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

Currently, there is no document in the Public Consultation.


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.


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Public consultation
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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 nameNameCompanyDocument in Public ConsultationMessageTimestamp
AnonymousAnonymousAnonymousISCC Credit Transfer System (v1.0) – Consultation open until 07 January 2024- Re slide 9 - what if the PoS has been retired downstream and is not available for submission in the registry?

- Are the scope 1s transferable? How would the contract with the airline who buys the scope 1 be managed, so they understand that the SAF they
are purchasing does not have any scope 3 emissions characteristics attached - what systems do you have in place to ensure scope 3s are not
sold without the scope 1 being burnt first?
2024-01-04 12:34:47
NoelleFroehlichDHL GroupISCC Credit Transfer System (v1.0) – Consultation open until 07 January 2024We welcome this initiative by ISCC. A registry is urgently needed to increase transparency on the chain of custody from feedstock origin all the way to SAF related claims in corporate carbon inventories in Scope 1 and Scope 3 irrespective of if it is via credit transfer or conventional physical delivery. In addition, once the chain of custody is secured via a registry, a credit transfer system is the logical next step to reduce unnecessary physical transport of SAF and market barriers for players without access to physical SAF supply. A well-designed credit transfer system will help to accelerate the SAF ramp-up without compromising on credibility of claims.

For DHL Group, the most important aspects in a credit transfer system (Book & Claim) are the following:

1. Removing the requirement of SAF being physically delivered to the airline that makes the Scope 1 claim. It is a significant challenge especially for small SAF producers to get access to airport fueling infrastructure. Allowing them to deliver SAF to the airport of their choice with easiest access for them and independent of the customer airline will facilitate market entry for them. In addition to that, it will reduce unnecessary transport of SAF molecules. This is currently not foreseen in the proposed credit transfer system, and we would urge ISCC to implement this.

2. Ability to allocate environmental attributes (emission reductions) to customers of transportation services on a marked based approach: We need to enable our customers to contribute to our SAF uplift and receive the resulting environmental attributes in return. It is practically not possible to ensure the respective volumes are on the exact same plane as those customers’ shipments. We argue that we need to be able to allocate emission reductions across our network to any specific customer. At the same time, where we are customer of transportation services (Scope 3 user), our carriers must have the same possibility to allocate environmental attributes to us when we purchase low-emission transportation services from them, irrespective of the specific flights / trade lanes where physical SAF is available. This is currently fulfilled by the proposed credit transfer system.

The current draft foresees the option to sell the environmental attributes for Scope 1 and Scope 3 separately. We acknowledge that this will contribute to the aim of facilitating a market ramp-up by increasing the potential customer base for SAF independent of individual airline – end-customer relations. We do not oppose this rule but would like to highlight that it poses at least the same or even higher risk of illegitimate claims as the separating the physical delivery from the scope 1 claim (as proposed by ourselves above). Therefore, we strongly urge again to decouple the physical delivery from delivery of environmental attributes in general and would then even be open to limit passing of Scope 1 and Scope 3 in a bundled way. This however is deviating from other published frameworks currently available (e.g. Smart Freight Centre’s Market-based Measures Framework, RSB and SABA’s Book & Claim frameworks). In general, alignment with and interoperability of other existing book & claim frameworks – as far as possible – is important for DHL Group from a SAF user perspective.

We acknowledge that the two above mentioned objectives need to be restricted by constraints to ensure credibility and reliability. These should cover modal and/or fuel type constraint (i.e. only SAF can be accounted for aviation), vintage rules and additionality requirement and might cover related aspects (such as consideration of additionality with a geographic constraint). The proposed credit transfer system considers an overall reasonable set of constraints. However, regarding definition of additionality we have a diverging view:

The current proposal defines additionality via mandates or significant incentives. We agree with the argument that SAF volumes that are counted towards a blending mandate are not additional. However, we argue that all other known incentives (EU-ETS, CORSIA, LCFS, RFS, HBE, RTFC, BTC) are for voluntary uplift of SAF, meaning that any volume used under such incentive is voluntary, hence additional. The current draft document excludes such incentives if they “substantially incentivize” the SAF. We would argue that the incentive from most of the named incentives is substantial, but the remaining price premium also remains substantial (1000 €/t and higher). Therefore, voluntary use of SAF remains a significant financial commitment despite use of incentives and will not happen if customers are not able to account for related emission reductions.

The registry will need to recognize emerging and existing frameworks for trading emissions reductions like insetting or other market-based measures that will require additional data fields in the future. For example, the SFC MBM Framework introduces the concept of “Low emission transportation services” (LETS) that also add certain requirements like the transport activity in tkm and adherence to rules on vintage and additionality to a set of data points that need to be registered and traded.

As long as this is not the case, the registry needs to acknowledge that there will be other systems and mechanisms, that will allocate and assign LETS to customers and ideally it should be able to provide a certain hand-over-compatibility to ensure a cross-system chain of custody. I.e. it should be possible to not only retire emissions reductions on behalf of a customer but also in connection with a unique, traceable and immutable ID.

ISCC should continue to engage in the discussion on a global scale to help create a credible and recognized market for trading sustainable fuels and environmental attributes. Hence an involvement in the upcoming TWG on Market-based measures from the GHG Protocol would be desirable.

We propose to extend this registry to other sustainable fuels (such as marine and road fuels) as soon as possible.
2024-01-05 10:20:59
AnonymousAnonymousAnonymousISCC Credit Transfer System (v1.0) – Consultation open until 07 January 2024Thanks for allowing me to provide feedback and congratulations for this initiative. After a first read, some points need clarification:
- Please define "substantially incentivized" in the additionality criteria (is a zero-emission factor claim under ETS a substantial incentive? Is the claim under CORSIA eligible fuel a substantial incentive?)
- What is the point of showing SAF incentives used in point 6.4 in the registration of the SAF credits, if this is not compatible with using the credits in the ISCC Credit Transfer System?
- How can this be linked to the UDB and other national databases to confirm no double counting?
- Scenario explanation (similar as those used in ISCC guideline 203 Annex I) would be appreciated and useful
- Has the consultation been extended to airline operators, even if they are not System Users?

Thanks and best regards
2024-01-05 10:24:15
LukeGreiciusEvidentISCC Credit Transfer System (v1.0) – Consultation open until 07 January 2024We welcome the opportunity to respond to the ISCC Credit Transfer System consultation. Evident EV Ltd operates registries services for a range of environmental attribute certificates (EACs), providing a single source of truth for renewable electricity (I-REC), sustainable aviation fuel (Fly-i), and durable carbon removal (C-Capsule), among others. We help ensure that every transaction and consumer claim is uniquely traceable to the activity associated with a certificate’s creation. We have substantial experience operating book and claim systems and registry-based services in over 50 countries.

Integrity is at the core of our business, and it is essential to ensure the credibility of the markets we are helping build. Establishing transparent standards and rules through public consultation is the foundation of this integrity, and we support ISCC’s efforts in this regard. As many of the technologies required to achieve global decarbonisation goals remain at an early stage, we favour an ‘all-of-the-above’ approach to solutions, incentives, and broad competition in the market, particularly as we urgently seek scale.

We recognise and appreciate the steps that ISCC has taken to ensure that the SAF Credit Transfer Registry design is robust. At the same time, we would emphasise the importance of acknowledging the work being done by others developing SAF certification and registry schemes, including Evident, RSB, SABA, etc. While multiple products and approaches are natural at this stage in the SAF market’s development, we believe it critical to harmonise and align efforts, principles and standards as much as possible. This will inevitably strengthen credibility, ensure a level playing field, and reinforce controls against double-issuance and double-claiming – one of the most challenging aspects of a multiple-registry system. While ISCC’s public consultation here is an important element, we would flag ongoing efforts by RSB to develop a registry Recognition Framework as a valuable mechanism as well.

Regarding the content of the ISCC System, we would like to highlight the following observations on potential areas for additional consideration. We would welcome future opportunities to discuss these in more detail directly.

1. Governance/structure: With regard to overarching governance and structure, our view is that it is important to have an independent issuing body/verification authority – distinct from the registry operator, standard setting body, and other market participants – to provide an additional layer of independent verification to the process. This separation of roles, typically also including an independent registry operator, helps prevent unintentional errors and inconsistencies as well as wilful attempts at double-crediting – generally helping shore up concerns about credibility. This approach is similarly recommended by the leading environmental attribute tracking standard body, the I-Track Foundation, founder of I-REC.

2. Downstream transfer limitations: We note that ISCC has opted to restrict the transfer of SAF credits to direct downstream participants (i.e. from SAF producer to scope 1 aircraft operator to scope 3 air services customer). Within the consultation, ISCC precludes transfer across value chains, citing the aviation guidance of the Science-Based Targets Initiative (SBTi) and underlying standards designed by the Greenhouse Gas Protocol (GHGP). We understand the decision to limit transfers to within value chain is to ensure integrity and emissions impact. While this approach does necessarily reduce risk, we question the additional protection it affords. Existing requirements in the ISCC rules restrict claims to in-sector usage only up to the emissions produced by a claimant, and mandate third-party validation of claims. We are concerned that limiting transfers of credits to the downstream value chain may potentially limit market growth at this early stage. Book and claim systems are designed to overcome challenges linked to supply/demand discontinuities, which are acute in the SAF space. By limiting a SAF book and claim system to use-cases where consumption can be closely tracked from producer to consumer to end-user, large portions of the global market could be excluded from the ISCC System – whether because of a lack of technical or monetary resources required to demonstrate valid claims, a lack of local supply, or a lack of local demand. It is worth noting that developing economies and the global south would likely be disproportionately affected by these constraints, exacerbating prevalent global inequalities in climate financing.

Additionally, while alignment with standard-setting bodies like SBTi and GHGP is important, it is worth reinforcing that the guidance cited in the ISCC System documentation is currently under a concerted review process. While SBTi currently restricts transfer of SAF attributes across value chains, this could change if a more expansive view of market-based instrument usage takes hold. Locking in restrictions in an evolving market, particularly restrictions where the cost-benefit balance may be questionable, while conservative, risks undermining the effectiveness of an essential instrument to drive market growth.

Furthermore, the Smart Freight Centre (cited as a reference in the ISCC System documentation) explicitly encourages the development of systems that are ‘flexible enough to incentivize the uptake of SAF,’ highlighting the below recommendations in the paper ‘Sustainable Aviation Fuel Greenhouse Gas Emission Accounting and Insetting Guidelines’:

‘An important aspect of the book and claim system for insetting described in these guidelines is that it allows a carrier, and the logistics service providers, shippers, travel management companies, and business travellers that the carrier serves, to purchase and report SAF environmental attributes from a fuel supplier whether or not that fuel supplier provides aviation fuel to the carrier.

This flexibility removes barriers to the uptake of SAF associated with the structure of fuel purchase contracts. Specifically, it allows:

(1) A carrier to purchase and report SAF environmental attributes without that carrier having to cancel or change existing fuel supply contracts.

(2) Shippers, logistics service providers, business travellers, and travel management companies to purchase and report SAF environmental attributes without having to convince air carriers to change fuel suppliers.’

3. Additionality requirements: The additionality criteria are core elements of a system designed to accelerate decarbonisation. However, the ISCC System documentation as drafted appears to attribute too much impact to regulatory and government incentive schemes in driving supply up and price down toward proximity with conventional jet fuels. While these regulatory requirements and tax incentives are certainly responsible for some reduction in cost, helping bridge SAF’s green premium, participants in early SAF offtake agreements have underscored the importance of the additional revenue from certificates or credits – in addition to regulatory demands or incentives – in making the purchase viable. As such, omission of any fuels incentivised in part by tax benefits could preclude much of the current and projected near-term supply of SAF from being credited. Many analysts estimate that SAF supply through 2030 may be able to meet regulatory demand (e.g. from ReFuel EU, EU ETS, CORSIA, and various national targets), but there will likely not be additional capacity to meet purely voluntary supply.

We are grateful for the opportunity to respond to this consultation. Please let us know if you would like to discuss any of the issues we have raised. We welcome the opportunity to continue to collaborate on building a viable, credible, and robust SAF market.

Kind regards,

Evident

Theo-Platts Dunn, Policy Associate (theo.platts-dunn@evident.global)
Luke Greicius, Head of Policy (luke.greicius@evident.global)
2024-01-05 15:52:17
LauraHutchinsonRMIISCC Credit Transfer System (v1.0) – Consultation open until 07 January 2024The SAFc Registry team commends ISCC for the well-written system document and building the ISCC Credit Transfer System. We believe that standardizing requirements across SAF certificate systems and registries (or SAF credit transfer systems) would contribute to clarity for users, enhance the use of SAF certificates to drive aviation decarbonization, and facilitate interoperability among registries. Therefore, we look forward to collaborating with ISCC on registry and related topics, and in this vein, provide the following feedback:

Feedback 1: The SAFc Registry allows units to be issued any time after the neat SAF is blended with conventional jet fuel or certification of the neat SAF to ASTM D7566. In our view, certification of neat SAF to the ASTM standard provides reasonable assurance that the SAF will be consumed/combusted for aviation-related purposes.
o The ISCC system requirement that credits can only be generated after the SAF enters a jet fuelling system presents a challenge for interoperating with the SAFc Registry and the Roundtable on Sustainable Biomaterials (RSB) Book & Claim Registry, both of which allow issuance of units any time after SAF blending

Feedback 2: How would the ISCC system verify the requirement for retirement or transfer of credits to organisations in the retirer’s/transferrer’s value chain? For example, where a SAF supplier is retiring credits on behalf of aviation end-customers. In essence, how would the ISCC system prove an entity is in another’s value chain?
o It is our view that to facilitate the use of aviation-based sustainability credits (equivalent to SAF certificates in the SAFc Registry) to drive demand for SAF, the ecosystem for SAF certificates will benefit from market intermediaries as well as air transport providers, logistics service providers, and aviation customers that may not have access to direct purchase and combustion of SAF. Further, broadening the category of entities that can receive and retire SAF certificates will contribute to wider use of such certificates to stimulate SAF production, and deeper market liquidity for aviation-based sustainability credits.
o The SAFc Registry allows for transfer of units to (or retirement on behalf of) accounts that may not be in the retirer’s value chain. We believe that because units are issued based on SAF, that its supplier was verified in compliance with the applicable ISCC (or RSB) sustainability certification schemes, such SAF can only be consumed for aviation purposes. Therefore, the use of SAF certificates will be for in-sector reduction of aviation emissions and so, the requirement for transfer to (or retirement on behalf of) organisations in the transferer’s/retirer’s value chain is not necessary.

Feedback 3: We believe the requirement for ISCC trader certification burdens SAF suppliers with concurrently meeting both ISCC and RSB trader/operator certification terms and could result in higher costs and complications for SAF suppliers. Given that both ISCC and RSB are approved by the EU and ICAO for their respective SAF sustainability certification schemes, our understanding is that at the very least, the trader certifications for ISCC EU and ISCC CORSIA are equivalent to RSB’s. This understanding is also borne out from our review of the respective ISCC and RSB documents.
o Hence, we suggest that in addition to accepting ISCC trader/operator certification, ISCC accepts trader/operator certifications by RSB. (Note that we’ve suggested the same to RSB).
o Given the increasing attention and intent of organisations to use SAF certificates to demonstrate aviation-related emissions reductions, we urge ISCC to conduct a timely benchmarking exercise on RSB trader certification.

Feedback 4: The requirement for SAF to be in the SAF supplier’s chain of custody when issuing its associated credits (according to page 16, paragraph 3) appears to conflict with that for SAF to be delivered to the control point before credit issuance (according to page 6, paragraph 2).
o There is a need for ISCC to reconcile the seemingly contradictory requirements or clarify which requirement takes precedence.

Feedback 5: We acknowledge ISCC’s argument that the allowance for only POS is a safeguard for additionality. The SAFc Registry, however, allows for issuance of units for which the POS is not available for submission. We believe this is useful if fuel providers submitted their POS against SAF produced to meet a regulatory scheme that passes the additionality test of the SAFc Registry. The SAFc Registry evaluates additionality in line with the assessment tool published by the Sustainable Aviation Buyers Alliance [available at https://flysaba.org/atmospheric-benefit-principle-evaluation-tool/]. Such providers can submit a proof of compliance (POC) in place of a POS.
o The SAFc Registry prevents the issuance of units associated with SAF produced to meet incentives and regulatory schemes that fail its additionality test.

Feedback 6: What are the implications if a SAF volume is not additional? Would no credits be issued, or would only Scope 1 credits be issued?
o The Sustainable Aviation Buyers Alliance (SABA) has published a tool for assessing the additionality of incentive schemes and regulatory programs [available at https://flysaba.org/atmospheric-benefit-principle-evaluation-tool/]. We recommend the tool as a resource for ISCC in determining what SAF volume or GHG emissions reductions are additional.
o Alignment amongst registries on criteria for SAF certificates to be additional will help improve clarity for the industry a nd contribute to registry interoperability.

Feedback 7: It is not clear how the requirement for ‘the SAF supplier to register credits no later than 30 days after SAF delivery to control point’ and ‘the SAF supplier to register credits for SAF in their chain of custody system’ can be fulfilled at the same time.

Feedback 8: Given the multiplicity of registries and need for interoperability amongst them, we encourage ISCC to publish a minimum set of criteria for recognizing non-ISCC operated registries.

Feedback 9: We encourage ISCC to, through the Book and Claim Community [https://bookandclaimcommunity.org/] and other forums, help identify unique but common SAF batch information and documentation that prevents issuance of the same SAF volume in more than one registry.

Feedback 10: How will the ISCC Credit Transfer System ensure that a SAF volume has been ‘booked out’ of traceability databases for regulatory compliance? (Page 16, paragraph 6 notes that compliance fuel volumes should be booked out of Union Database or Nabisy).
2024-01-07 17:51:52

Further Information

This document lays down the general principles according to which the ISCC is governed globally. It specifies the goal and internal structure of ISCC, as well as the relationship between ISCC and its stakeholders.

Documents recently in Public Consultation

ISCC Carbon Footprint Certification (v1.1)

This document was subject to public consultation until 13 May 2024. The public consultation is now closed.