01 July 2021
Dear Ladies and Gentlemen,
We herewith inform you about updated ISCC documents that become relevant in the course of the transition from RED I to RED II. Please share this information with all relevant members of staff.
1. Overview of RED II requirements
ISCC has set up a document highlighting the RED II requirements that have to be applied by economic operators as of 1st July 2021. The document is available here on the ISCC website.
As communicated in the ISCC System Update from 29 June 2021 ISCC also provided gap audit procedures that specifically address the RED II requirements. Please click here for further information. Please kindly note that ISCC has updated the gap audit procedure for chain of custody. The update version (1.1) is available on the ISCC website and has to be applied as from 1st July 2021. The requirements 01.02.07 and 01.03.05 were removed from the gap audit procedure (see also item 3 below).
2. Update of actual GHG calculations
If an economic operator has to adjust an actual GHG calculation the adjusted calculation has to be provided to the certification body. The assessment and verification of the updated GHG calculation has to be done by the CB in due time but latest in the framework of the recertification audit.
3. Minimum sample size of group members
When calculating the sample size for group audits of farms/plantations and points of origin the minimum sample size remains for the time being the square root of the number of group members. This approach reflects the approach in the draft implementing regulation on rules to verify sustainability and greenhouse gas emissions saving criteria and not to the approach stated in the current assessment protocol template.
4. Sustainability Requirements for Agricultural Biomass: ISCC Principles 2-6
ISCC has now also uploaded the ISCC EU System Document 202-2 “Sustainability Requirements for Agricultural Biomass: ISCC Principles 2-6” here on the ISCC website.
For the implementation of this document ISCC will provide an adequate transitional period. This means that the application of this document will become mandatory as of 1st January 2022. An earlier application is possible on voluntary basis. Until this date the ISCC EU System Document 202 “Sustainability Requirements” (v.3.1) (also available here) must be applied for the verification of the ISCC Principles 2-6 for agricultural biomass and residues from agriculture, fisheries and forestry.
5. Update ISCC self-declaration for waste and residues
ISCC has updated the self declaration for waste and residues to adjust the reference from RED I to RED II. An update of the other self declaration templates is not necessary for the time being.
You can download the updated self declaration (v2.0) here on the ISCC website (login in required).
6. EC public consultation on voluntary schemes and low ILUC-risk certification
The European Commission has published the draft Implementing Act on “rules to verify sustainability and greenhouse gas emissions saving criteria and low indirect land-use change-risk criteria” for stakeholder consultation. The draft Implementing Act and the related annexes aim aims to set out detailed rules for voluntary schemes to certify sustainable biofuels, bioliquids and biomass fuels according to the REDII (Renewable Energy Directive (EU)2018/2001).
The documents can be downloaded here via the European Commission website.
The consultation is open until 27 July 2021 and feedback should be submitted via the European Commission website (see link above).
7. Nabisy: Information regarding the implementation of the REDII
We herewith inform you about a communication by the Federal Office for Agriculture and Food (BLE) from 1st July 2021 regarding the German Nabisy database. Please share this information with all relevant members of staff within your organisation.
Federal Office for Agriculture and Food (BLE):
„The European Commission has informed the certification systems which have applied for recognition as a Voluntary Scheme that the requirements of the Renewable Energy Directive (EU 2018/2001) (REDII) must be met with from July 1st, 2021.
As there will be no adaptation of Nabisy until 01.07.2021, please note the following:
Proofs of sustainability that are issued in Nabisy before the new version of the sustainability ordinances are in force remain valid. As soon as the new sustainability ordinances come into force, Nabisy will be adjusted accordingly. A simplified procedure for the subsequent change / reissue of proofs of sustainability that were issued from July 1st, 2021 will then be temporarily possible for the affected proofs of sustainability.“
Please contact the BLE for any questions related to Nabisy. You can find their contact details here.
ISCC is continuously working on further guidance regarding the transition from RED I to RED II which will be send out soon.
Your ISCC Team