14C Test results intact. - In addition, considering the difficulty of operating 14C test equipment (AMS), most economic operators will request a specialized agency to conduct an outsourcing analysis. Considering that the more frequent 14C tests are conducted, the higher the social cost, the 14C test is required only during certification examination. Verification every four months is irrational. 5. Need to abolish Co-processed product sample storage obligation - There will be physical space and additional storage costs for sample storage, and maintaining it for two years is a big burden in the aspect of operation. - In addition, it will be a quite inefficient procedure because it is not linked to the process of analyzing or verifying the stored samples by the certification body. - Therefore, the obligation to store Co-processed product samples should be abolished, and sufficient information can be obtained through verification at the process unit. 1. Related to C14 Test I understand that sample collection for C14 test should be carried out after storing the product produced by Co-processing in a separate tank, and most oil refineries are in a similar situation, but it seems difficult to secure a separate tank only for Co-processing products, and considering the situation in which it is being processed quickly, Sampling in the tank is likely to be limited in terms of volume produced by Co-processing. 2. Regarding the Yield Factor It seems necessary to create a Yield configuration under various driving conditions and apply the Yield according to the driving conditions, but there are no specific instructions for the Yield Factor, such as having to test at several points under a certain range of driving conditions, so the actual Yield Factor configuration may not be easy under the current processing conditions. 1. Since the final product of the refinery is produced by blending various semi-finished products, the actual bio-content of the final product is greatly diluted. (Ex. Diesel (final product) is produced by mixing diesel oil (semi-finished product) from the coprocessing process with diesel oil (semi-finished product) from other hydrotreaters, so the bio-content in diesel is diluted and greatly reduced. 2. Depending on the time difference, there is a high possibility that the bio-content of the final product is inconsistent with the bio-materials that have been put in. (Ex. If coprocessing is performed intermittently, the bio-content may be lost in the final product.) | 6 March 2025 |
| Anonymous | Anonymous | Anonymous | Guidance Document for the Certification of Co-processing (v2.0) | Point 3.1.3 General considerations for using a method other than radiocarbon 14C testing as the main calculation method. Page 15: We recommend to change this parragraph: The phrase “in absolute terms” is interpreted as meaning that if the bio-content were calculated as 4.9% using the yield method and the radiocarbon (14C) testing result gave a value of 6.4% this would be a discrepancy of 1.5%. This interpretation of “in absolute terms” is applied to all percentage limits given in the Delegated Regulation. to: The phrase “in absolute terms” is interpreted as meaning that if the bio-content were calculated as 4.9% using the yield method and the radiocarbon (14C) testing result gave a value of 6.4% this would be a discrepancy of 1.5%, rounded up to 2%. This interpretation of “in absolute terms” is applied to all percentage limits given in the Delegated Regulation. Point 3.1.3 General considerations for using a method other than radiocarbon 14C testing as the main calculation method. Page 15, 1st parragraph says: ...The main calculation method must be verified using radiocarbon 14C testing any time there is a change to the baseline co-processing conditions by more than 5%. At a minimum, radiocarbon 14C testing must be used to verify the results of the main calculation method at least once every four months. We recommend to add what it is defined in the Delegated act regarding a mapping method: ...Unless a method is applied that can map the operating conditions related to carbon content in the output for each batch or consignment, the radiocarbon 14C testing method shall be carried out every time that there is a change by more than 5 %. | 5 March 2025 |
| Anonymous | Anonymous | Anonymous | Guidance Document for the Certification of Co-processing (v2.0) | please find enclosed our comments on the Guidance Document for the Certification of Co-processing.: Pg.7 – 3.1. In some cases, it may be required to conduct radiocarbon 14C testing of inputs, for example where co-processing a waste of mixed bio- and non-bio-origin, such as municipal solid waste. – please specify whether each delivery in case of municipal waste needs to be tested by 14C testing or a bio-content declaration from supplier is sufficient Pg. 11 – 3.5.1. Yield method B – the method description is not clear, please specify further Pg. 12 – 3.1.1. Determination of the bio-content of the input requires the feedstocks’ moisture and non-fuel impurities to be taken into account. – please specify what is considered a non-fuel impurity Pg. 12 – 3.1.1. and 3.1.2. Mass and Energy balance method – the method description is not clear, please specify further Pg. 18 – 3.4. Where bio-based inputs with different sustainability characteristics (e.g. type of feedstock, country of origin, greenhouse gas (GHG) emissions) are coprocessed with fossil inputs, the quantity and type of the different bio-based oils is taken into account in the calculation of the biofuel output amounts. – the country of origin of the feedstock does not have an impact on the final biofuel output amounts, the parameters influencing the bio-content of outputs are specified on Pg. 13 3.1.3. Therefore, we propose to remove the country of origin sustainability characteristic from this paragraph. General comment: ,the numbering of chapters is not harmonized, and repeated numbering occurs, leading to uncertainties. For example, there is a reference to Section 3.5 regarding the indirect calculation method, but Section 3.5 appears twice in the document. | 5 March 2025 |
| Anonymous | Anonymous | Anonymous | Guidance Document for the Certification of Co-processing (v2.0) | It is not recommended to implement DraftVersion 203-01 for the following two reasons: (1).Potential Obstruction to SAF Industry Development: According to the ICAO "ACT SAF Series 7 - SAF Logistics" webinar discussion on the 14C testing issue, as renewable feedstocks continue to evolve, 14C testing may not always be an effective method for verifying all potential feedstocks. Essentially, the focus should return to feedstock traceability and the measurement and accounting of lifecycle carbon emission reductions, as these approaches provide a more effective and cost-efficient method for determining the carbon footprint of SAF. (2).Limited Availability of 14C Testing Resources: There is a shortage of certified laboratories capable of conducting 14C (AMS) testing, creating uncertainties for SAF production. For example, in Taiwan, there are no local laboratories with 14C analysis capabilities, meaning samples must be sent to overseas laboratories for testing. This process, including shipping and analysis, takes at least 14 days. | 4 March 2025 |
| Anonymous | Anonymous | Anonymous | Guidance Document for the Certification of Co-processing (v2.0) | According to the revised Standard '3.5 Reporting', it seems that C14 inspection of the final product, not the semi-finished product, is necessary, so it needs to be confirmed. If C14 inspection of the final product other than semi-finished product is required, co-processing operation is not practically possible due to the following problems. 1) Since the final product of the refinery is produced by blending various semi-finished products, the actual bio-content of the final product is greatly diluted. (Example. Diesel (final product) is produced by mixing the coprocessed diesel oil (semi-finished product) and the other hydrotreater's diesel oil (semi-finished product), so the bio-content in diesel is diluted and greatly reduced.) 2) Depending on the time difference, there is a high possibility that the bio-content of the final product is inconsistent with the bio-materials that have been put in. (Ex. Intermittent coprocessing may result in loss of bio-content in the final product.) | 3 March 2025 |
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