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
ISCC Document 203-01 – Certification of Co-Processing
The ISCC 203-10 Guidance for the certification of co-processing (v2.0) is amending the previous version 1.1. It provides more and clearer guidance on the certification of co-processing including methods to determine the biogenic content. It is currently assessed by the European Commission.
This document is subject to public consultation until 8 March 2025.
Public Consultation – Procedure
ISCC publishes fundamentally changed or new documents for public consultation. Please note that all published documents are draft documents. In addition, finalised versions of the documents might be subject to further adjustments.
ISCC invites all interested parties to send their feedback regarding the documents. ISCC will announce documents that are in the public consultation via ISCC’s communication channels in order to ensure adequate balance of various stakeholder groups.
The first round of public consultation will last 60 calendar days from the date of publishing. Please use the contact form below to submit your feedback. All fields marked with an asterix (*) are mandatory.
Where substantive, unresolved issues persist after the first consultation round, or where insufficient feedback was received (for example, inadequate representation of stakeholder groups relevant for the topic), ISCC will carry out additional rounds of consultation that last 30 calendar days. In case of necessity of another round, ISCC will make the synopsis of the previous round publicly available to comment on it.
ISCC will publish the feedback during the public consultation phase in the table below for reasons of transparency.
After the final round of public consultation, ISCC will analyse and consider the feedback received before publishing the final version of the document. All feedback is handled impartially. In case of adjustments or changes to the relevant content of ISCC EU in the version recognised by the European Commission, ISCC will notify the European Commission. Only after approval by the European Commission such adjustments or changes can be implemented. If fundamental changes of the existing system are requested (especially in the ISCC PLUS system) ISCC will notify the Board of the ISCC Association. Only after approval by the ISCC Board such adjustments or changes can be implemented.
ISCC will announce the date from which on the document will be valid and allow an appropriate transitional period for all stakeholders to adapt to the adjustments or changes.
Submit your Feedback
Submitted Feedback
Please find feedback from ISCC stakeholders regarding documents published for public consultation below. ISCC reads all comments thoroughly and considers the feedback for the further development of ISCC documents.
| First name | Name | Company | Document in Public Consultation | Message | Date |
|---|---|---|---|---|---|
| Anonymous | Anonymous | Anonymous | ISCC Carbon Footprint Certification (v1.2) | The country or region of origin of the forest biomass. Biogenic feedstock sources for SI metal operations are very global in nature. With several SI metal plants in US and China which do not currently have a robust NDC or Paris Article 5 frameworks and mechanism. Hence this clause will only become applicable to specific set of countries as of today but exclude a major portion of the market. Although ISCC certification for those biomass sites, is welcome. But an alternative should also be open for bio based charcoal which is certified by reputed organization like Forest Stewardship Council (FSC). | 7 November 2024 |
| Anonymous | Anonymous | Anonymous | ISCC Carbon Footprint Certification (v1.2) | Requirements for the emission factor of used electricity in Silicon metal. Adapted EF should be allowed to be used for Power purchase agreement which are long term and credible. If ISCC chooses to wait to add the PPA scenario in future revisions, it will hold back adoption of the new ISCC CFC certification. Most Si metal sites are neither stand alone from the grid nor have a captive renewable energy power plant. | 7 November 2024 |
| Anonymous | Anonymous | Anonymous | ISCC Guidance - Waste and Residues for Food and Food Processing (v1.0) | With reference to the ISCC Guidelines "Food waste and residues and food processing" Version 1.0, we intend to focus on point 3.1.5. on the subjects who carry out the collection practices. In particular, it is requested that the sentence "The biofuel producer supplies the virgin vegetable oils or animal fats to the UCO PoO and collects it for recovery after use" be modified with "The biofuel producer or the Collecting Point supplies the oils virgin vegetables or animal fats to the UCO PoO and collects it for recovery after use". The change request is motivated by the fact that not only the biofuel producer necessarily adopts this method, which could also be practiced by a Collecting Point which is often the first interface with the Point of Origin. | 31 October 2024 |
| Anonymous | Anonymous | Anonymous | ISCC Guidance - Waste and Residues for Food and Food Processing (v1.0) | With reference to the ISCC Guidelines "Food waste and residues and food processing" Version 1.0, we intend to focus on point 3.1.1. on the definition of UCO. Used cooking oils (UCO) are oils and fats of vegetable or animal origin that have been used in cooking, frying, preparation or preservation of food for human consumption. Food preparation includes marinating, whereas preservation involves methods such as brining and canning foods in fats or oils. We ask that the definition of “expired vegetable oil” also be added to the definition of UCO, as follows: “Expired oils and fats of vegetable or animal origin (coming for example from supermarkets or from seizure orders carried out by the public administration) can be considered used cooking oil as long as this is not contrary to any local legislation on such practices”. The request for modification can be explained as follows: The definition of waste in Directive 2008/98/EC states that waste is "any substance or object which the holder discards or intends or has the "obligation to discard". In the third case the "obligation to discard" is imposed by law or by a public administration provision. “Edible oils and fats” are waste identified with the EER code 200125 which include not only oils and fats used in cooking, frying, preparation or preservation for human consumption but also those that potentially could have been used in this sense but which for temporal and/or hygienic-sanitary reasons can no longer be used. Whether or not it belongs to the definition of UCO is not given by the cooking of the oil (or fat) but by the assumption that cooking oils are waste not produced deliberately; Expired vegetable oil is waste not produced deliberately since its belonging to the waste sphere is decided by law or by an administrative measure which no longer makes it suitable for human consumption. Proof that the UCO has expired and that it is not deliberately produced waste can be provided by attaching, at the time of transport, a declaration from the Point of Origin with a photo of the expiry date of the batch or by a report from the competent authority that it is an expired UCO. | 31 October 2024 |
| Anonymous | Anonymous | Anonymous | ISCC Carbon Footprint Certification (v1.2) | The CFC guidance would benefit from adding a requirement for technical feasibility for assignment of CO2 savings to products. The existing guidance seems to allow a situation sometimes called "overcompensation", in which the assignment of CO2 savings would not necessarily be required to reflect the chemistry of what is technically possible within the system and within the constraints of product composition. | 15 October 2024 |
| Anonymous | Anonymous | Anonymous | ISCC Carbon Footprint Certification (v1.2) | Regarding chapter 4.4.5 and Requirements for the emission factor of used electricity. : Consider requirement to use grid-specific fossil mix if there is no residual grid mix to choose for the specific region or country (average grid mix is not appropriate because of some double counting). | 11 October 2024 |
| Anonymous | Anonymous | Anonymous | ISCC Carbon Footprint Certification (v1.2) | The proposed document appeared towards certification for product carbon footprint where ISO 14067 have been quoted several times. However, ISO 14067 is developed on the strong foundation of LCA from ISO 14040/44. Thus, it is recommended to realign this document with the core principles from the ISO 14040/44. | 25 September 2024 |
| Anonymous | Anonymous | Anonymous | ISCC Document 208 - Logos and Claims (v2.0) | The document seems to me to better explain the use of logos in different situations. Nevertheless, it seems essential to me to allow the use of the ISCC Corporate Logo in black and white. Some companies don't have the option of printing their labels in color, which would exclude them from using the ISCC logo. | 22 November 2024 |
| Anonymous | Anonymous | Anonymous | ISCC Document 208 - Logos and Claims (v2.0) | In general, it’s super hard to explain “mass balance” in a way that consumers understand quickly. Any additional help is always appreciated. Can ISCC provide quicker/shorter, easily understood definitions to be used in marketing campaigns? i.e. ‘mass balance, a process that mixes plastic types to lower emissions associated with this product.’ - We reduce the consumption of fossil-based materials by sourcing 50% bio-based materials in the production of our bottle via mass balance. - Has this language been tested with consumers? Can they provide messaging bullets that work best with various demographics? Is there ever going to be a need to include license numbers on claims as to create assurance in alignment with GCD? Will there ever be an opportunity perhaps through the Carbon Footprint Certification to report on emissions savings either in marketing campaigns or within companies’ decarbonization reports? Does ISCC plan to do any experiments to gain statistics on the recognizability & trust of the ISCC logo amongst consumers? 2.3 Logos are shown for each of the following: bio, bio circular and circular- what if products use multiple ISCC materials? How can brands talk about more than one of these on the package? 4.1.3 The guide does not state approval of the phrase “made using” in reference to mass balance on logos- if this is approved language can it be explicitly stated in the guide? Similar concern as Julee. Why can’t we use the approved wording for physical segregation – is there something closer to ‘contains’ ‘uses’ or ‘is made from’? All of the approved wording options in the mass balance section are very confusing. If we’re making this claim with a specific percentage (e.g. a minimum of 51% ISCC-certified plastic), what’s the rationale for adding something like ‘linked to’? My understanding is if we use that % we are covered because it can be no lower than that in the finished good and is usually much lower (and a less powerful claim) than what teams suspect actually shows up in the product. 5.3 The logo showing X% certified plastic is improved language-wise, but I wonder if there are other improvements that could help be clearer about what this is. The magnifying glass is unnecessary and adds confusion to an already complex system. Has there been any testing around the sentiment and understanding of these visuals | 26 November 2024 |
| Anonymous | Anonymous | Anonymous | ISCC Document 208 - Logos and Claims (v2.0) | If would be helpful, if required minimum height size of corporate banner in chapter 6.1, page 34 can be added. | 26 November 2024 |
| Anonymous | Anonymous | Anonymous | ISCC Guidance - Waste and Residues for Food and Food Processing (v1.0) | We would like to propose a clarification of a production pathway of Used Cooking Oil to be included in paragraph 3.1.1 It is not clear in version 1.0 of the document whether or not fat which renders out of food while it is being cooked can be considered UCO or Food Waste. We have discussed this with auditors and consultants on many occasions and different people have different opinions which means there is probably an inconsistent application of the rules. This material is typically produced from grilling or oven cooking meat, such as burgers, rotisserie chicken, kebabs. We would like to propose that it should be stated explicitly that this material is “Used Cooking Oil”. The reasons why it should be UCO and not food waste are: 1. It does not clearly meet either of the options on the Food Waste self declaration, it is not out of date nor is it out of specification. 2. It has been through a cooking process and as the fat renders from the food it helps cook it. 3. It is usually produced in the same place as Used Cooking Oil, and the Points of Origin will mix the two making it impossible to quantify how much is UCO from fryers and how much is the fat rendered from cooking. An example of this would be a fast-food restaurant preparing chips in a deep fryer and grilling burgers and kebabs, which then puts all the oils and fats in a single barrel. 4. It is entirely homogenous with UCO; collected, treated and processed together. 5. Due to item 3 and different auditor opinions, I suspect many collectors are already collecting this material as UCO. It would simplify things if it could be explicitly stated that it is “Used Cooking Oil”. The clarification could be as simple as changing the first sentence from: "Used cooking oils (UCOs) are oils and fats of vegetable or animal origin that have been used in the cooking, frying, preparation, or preservation of food for human consumption." to "Used cooking oils (UCOs) are oils and fats of vegetable or animal origin that have been used in the cooking, frying, preparation, or preservation of food for human consumption and fats rendering out of food as they are cooked." | 29 November 2024 |
| Anonymous | Anonymous | Anonymous | ISCC Guidance - Waste and Residues for Food and Food Processing (v1.0) | The lack of markers for UCO allows for easy misclassification of virgin oils as UCO. Virgin oils used for food, however, are extensively refined during which FFA is generally brought back to max 0.1-0.15%. During food preparation FFA inevitably goes up. It would be refreshing if the guidance would be more clear, and maybe even set boundaries, for FFA levels in UCO. | 3 December 2024 |
| Anonymous | Anonymous | Anonymous | ISCC Document 208 - Logos and Claims (v2.0) | I request that the exception conditions for certified raw material content of less than 20% be maintained. Currently, the base oil market is mostly made up of waste lubricants of Group 1 and Group 2, so there is a clear limit to the supply and demand of high-quality lubricants that handle Group 3 or higher. In addition, there is also a quality issue due to technical limitations, so it is a transitional market situation where it is difficult to increase the content of certified raw materials alone without free attribution. | 5 December 2024 |
| Anonymous | Anonymous | Anonymous | ISCC Document 208 - Logos and Claims (v2.0) | Opinion on Section 3.2 “What is an ISCC Claim?” The draft has the following description: Companies should avoid using generic terms such as “conscious,” “sustainable,” and “responsible” based exclusively on recognized excellent environmental performance. Is it correct to understand that this only applies to descriptions related to ISCC PLUS certified raw materials and semi-finished products/finished products that use certified raw materials? In general, sustainability reports and news releases often describe not only ISCC PLUS certification, but also the company's overall efforts, and we believe that it is excessive to apply this clause to the entire document that contains a description of ISCC PLUS certification. To avoid any misunderstandings, it would be better to clarify the scope of application in the standard document. Opinion on Section 5.3.3 & ANNEX IV It is common for tire products to be sold in many different sizes, even if they have the same product name. Sometimes more than 60 sizes are sold. Different tire sizes may slightly change the proportion of raw materials used. If numerical values were to be shown for every size, it would be difficult for consumers to find the relevant information among the large amount of information available, which could result in information that is difficult to understand. It would also impose a heavy burden on manufacturers and sellers. Therefore, we would like the standards document to clearly state that it is possible to show numerical values within a range. (Example: Contained at least **.*%, Contained **.*% - **.*%, Linked to at least **.*% ISCC certified materials via the ISCC mass balance approach, etc.) | 27 December 2024 |
Further Information
ISCC EU 102 Governance
This document lays down the general principles according to which the ISCC is governed globally. It specifies the goal and internal structure of ISCC, as well as the relationship between ISCC and its stakeholders.
Documents recently in Public Consultation
ISCC Guidance – Waste and Residues from Food and Food Processing
This document has been in Public Consultation until 13 December 2024. The Public Consultation is now closed.
ISCC Document 208 – Logos and Claims
This document has been in Public Consultation until 28 December 2024. The Public Consultation is now closed.