Union Database (UDB)
The RED II envisions the application of a “Union database” (UDB) for biofuels and bioliquids (see Art. 28(2) Directive (EU) 2018/2001 – RED II). The database aims to ensure the tracing of liquid and gaseous transport fuels that are eligible for being counted towards the share of renewable energy in the transport sector in any Member State. ISCC regularly informs about the development process and the timeline of the UDB. This is done via the ISCC System Updates, which ISCC system users, cooperating certification bodies and members of the ISCC Association receive regularly via email. Updates on the UDB will also be publicly posted on this page.
Update from 12 January 2023
ISCC Update Regarding the Union Database
The RED II envisions the application of a “Union Database” (UDB) for biofuels and bioliquids (see Art. 28(2) Directive (EU) 2018/2001 – RED II). According to the proposed schedule by the European Commission (EC), onboarding of Voluntary Schemes (VSs) and Economic Operators (EOs) shall start on 16 January 2023 and from 3 April 2023, liquid biofuel transactions are to be registered in the UDB. The onboarding of EOs comprises the transfer of EO basic data and certificate specifics and will be handled by the VS (no action from EOs required).
From the very beginning of developing the UDB, ISCC has been an active participant in workshops and stakeholder meetings set up by the EC and has been in continuous discussions about the UDB, both with the EC and other stakeholders.
In July 2022 ISCC declared its intent to act as a Service Provider (SP) for the UDB (see our Updates of 22 October and 25 August 2022) and has been intensively testing the UDB and its functionalities since then.
In our assessment, the UDB platform is still far from a stable and technically mature state that would allow a start of operation. Also, many organisational and governance issues are still unresolved. To name but a few examples:
- Testing of realistic REDII compliant supply chain scenarios from the point of origin (material uptake) down to quota obligated parties has not been possible.
- The integration of Member States’ databases is still in its infancy. Without such integration EOs may have to process the same biofuel batch in at least two databases.
- The ‘harmonized’ materials list with more than 500 items is a good starting point but currently not aligned with Member State codes and wording.
- The system-to-system communication between EOs and the UDB and the expected role of VSs is still unclear and undefined and raises a lot of operational concerns.
- Comprehensive training as one of the prerequisites for the successful onboarding of more than 12.000 Economic Operators under 14 different VSs is not reflected appropriately in the proposed timeline.
- Tasks and responsibilities of SPs, provisions and requirements regarding data security, scope and period of data storage etc. are not legally defined yet.
For these reasons, ISCC will not be able to act as an SP and will have to refrain from doing so for the time being until a stable and reliable UDB system environment has been implemented by the EC and the framework conditions for SPs have been clearly defined. We want to stress our firm commitment for establishing an SP platform as soon as possible.
For the same reasons, ISCC also does not see itself in a position to approve third-party SPs at this point in time.
ISCC has urged the European Commission to adjust the proposed timeline for the start of operations of the UDB to avoid damage to all parties involved, including EOs, Certification Bodies and VSs, and Member States, but also the transport biofuel market as such. In our view, it must be ensured that a stable system environment and clearly defined and reliable interfaces are available at the time the UDB goes live, relevant governance and IT issues are settled, and Certification Bodies and Economic Operators can be sufficiently trained before onboarding begins.
We have raised these issues with the European Commission in a letter in the first week of January 2023 and at the same time signalled that ISCC remains more than willing to assist the European Commission in any way possible in the development and testing of the UDB.
Update from 11 October 2022
ISCC Digitalisation Processes
ISCC as Service Provider for the UDB
ISCC’s service provider platform for the Union Database is designed to be a lean and efficient interface with a focus on enabling users to upload the required information regarding their company and its transactions to the UDB with ease. In this way, ISCC will contribute to improved traceability in biofuel and bioliquid supply chains.
The platform developed by ISCC will serve as an interface to the UDB, as opposed to an additional database, with focus on facilitating the communication of information to the UDB and allowing users to view information relevant to them from the UDB in a clear and concise layout. Ensuring that the UDB remains the sole database in this environment contributes to the consistency of data and stock calculations.
ISCC system users will be automatically registered in the ISCC platform to remove yet another hurdle to interacting with the UDB, which underlines ISCC’s commitment to minimizing additional effort on the part of system users linked to the mandatory implementation of the UDB.
In terms of data security, ISCC has ensured that all servers hosting our platform are located in Europe, which ensures that all data handling is in line with GDPR rules (although there will be no personal data saved!). Data security is also improved by only saving the data which is essential for the transfer of transactions to the UDB. Finally, all transfers are encrypted in line with the industry standard.
ISCC is in the process of planning and conducting pilot projects with some key partners to test its functions and identify ways to further improve the platform’s user-friendliness and utility for the economic operators that will be using it. In this context, ISCC is very thankful for the support being provided to us by the companies who are taking part in the pilots.
ISCC will also be instrumental in providing mobile apps for the first uptake of eligible material into the platform both for agricultural commodities as well as waste / residues such as UCO and POME. The use of these apps will increase the data integrity and at the same time support third party audits.
ISCC Registration and Document Submission System
A further element of ISCC’s digitalisation efforts is the development of an online system which will improve the current processes for registering new system users and submitting audit documents. The registration process will incorporate automated due diligence checks to improve confidence in the veracity of ISCC system users. Beyond this, system users and certification bodies will be able to update company information themselves to reduce the burden of communicating changes to ISCC by email. Finally, there will be an interface for submitting audit packages which will display the required documents based on the specific audit based on the answers in the APS audit and the scope of the certification.
Update from 25 August 2022
The RED II envisions the application of a “Union database” (UDB) for biofuels and bioliquids. The database is currently being developed by the European Commission (EC).
In this framework, ISCC is presently working on various topics:
a) ISCC is setting up a tool for making registration and certification more efficient for CBs and System Users:
The digitalization of certification processes presents challenges, such as the increasing documentation requirements by the EC. ISCC is working on facilitating workflows and at the same time providing system users with the means to seamlessly demonstrate that their actions are sustainable. For this, a new online data management tool is currently in the making. ISCC will provide more information in due time.
b) ISCC will act as a Service Provider (SP) for all ISCC System Users and will also offer this service to other Voluntary Schemes (VS) and their Economic Operators (EO):
With the ISCC application, that will be linked to the UDB, the process of data provision for system users will be facilitated. ISCC System Users, as well as other EOs and VSs will have the exclusive choice of the ISCC application for the transfer of their data.
c) ISCC is conducting pilots to adapt the system to user needs:
ISCC is conducting pilot projects to test the data flow from economic operators to the service provider system.
ISCC will keep you updated about the development process and timeline of the UDB in System Updates and on this page. Please kindly note that it is not known yet when the UDB will become operational.
Update from 22 July 2022
The RED II envisions the application of a “Union database” (UDB) for biofuels and bioliquids (see Art. 28(2) Directive (EU) 2018/2001 – RED II). The database aims to ensure the tracing of liquid and gaseous transport fuels that are eligible for being counted towards the share of renewable energy in the transport sector in any Member State. The database is currently being developed by the European Commission (EC). Once it has started its official operation, relevant system users are required to provide specified information to the UDB on sustainability and GHG emissions savings characteristics that are related to batches of sustainable material transferred along the supply chain.
ISCC is an active participant in workshops and is in continuous discussions about the UDB with the EC and other stakeholders. ISCC has already set up a database to facilitate the process of data provision for system users and is working to link this database to the UDB, i.e. ISCC will also facilitate the process as service provider (SP). As soon as the development process by the EC has proceeded so that the role of the SP and its interaction with the UDB is more clearly defined, ISCC may reach out to system users to participate in pilots.
ISCC will keep you updated about the development process and timeline of the UDB. Please kindly note that it is not known yet when the UDB will become operational.