05 September 2017
Dear Ladies and Gentlemen,
We herewith inform you about updates and clarifications of the ISCC System. Please share this information with all relevant members of staff.
1. ISCC DE: Fossil Methanol
The Federal Office for Agriculture and Food (Bundesanstalt für Landwirtschaft und Ernährung – BLE) has sent a letter to the schemes that are recognized by the BLE (“DE schemes”) regarding the emission factor for fossil methanol. The BLE expects the DE schemes to implement the same methodology for fossil methanol as laid down in the European Commission’s GHG Note and as already implemented by the re-recognized EU schemes since 01 September 2017. This means that the emissions from combustion of fossil methanol shall be included also in GHG calculations under the DE schemes recognized by the BLE. The BLE expects the DE schemes to implement this approach until the end of 2017 the latest. Therefore, ISCC will implement this requirement under ISCC DE as specified by the BLE. This means, ISCC DE certified System Users using fossil methanol for biodiesel production must include the emissions from combustion of fossil methanol from 01 January 2018 onwards.
If System Users intend to become ISCC DE certified, a full ISCC DE audit is required before an ISCC DE certificate can be issued. In case of an initial (first) certification under ISCC DE, please be aware that a surveillance audit after six months is required.
Please also keep in mind that the European Commission does not recognize the DE schemes. Therefore, other EU Member States are not obliged to accept material which is certified under a DE scheme. This means, ISCC EU certified economic operators cannot accept DE certified material as RED compliant under ISCC EU.
2. ISCC EU: Separate GHG Calculation Elements
According to the new GHG methodology implemented under the re-recognized voluntary schemes, from 01 September 2017 the elements of the GHG calculation must be forwarded separately and per dry ton (please see ISCC document 205 and the EC’s GHG Note for further information). This requirement particularly applies for raw material that enters the supply chain (i.e. is supplied by a First Gathering Point or Collecting Point) from 01 September 2017 onwards. If possible, the separate GHG elements may also be obtained and forwarded for intermediate and final products that have entered the supply chain prior to 01 September 2017. However, the GHG Note does not require material which was already in the supply chain prior to 01 September 2017, and which was compliant according to the “old” RED methodology, to lose its status as RED compliant. Therefore, such deliveries can still be accepted and forwarded under the “old” RED methodology, i.e. with one single GHG value. The “old” material subsequently will be replaced by material supplied into the chain that complies with the adjusted requirements.
If companies are handling both material that complies with the new methodology (separate GHG calculation elements) and material that complies with the old methodology (only one GHG value), these deliveries must be kept separately in the mass balance. We point out, that the acceptance of “old” material may depend on the requirements in the EU Member State, where the final biofuel will be used to fulfil a quota obligation. Therefore it is recommended to replace “old” material with material that comes with separate GHG calculation elements as soon as possible.
3. Transitional Period Red Tractor
The European Commission has sent a letter to the voluntary schemes that have been recognized by the Commission regarding the recognition of the Red Tractor scheme that expired on 06 August 2017. According to the Commission, the process of technical assessment of the re-recognition of Red Tractor is close to finalization. To avoid disruption in the biofuel market, the Commission has advised the recognized voluntary schemes to continue accepting evidence from Red Tractor even if a gap between the expiry of the old and entry into force of a new decision cannot be avoided. This exception should be applied for a period of at most three months from the date of expiry of the voluntary scheme.
ISCC will follow the recommendation by the Commission. This means ISCC certified System Users can continue to accept deliveries from Red Tractor certified economic operators as RED sustainable until 06 November 2017 the latest.
4. Update: Sustainability Declaration, ISCC PoS (“Blue PoS”) and List of Materials
ISCC has updated the newly developed template for “Sustainability Declarations for Raw Materials and Intermediate Products”. Feedback from System Users was included into the updated version. Furthermore, the voluntary template can now be applied for raw materials and intermediate products certified under ISCC EU and ISCC PLUS.
ISCC has also updated the format of the template for the “Proof of Sustainability for Biofuels and Bioliquids” (“Blue PoS”) (v4.1). Depending on the program or version of the program used to open the template, some System Users experienced minor problems in the format and display of the data. The new version of the template should ensure that the electronic and the printed version of the POS correctly display all information.
Furthermore, ISCC has updated the ISCC list of materials. Roadside grass cuttings were added to table 1 (raw materials).
The updated documents are available in the client section of the ISCC website.
5. ISCC Trainings – Forthcoming Dates
ISCC Greenhouse Gas Training
20 – 21 November 2017, Cologne, Germany
ISCC EU and PLUS Basic Training
14 – 16 November 2017, Shanghai, China
22 – 24 January 2018, Cologne, Germany
Important note for certification bodies and auditors: The participation in the ISCC EU and PLUS Basic Training is a mandatory requirement for all auditors before they can conduct audits under ISCC.
Auditors who have not yet participated in an ISCC Basic Training after July 2016 are required to re-attend an ISCC Basic Training until the end of January 2018 if they want to conduct ISCC Audits in 2018 and thereafter.
If you have any questions, please do not hesitate to contact ISCC.
Your ISCC Team