Stakeholders · Public Consultation

Get involved and participate in the ISCC multi-stakeholder dialogue

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 here.

As ISCC is continuously working to improve the ISCC System, feedback from companies using ISCC, certification bodies and other interested third parties is an important source for the ongoing development and therefore highly welcome.

 

Documents in the Public Consultation:

The public consultation of the ISCC PLUS system document has closed. ISCC is currently working on the feedback. The final version of the document will be published in January 2023.

ISCC PLUS System Document (v3.4)*

This document was subject to public consultation from 06 September to 05 November 2022. It is not yet the final version.

Public Consultation – Procedure

  1. ISCC publishes fundamentally changed or new documents for public consultation below. Please note that all published documents are draft documents. In addition, finalised versions of the documents might be subject to further adjustments.
  2. 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.
  3. 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.
  4. 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.
  5. ISCC will publish the feedback during the public consultation phase in the table below for reasons of transparency.
  6. 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.
  7. 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

Public consultation
I agree that ISCC will publish my statement on the ISCC website *

 

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.

Draft DocumentVersionDateFeedback from Public ConsultationName, Company
ISCC PLUS System Document3.405.09.22It seems to be relevant to provide better clarification for option 3 of mass balance. Some system users have difficulties to understand the approach for option 3. Clarification slides have been included in ISCC training materials and the same description together with an example (as given for option 1 and 2) should be included in ISCC document.Szymon Kołodziejczyk, Bureau Veritas Polska sp. z o.o.
ISCC PLUS System Document3.407.09.22Dear ISCC Team ,
we received the latest system update on ISCC PLUS documents and we would appreciate your clarifications about the new provision of paragraph 11.7 ( GHG Continuous improvement plan :
- the reduction of GHG emersions due to improved practices , in the event company product processing emissions improvement how such should be claimed and accounted ?
- which are the compensations measures that are to be reported separately ?

thank you very much in advance for your guidance and response

with my best regards
ISCC PLUS System Document3.414.09.22Hello,
It seems like summary of the changes and the changes itself do not fit always each other. E.g. The change mentioned for chapter 5.2.1 is in chapter 5.
Regards,
Niklas Rad, Berry Superfos Packaging Bremervörde GmbH
ISCC PLUS System Document3.422.09.22Dear,
We have reviewed the ISCC September 2022 system update which includes the handling of N and O atoms.
Accordingly, we would like to get a couple of points clarified.

I will send you an email with the referred document. The attached document contains a visual representation of our chemical processes which includes our remarks/questions per subprocess for clarification. The questions in this email repeat the questions in the powerpoint file but are guided by the concerned text fragment from the ISCC system document.

Firstly, paragraph 9.3.2 (page 30) describes:
Next to the above outlined attribution approaches, also the Trace-the-Atom option (option 3, see figure 4) can be used to determine the conversion factor and sustainable share. The equation of the chemical reaction used for the production of the sustainable product is followed. Consequently, the conversion factor is based on the share of (carbon) atoms derived from the sustainable input in relation to all (carbon) atoms that are part of the output molecule.. Operational data of the processing unit must be used to take process losses into account and determine the sustainable output.

Could you clarify if this paragraph is not only intended for the handling of C atoms, but incorporates the handling of O and N atoms as well. Based on the methodology description of 9.3.6. about the handling of O and N atoms in the ISCC scheme this seems the case.

Next, paragraph 9.3.5 (page 33) states:
For example, in case of a chloralkaline processing unit in which renewable
electricity, sodium chloride and water are used to produce chlorine as the main product, the process yields equivalent amounts of chlorine, sodium hydroxide and hydrogen (for every mole of chlorine produced, one mole of hydrogen and two moles of sodium hydroxide are also produced). In this case it is not allowed to e.g. transfer sustainable credits from chlorine to hydrogen or vice versa.

Based on this paragraph and Annex 1.4 example 3 we would appreciate clarification about the handling with NaCl which is a mineral, and water.
Namely, Annex 1.4 states that:
The material feedstocks water and sodium chloride itself are not certified. All products of this production process (chlorine, hydrogen, sodium hydroxide) can be claimed “renewable-energy-derived”. The sentence indicates that it is allowed to claim that the end-products of this production can be claimed “renewable-energy-derived”. As OCI has the aim to sell CAN (Calcium Ammonium Nitrate) based on biogas (which will replace our natural gas input and result in a 100% renewable input), we do not see the difference between NaCl and dolomite as both materials are minerals and derived from the soil. Why shouldn’t it be possible to make a 100% claim for CAN when it is possible for Chlorine with NaCl as input material?

Lastly, regarding water we have multiple questions, that can be supported by the example of nitric acid production: The final product is a 60% solution in water. The nitric acid (HNO3) is formed by the oxidation of ammonia (NH3 + O2 from air). In the reaction water is formed, this constitutes for about half of the water in the final product. The remaining water is added.
- Is there a difference in water used/produced in chemical reactions and water added to the product (e.g. for dilution)?
- As water is the lowest energetic form of hydrogen, should water (in reaction) be treated similar to CO2 (which is the lowest energetic form of carbon)?
- It is possible to produce hydrogen with a claim from uncertified water and renewable electricity (electrolysis) or from uncertified water and biomethane (bio-steamreforming). What would be the classification of water produced once the certified hydrogen is burnt (or when water is formed in another reaction)?

Hope you can clarify.
KR,
ISCC PLUS System Document3.413.10.22The benzene part of the phenol molecule is determining the (bio-)circular content. This content is calculated by dividing the benzene molecular weight and the phenol molecular weight:
(78.11 / 94.11) x 100% = 82.9986%. Rounded to two decimals the (bio-)circular content becomes 83.00%.

From a “weight% point of view”, the hydrogen atom of the hydroxyl group of phenol comes from benzene. The oxygen atom comes from air.

The oxygen from air can’t be seen as a contribution to the sustainability content of phenol, since oxygen from air is not derived from biomass. Therefore, the correct (bio-)circular content of phenol amounts 83.00 weight%.
ISCC PLUS System Document3.419.10.22Chapter 5.1 (on page 8; paragraph 1 “Acceptance of certification schemes”; line 1 f.)
Proposal: The document should instead lay out objective acceptance criteria to enable future scheme applicants to compete and to contribute to sustainable raw material change. As a minimum, schemes already recognized by the EU Commission regarding the RED should be accepted.

Chapter 5.3 (on page 11; paragraph 3 “Multi-input processes”; lines 1-4)
Proposal: 2nd part of the sentence after the comma should be deleted, because it might reflect only one of three possible MB models (Trace-the-Atom).

Chapter 5.4
Proposal: Please align with the requirements of the Together for Sustainability (TfS) guideline.

Chapter 5.5 (on page 12,13; paragraphs 2 and 3)
Proposal for post-consumer material: EN 45557:2019 to be deleted
Proposal for pre-consumer material: Change to standard 14021, since 472 is under revision. The goal should be to reference to only one standard.

Chapter 7.3
Proposal: To be deleted “according to EN 15343”

Chapter 9.3 (on page 24; paragraph 1 “Mass balance”; lines 1-4)
Proposal: Please change from “remain assigned to batches of material” to “remain assigned to deliveries of material”

Chapter 9.3 (on page 24; paragraph 1 “Mass balance”; line 6)
Proposal: The maximum mass balance timeframe of 12 months would be helpful.

Chapter 9.3.2 (on page 27; paragraph 4 “Mass balancing based on input, output and losses; line 9)
Proposal: Regarding the term “share” it would be helpful to include an example in the annex, e.g. based on mass.

Chapter 9.3.2 (on page 27; paragraph 5 “Certified free attribution and certified energy excluded attribution for mass balancing”; line 7-9)
Proposal: Before the sentence “However, as described above, process losses (e.g., energetically used inputs) need to be considered for the calculation of the conversion factor.” comes into force, it must be agreed beforehand (e.g. all cracker operators). The topic must be brought into the MB Working Group.

Chapter 9.3.2 (on page 28; paragraph 6 “Mass balancing based on chemical reactions”; line 4-7)
Proposal: The sentence “Consequently, the conversion factor is based on the share of (carbon) atoms derived from the sustainable input in relation to all (carbon) atoms that are part of the output molecule.” has to be clarified.
Free attribution with different allocation methods should be allowed as described in different ISO standards e.g. ISO 14044

Chapter 9.3.3 (on page 30; paragraph 2; line 6-7)
Proposal: Please include a footnote “* The conversion factor is here defined as the chemical yield of the process.”

Chapter 9.3.5
General remark: The chemical industry needs the free attribution approach for renewable electricity.

Chapter 9.3.5
Proposal: Change of the heading to "Consideration of hetero atoms"

Chapter 11.1 (on page 33; paragraph 1 “Emission factors”; line 7)
Proposal: Sector-specific category rules like TfS must be also possible and recommendable. So please delete ISO 14064. This standard is not relevant for the calculation of product carbon footprints.

Chapter 11.5
Proposal: Change the heading to “Allocation in multi-output processes”

Chapter 11.5 (on page 33; paragraph 1 “Allocation of GHG emissions”; lines 3-4)
Proposal: 2nd part of the sentence after the comma should be changed within the bracket from (e.g.based on mass) to (e.g. as described in TfS or PCF guideline or ISO 14044).

Chapter 11.6 (on page 34; paragraph 2; lines 3-4)
Proposal: editorial change to “of 14040/14044 or in 14067”

Chapter 11.7 (on page 34; paragraph 1; lines 1-3)
Proposal: Change from "must be available" to "should be available"
ISCC PLUS System Document3.428.10.22Group Certification - Our distribution company has multiple subsidiary companies which for legal reasons purchase materials in their own name. Each subsidiary is currently classified as a Trader with Storage. However, all purchases are made using the same standard corporate wide ERP system and they use the same processes. (All the subsidiaries operate under a single matrix ISO9001 certificate). Under the proposed Group Certification / LRD definition there is no opportunity to participate in the Group Certification scheme. This means that each site has to have its own annual on-site external audit of the common corporate processes. This is neither very green nor supportive of a sustainable approach and quite costly. Could a broader definition be applied to Group Certification whereby any subsidiary companies which are part of the same parent corporate entity be permitted to be classified as an LRD or be part of a matrix certification whereby only a sample of the total number of subsidiaries is audited annually?

Remote audits - One solution to support a sustainable approach would be to permit remote audits which would be greener and have the additional benefit of freeing up external auditor time as they would not be required to travel as much. They could use this time to carry out additional ISCC scheme audits at other companies.
ISCC PLUS System Document3.429.10.22Par 12.2 refers "The group certification approach for Final Product Refinement (FPR) activities
(see chapter 5.7.5)".
Par 5.7.5 dies not exist.
Aris Gorogias, Green Trust
ISCC PLUS System Document3.431.10.22As par. 9.3.2 - "Mass Balancing Approach under ISCC PLUS" is the core for the correct understand of all possible approaches that a company can apply, it should include more examples (with numeric values) for each possible choice.

Furthermore, as it is still not clear to all companies the meaning of "Total quantity of certified material" in the Sustainability Declaration, I suggest also in this case to include an example with a numeric value in the par. 9.1 - "Requirements for Sustainability Declarations".
ISCC PLUS System Document3.431.10.221) Attribution mass balancing: “Certified Energy Excluded Attribution”

Clearer explanation of what is meant by “energetically used outputs” is required.
An explanation of what is meant by “material outputs” is required, to complement the above.

Some clarity around the procedure for determining the energetic use of an output – some outputs can be used for both fuels and intermediates. It will be too administratively burdening to constantly track sales of products and their uses. We also do not have control over what our buyer does with the product, even a ‘typical’ chemical company may have the opportunity to put the product into fuels. If the approach was instead to forecast sales, this would not be possible. This approach would bring operators legal/economic uncertainty on what might happen if the forecast was wrong, which might lead to a paralysis of activity for serious companies who wanted to participate, or a lack of credibility for the other companies.

We recommend adding a category defined as ‘dual use’ products. These are products that could go into either chemicals or fuels, and should be considered into the chemicals pool for the calculation of the conversion factors. We propose that ISCC include a definitive list of products that are within each category, to make it immediately clear to the system user how to calculate their conversion factor.

Given the concerns raised from some of the end-consumers that was raised in the working group, we suggest that the inclusion of Energy Excluded Attribution in it’s proposed form is carefully considered by ISCC. It may be more beneficial to re-define the methodology and run another public consultation.

2) GHG Continuous Improvement Plan

More clarity or an example of an acceptable continuous improvement plan should be given. It is unclear why a continuous improvement plan must be made available in a scheme that is for voluntary markets. It should be optional.
ISCC PLUS System Document3.431.10.22We noticed that, in an other page of the document, the process losses refer only to the gas flaring (p. 26 : “Process losses (e.g. gases to flare) are deducted from the conversion factor”), which is consistent with our understanding of what is to be considered as a process loss under the current ISCC+ reference document.

In the case of a steamcracking, does it mean that to compute the conversion factor, the ISCC+ 3.4 version will require to substract the fuel gas derived from the sustainable inputs ?
Note that, this fuel gas is usually used as a combustion within the unit. It means that it is not a loss of the process but an optimization of the outputs.
ISCC PLUS System Document3.402.11.22In 9.3.3. is mentioned that when the amount of all additives is > 3%, this can not be neglected anymore. I think this text is more clear than in the current standard. When companies have to apply this (after publication) will there be a transition period (for instance the mass balance period (max. 3 months) before a company have to apply this requirement?

Par. 11.7. describes that a company that uses Add-on for GHG, must have a long-term GHG Continuous Improvement Plan regarding a reduction commitment. Can companies decide the timeframe of the plan and the percentage of the reduction commitment? Will ISCC set up a guideline on the timeframe of the plan and the reduction commitment? Is other regulation applicable here?

Par. 12.1. describes that the LRD's must be mentioned on a list. For verification for the client the ISCC certified company can provide the verified list to the customer. I think it would be better idea to provide the list of LRD's on the ISCC certificate as an annex. How will the customer know the LRD is on the verified list, which is audited by the CB?
ISCC PLUS System Document3.403.11.221. Paragraph 9.3.2. Addition of the “Certified Energy Excluded attribution” approach as another calculation method for credits attribution alongside “Certified Free attribution”.

A. We understand that another calculation option is provided by ISCC PLUS certification, so that a company adopting mass balance option 1 or 2 may choose between “Certified Free attribution” or “Certified Energy Excluded attribution” methods. As far as we understand the calculation method may be chosen freely, regardless of the type of product, its category (bio, bio-circular, circular,…), the feedstock. Is it so or will be there rules regulating the calculation options? If companies use the “Certified Energy Excluded attribution” method for one specific product, then can they switch back to the “Certified Free attribution” method for another product or even for the delivery of the same product to another customer?

B. On page 28 footnote 17 states: “In case of simultaneous ISCC EU and PLUS certification: sustainable parts of sold fuels can be used under ISSC EU.” Does that mean that if System Users are certified both ISCC EU and PLUS and they produce a sustainable material by using the “Certified Energy Excluded attribution” approach under ISCC PLUS certification, they will be able to exploit also the part of credits allocated to fuel products by transferring them into the ISCC EU mass balance? The possibility to use also the credits allocated on fuels is very interesting but how can this operation be performed if we consider the requirement indicated on page 26: “Operations that are both certified under ISCC EU and ISCC PLUS can transfer credits from ISCC EU to ISCC PLUS mass balances, if the material is “ISCC Compliant” and the other sustainable characteristics are identical. However, it is not possible to transfer credits from ISCC PLUS to ISCC EU mass balances.”? Is the certification under both ISCC EU and PLUS necessary?

C. If the “Certified Energy Excluded attribution” method is applied, are there specific evidences to show for the classification of products as “materials” or “fuels”?

2. Paragraph 11.7. GHG Continuous Improvement Plan

We don’t agree with the addition of the whole paragraph to the ISCC PLUS procedure.
In our opinion, introducing such challenging requirement for the certification with GHG Add-on 205-01 (currently not so frequently applied in some sectors, like the chemical industry) could disincentivize more System Users from certifying with the voluntary Add-on 205-01 and further hinder its application also for System Users already certified with the GHG Add-on because of the lack of suitable upstream suppliers certified with the Add-on.

Also we don’t understand the role of ISCC PLUS certification in assessing and monitoring the companies’ decarbonizations plans and their implementations; to the best of our knowledge this type of requirement is not present in any ISO standard for Carbon Footprint or Life Cycle Assessment evaluations and neither in RED II legislation. Moreover we’d like to note that paragraph 11.7 mentions GHG emissions reduction plans both at company and product levels: “If the ISCC GHG add-on is applied, a long-term plan for continuous improvement on reductions of GHG emissions (company/product level) must be available….”. Does that mean that a System User should choose what type of GHG emission reduction plan should provide, if company level or product level? ISCC PLUS certification for Processing Units is site specific: what does company emission reduction plan mean? Are we referring to the specific site, company or corporate group?
ISCC PLUS System Document3.403.11.227.3 'New subchapter on mechanical recycling': Some of the language seems to clash with mass balance e.g 'in the product'

9.3.3 'Change in consideration of additives: removal of requirement for single additive, total amount of additives remains requirement for neglection from the mass balance': This is an improvement as it simplifies the process.

9.3.6 'Specification on the consideration of hetero atoms in the calculation of the sustainable share of a product': This is a good clarification: only streams of molecules connected to the alternative input can be certified in the output product.

12.1 'Clarification LRD: Branches of the same legal entity at a different address can also be considered as LRDs': This is a good clarification for supply chain setup
ISCC PLUS System Document3.403.11.221. Section 9.3.1 Credit transfer,
The requirement 'Sites must be located within national borders, or within neighbouring countries (sharing an inland border)' places logistical barriers on usage of credits for multinational companies. The current requirement for neighbouring countries seems quite arbitrary. We propose that this part of the requirement should be removed.

2. Section 9.3.2 Mass Balancing Approach under ISCC PLUS
Concerning product groups we suggest transfer of credit & mass balancing between polyolefins rather than requiring e.g. PP to PP, LDPE to LDPE, in order to make administration of the mass balance less burdensome.
ISCC PLUS System Document3.404.11.22The document states the definition of a circular raw material as:
“circular “(incl. technical-circular) means feedstock derived from the mechanical and/or chemical processing of recyclable materials of non-biological origin (fossil-based) (e.g. mixed plastic waste, waste textiles, end-of-life tires, etc.)."

This can be seen as somewhat ambiguous and can be seen as being at odds with the definition used to define Recycled Carbon Fuels in the EU Renewable Energy Directive (RED II) :
Article 2, §35:
‘recycled carbon fuels’ means liquid and gaseous fuels that are produced from liquid or solid waste streams of non-renewable origin which are not suitable for material recovery in accordance with Article 4 of Directive 2008/98/EC, or from waste processing gas and exhaust gas of non-renewable origin which are produced as an unavoidable and unintentional consequence of the production process in industrial installations.

Based on this definition the wording in the ISCC plus document should be expanded and made more consistent with the EU legal framework.
ISCC PLUS System Document3.404.11.22Dear ISCC team,
we have read the latest update with great interest. Whereas we agree with most changes we have a couple of questions we would like to present to you.
7.3 Related to the “New subchapter: “Mechanical Recycling according to EN 15343” we would like to raise the following:
A new Spanish law enters in force in January 2023, which states that only recycled plastic will be exempt from the new tax (450 euros / mt of virgin plastic). (Enclosed a copy of that law). On page 86, it refers to the fact that the certification scheme that will certify the quantity of recycled plastic in the product has to be recognized by ENAC or any EU country official certification body.

Our questions:
1) Is ISCC certification scheme recognized by ENAC or any EU country official certification body?
2) If a company meets the under subchapter 7.3 listed conditions, could the ISCC certification be used to certify the quantity of recycled plastic in the product or is an additional recognized certification required?
Note: In the Spanish law, the methodology mentioned for this accreditation by national certification body is referring to "Reglamento (CE) # 765/2008 del Parlamento Europeo y del Consejo".
The Dutch certification system NEN wants to create a system so that all private certification schemes such as ISCC, UL, Recyclass, etc are all compatible between each other. (Enclosed is the draft which NEN prepared with some of the requirements that they would submit to the certification schemes.). One of the first requirements NEN is including is in the introduction of the document.

Our question therefore is:
3) Is ISCC certified under ISO 17065?

9.3.6 Related to “Specification on the consideration of hetero atoms in the calculation of the sustainable share of a product” we would like to bring the following to your attention:
Section 9.3.6 states "It is not allowed to attribute the sustainable share of oxygen and nitrogen during downstream production processes of the supply chain to hydrogen or carbon atoms. Therefore, if oxygen or nitrogen atoms from ISCC compliant input materials are no longer present in the certified output material (molecule), the sustainable share needs to be reduced by the respective mass of oxygen and nitrogen atoms from the ISCC compliant input material. The certified free attribution is hence restricted in those cases to the mass of the hydrocarbon content from the ISCC compliant input material."

This section clearly is describing a situation in which a heteroatom containing material to a product with a lower mass, e.g., ethanol is converted to ethylene by the removal of water. The total mass of the sustainable product is significantly less than the starting product, and free attribution would thus lead to an overstatement of the sustainability content of the product stream. Excluding the heteroatom content from the mass balance makes perfect sense in such a situation.
The exclusion requirement is written down as an absolute requirement, and as such leads to the question what this means for reality. The presence of heteroatoms within input materials is very likely to happen at low amount due to impurities. Does the exclusion requirement imply that all impurities are quantified and via a mass balancing get deducted from the product stream? We believe this would lead to a too high administrative workload and an unworkable situation, and it would also not be in line with the intent of the requirement. It would prove useful to add to the requirement that it is only relevant for that part of the input stream that describes the bulk of the material and that impurities at e.g. less than 1 wt% are out of scope.

On “Handling of oxygen and nitrogen from ambient air” we agree and have no further feedback.

Thanks and regards
Mr Henk Hagen, Dow Benelux BV
ISCC PLUS System Document3.404.11.22About energy-excluded attribution:
* Is it allowed to mix "free attribution" and "energy excluded attribution" across different stages in the value chain.
* When using "energy exlcluded attribution; do all previous operations in the value chain need to follow energy excluded attribution?

About GHG calculations:
* it would be helpful if a GHG calculation guideline would be developed specifically for ISCC PLUS. The current add-on is mainly written in light of bio-fiuels and ISCC EU. Especially the attribution and accounting of biogenic Carbon/CO2 deserves particular attention.
ISCC PLUS System Document3.404.11.225.7.2) Please amend the sentence “For ISCC certificates the following types of processing units can be applied:” to “For ISCC certificates the certification can be applied, but is not limited, to the following types of processing units.”

Or please add co-processing unit in the list of processing units and amend the description of refinery: "Processing of eg. bio-based liquid feedstocks or other materials (refining)"

9.3.2) We ask to re-word the principle of “energy excluded” to remove the reference to proportional attribution requirement in order to allow using actual input-output specific yields. Moreover, this method needs to be further clarified on how dual-use products are treated in the mass balance.

11.7) We ask to re-think the addition of this paragraph. As it is written in the draft it can cause confusion in the market and among system users, potentially leading to differing interpretations and implementation. Implementing a GHG improvement plan should be optional and additionally the requirements and guidelines should be clarified for system users and auditors to better understand what is the aim of such a plan and how to verify it. It should also be noted that managing such a plan can require a lot of resources from the system user and thus lead many system users to choose not to implement the voluntary GHG add-on.
ISCC PLUS System Document3.404.11.22Section 5.3, last paragraph (Multi-input processes), p. 11
From our point of view it does not make sense to keep the amounts separately, since these categories are combined in one molecule and cannot be separated from each other anymore. For the given Example I.4 4 (Sodium polyacrylate) the amounts are as following: 1 ton of sodium polyacrylate contain 245 kg renewable energy derived sodium and 755 kg bio polyacrylate. So a customer, who purchased 1 ton of renewable energy derived bio sodium polyacrylate would receive a sustainability declaration for 245 kg renewable energy derived Sodium polyacrylate and 755Kg bio sodium polyacrylate. This suggests a transfer of the renewable energy derived characteristic from sodium to polyacrylate and a transfer of the bio characteristic from polyacrylate to sodium
We think it would make sense to get more clarity on the attribution options in case of a multi -input system with chemical reactions between the multiple components.
Could you give an example how the sustainability declaration should look like (e.g. for the example in the annex) (also important for the tick mark “complies with system document 202” and “meets the definition of waste and residue” if bio and (bio-)circular is combined)

Section 5.4 (Requirements for CO2 Certifications), pp. 11-12
We question the necessity of a certified reactant to qualify CO2 as sustainable raw material.
Since the use of CO2 enables the partial replacement of fossil raw materials such as natural gas and coke in the production of the intermediate carbon monoxide (can lead to significant savings of fossil raw materials and is common practice) we would highly appreciate to consider this aspect in the system document.

Section 5.5 (Post-Consumer and Pre-Consumer Materials), p. 13
to be considered as recyclate in recycling quotas, only official waste management companies are obliged to treat the pre or post-consumer material and define this as recycled.

Section 8 (Sustainability Requirements) p. 20
The Sustainability requirements 2-6 in system document 202 should be available for (bio-)circular category too.

Section 9.3.6 (Consideration of Hetero Atoms for the Sustainable Share of a product), pp.31-32
we appreciate the new approach to count Heteroatoms derived from ambient air as sustainable, since this would allow to reach 100% sustainable share if all the fossil carbon atoms are replaced by sustainable carbon atoms in molecules containing Nitrogen and Oxygen from ambient air. Otherwise it would be impossible for molecules containing N2 and O2 to reach 100% Sustainable share even if all the carbon is sustainable. This change should be applicable to already purchased raw materials too.
ISCC PLUS System Document3.404.11.22We welcome the changes and updates made in the proposed ISCC Plus system document. We would like additional clarity on the following points:
• Section 5.4: “Under ISCC PLUS a certification of CO2 for direct usages of CO2 (e.g., in the food industry, as coolant or extinguishing agent) instead of using it as a raw material, is not possible for processes that do not go beyond the current state of the art (innovative process).” Clarification around intention of this text, and what is classified as current state of the art.

• Section 7.3: we request clarification on whether rejects from mechanical recycling facilities should be considered to have undergone mechanical when this is required to be stated on the Proof of Sustainability (PoS) document?

• Section 11.7: what is the rationale for requiring a continuous improvement GHG plan under ISCC Plus, and can you provide more details about what this should entail?

In addition, further requests are made:
• Please could you confirm when ISCC will enable certification of recycled carbon fuels (RCFs) under ISCC EU?

• When you do implement this, please could you confirm our expectation that the GHG methodology will follow that required by the European Commission (as currently issued in the draft Delegated Act )?

• Recognising that ISCC do not currently certify RCFs under the ISCC EU, we request that nevertheless under ISCC Plus the GHG methodology is updated to treat RCFs according to the method that is expected to be implemented under ISCC EU.

• We request that di-methyl-ether (DME) is added to the ISCC Plus list of eligible products.
Ms Lizzie German, Dimeta B.V.
ISCC PLUS System Document3.404.11.225.3) Raw material category:

Feedback related to the specifications on the requirements to the use of renewable electricity for the production of renewable-energy-derived materials.

ISCC Plus’ requirements to the use of renewable electricity lack robust criteria for additionality of renewable electricity. Production of e-fuels will need an enormous amount of electricity. Even though e-fuel producers acquire EACs of renewable electricity from existing plants, this will not necessarily lead to the installation of additional renewable electricity capacity. In contrast, overall increased electricity demand could lead to the expansion of fossil-based electricity and increase of GHG emissions. This has been established by the EU Commission’s draft Delegated Regulation on setting out detailed rules for the production of RFNBOs. Academic studies have also concluded that the use of unbundled EACs do not necessarily lead to the expansion of renewable electricity capacity or to decrease in total system emissions (Bjørn et al. Nature Climate Change, https://doi.org/10.1038/s41558-022-01379-5). Therefore, we strongly recommend the introduction of robust criteria for additionality in line with the EU Commission’s draft Delegated Regulation. For example, e-fuel producers should source renewable electricity from plants that came into operation no earlier than three years before the e-fuel plant. Additionality should also ensure geographical and temporal correlation. E-fuel producers should demonstrate that there is no grid congestion between the electricity plant and the fuel production plant (or prove a direct line connection), and that electricity use for fuel production takes place within the same time window (e.g. same calendar month) as renewable electricity generation to ensure transparency and avoid putting significant burden on the stability of the electricity grid.

Product claims where it is possible to use “renewable” instead of “renewable-energy-derived” is not entirely clear. Please explain further.

9.3.6) Consideration of Hetero Atoms for the Sustainable Share of a Product:

Since the origin of hetero atoms in an 12C/14C analysis cannot be determined, the following norm applies for the determination of the bio-based content after a 12C/14C analysis: If a product is processed by chemical synthesis and reactant are derived from both biomass and non-biomass, oxygen (O) and/ or hydrogen (H) and/ or nitrogen (N) element(s) is/ are bound to a carbon structure derived from biomass its/ their fraction is/ are considered to be part(s) of the bio-based content.
Ms Ingrid Marie Andersen, AP Møller-Mærsk
ISCC PLUS System Document3.405.11.22Section 9.3.2, paragraph #1:
Would you please mind elaborating on what constitutes "process losses" in more detail? This phrase can be interpreted in many ways and may unjustly penalize some system users' conversion factors while assisting others.

Section 9.3.2, paragraph #3:
In addition to on-product/off-product claims, does "equivalence" need to be taken into consideration when determining the sustainable share? I.e., after applying the conversion factor, is the system user limited to claiming outgoing credits in a product based on the "equivalence" content? For example, if a product contains only 70% certified ISCC input, is the maximum credit allocation threshold limited to 70%? Or, can credits be allocated to cover the entire product (100%) as long as the product contains some ISCC certified input?