07 January 2021

Dear Ladies and Gentlemen,

The entire ISCC team wishes you a Happy New Year and much health and joy for 2021!

We herewith inform you about updates and clarifications in the ISCC System. Please share this information with all relevant members of staff.

  1. Clarifications

1.1 Remote Audits and Complementary Follow-up On-site Audits

The European Commission has specified that remote audits under recognized voluntary schemes generally have to be complemented by on-site audits (“follow-up on-site audits”). An exception to the requirement “to complement the remote audits by onsite audits can be accepted to avoid excessive burden in limited cases where the risk of non-compliance and fraud can be expected to be low”.

In the ISCC System Update as of 07 July 2020, we have clarified the requirements under which a certification audit that was conducted remotely must be complemented by an on-site audit. According to the System Update “A follow-up on-site audit is required if a higher risk then regular was determined in the risk assessment, not all ISCC requirements could be fully verified remotely (i.e. one or more requirements could not be answered as “compliant” in the ISCC audit procedure from the remote audit), or if non-conformities with ISCC requirements were detected in the remote audit.“ We herewith clarify that in case of non-conformities detected in the remote audit, which do not lead to an increased “risk of non-compliance and fraud”, a follow-up on-site audit is not required if such an on-site audit leads to an excessive burden. This is particularly the case if non-conformities are found which do not relate to the sustainability of products or to (legal) requirements resulting from the Renewable Energy Directive and which can be corrected immediately. Examples include, but are not limited to, a missing signature under the ISCC terms of use or a missing organizational chart.

In case of non-conformities for which a higher risk of further non-compliances or fraud is to be expected, a follow-up on-site audit is required. This includes but is not limited to non-conformities with land-related sustainability requirements and non-conformities which have a negative impact on downstream supply chain elements (e.g. forwarding of incorrect information to other operators).

If non-conformities are detected during a remote audit, it is the responsibility of the certification body and the auditor to justify in the audit procedure why a follow-up on-site audit is not considered to be required in the individual case. ISCC reserves the right to demand a follow-up on-site audit in cases where ISCC sees a higher risk of further non-compliances or fraud and comes to a different conclusion that the certification body and the auditor.

Furthermore, with regard to the timeframe in which the complementary follow-up on-site audits must be conducted, the European Commission has provided the following additional clarification: “(…) for countries, to which in the meantime travel restrictions have been first lifted but re-applied at a later stage due to the worsening sanitary situation, the 5 months period for carrying out the (follow-up) on-site audits will start running from the end of the month, in which such restrictions were last lifted.”

The above clarifications apply equally under ISCC EU and ISCC PLUS.

 

1.2 Place of Dispatch in Sustainability Declarations and Proofs of Sustainability

ISCC recently updated the templates for Sustainability Declarations (SDs) and Proofs of Sustainability (PoS). The update included a checkbox for the cases in which the address of the place of dispatch matches the address of the certified supplier. Please see the ISCC System Update as of 07 October 2020. We herewith would like to further clarify the following:

If the place of dispatch differs from the address of the certified supplier, both the address of the certified supplier and the place of dispatch have to be provided on the SD or PoS. This can be the case, for example, when the dispatch of the sustainable material is done from a dependent storage facility covered under the supplier’s certificate. For reasons of traceability, the full address of the place of dispatch should be provided.

It would be sufficient to provide the information on the place of dispatch on separate documents connected to the delivery, for example transportation documents, as long as those documents can be clearly linked to the delivery and that the specific place of dispatch can be verified by the auditor.

Please be kindly reminded that ISCC does not make provisions regarding the layout of SDs and PoS and that it is not mandatory to use the templates for SDs or PoS as provided by ISCC. Please also refer to ISCC System Document 203 “Traceability and Chain of Custody”, p. 15: “Sustainability Declarations must contain the information that is laid down in this document. However, no provisions are made with regard to the form or layout of the Sustainability Declarations. (…) This opens two alternatives to a certified element of the supply chain. Alternative number one is to develop a template for a delivery note which includes all the required sustainability information. Alternative number two is to attach a document with the required sustainability information to existing templates of delivery notes (e.g. using an appendix).”

 

  1. Equivalence Assessment of the Dutch Manure System

ISCC has conducted an equivalence assessment of the Dutch manure system against the ISCC requirements for waste and residue materials. According to ISCC Document 201-1 “Waste and Residues”, ISCC can recognise the equivalence of existing systems operated by governmental authorities that ensure compliance with the waste and residue requirements under ISCC. Equivalence of such systems must be assessed and approved by ISCC.

The Dutch manure system is a system used by public authorities in the Netherlands to regulate the handling of manure. Under the Dutch manure system, all deliveries of manure are registered in a central database and can thereby be supervised by the competent authorities. The system contains relevant information on Points of Origin, collectors and other economic operators handling manure, including relevant documentation such as manure quantities. If an ISCC certified Collecting Point is handling transactions of manure within the Dutch manure system, the ISCC auditor can access the central database to verify compliance with several ISCC requirements.

Based on the findings of the equivalence assessment, ISCC has come to the conclusion that the Dutch manure system is a system operated by governmental authorities that demonstrates compliance with several requirements under ISCC. Particularly, the system ensures:

  • the traceability of manure from the collecting point back to the point of origin and the respective licenses of the operators,
  • the correct classification of the material
  • the correct determination and documentation of manure quantities

If the auditor can fully verify compliance with the above requirements during the audit, the respective Collecting Point does not have to receive and manage self-declarations from the supplying Points of Origin. In addition, a risk-based auditing of the Points of Origin as part of the certification process of the Collecting Point is generally not required (unless there is indication of non-conformity or fraud). This applies irrespective of the amount of manure generated by the Point of Origin.

However, the Dutch manure system does not authorize auditors from certification bodies, staff of ISCC and inspectors from national bodies to conduct on-site examinations also at Points of Origin if required. This may be required, for instance, to verify the claims made by the Collecting Point. Such an authorization must be granted by the Points of Origin explicitly, e.g. as part of the contractual agreement with the certified Collecting Point. This means, for all Points of Origin it must be ensured that auditors from certification bodies, staff of certification schemes and inspectors from national bodies (if applicable) are allowed to conduct on-site examinations to verify whether the relevant ISCC requirements for Points of Origin are met (if required).

Collecting Points using the Dutch manure system still need to become certified individually . Auditors must explicitly indicate in the ISCC audit procedures if the certified Collecting Point is registered with and handling manure within the Dutch manure system and how the authorisation for third parties to access the Point of Origin is granted (e.g. as part of a contractual agreement with the certified Collecting Point).

  

  1. Procedure to Cancel or Correct Sustainability Declarations and Proofs of Sustainability

In the ISCC System Update as of 09 April 2020 we have clarified how the procedure to cancel or correct Sustainability Declarations (SDs) and Proofs of Sustainability (PoS) containing incorrect information shall be handled. As ISCC has received feedback from market participants and certification bodies (CBs), we hereby further specify this procedure:

If a supplier provides incorrect information to a recipient on an ISCC PoS or SD (e.g. an incorrect GHG value), it may be possible for the issuing party (supplier) to cancel or correct this mistake. This may be possible under the condition that the recipient has not used (i.e. forwarded) the incorrect information and cancels or corrects the corresponding information from their mass balance. The supplier has to inform the recipient, the CB of the recipient and ISCC in writing about the incorrect information or document and the intention to cancel or correct the respective SD. The CB of the recipient must confirm in writing to the supplier, the CB of the supplier and ISCC that the request was received and documented, and that the incorrect information/SD was cancelled from the mass balance. The CB of the supplier shall  document a non-conformity in the audit procedure of the supplier (the party responsible for providing incorrect information to recipients). In the next scheduled audit, the CB of the recipient has to verify that the incorrect information has been cancelled from or corrected in the recipient’s mass balance. Should the supplier and/or the recipient change the CB for the next audit the newly contracted CB must be informed accordingly to ensure that the specific transactions are covered in the next scheduled audit.

This procedure generally also applies if a PoS is handled within a national database (such as Nabisy) and shall be cancelled. However, if the PoS is handled within a national database, the specific processes from the national database must always be followed.

 

  1. Updates on ISCC Documents

ISCC EU Material List

Table 1 “Raw material” – The following raw materials were added/amended:

  • Ethanol used in the extraction of ingredients from medicinal plants
    (Info: Contaminated bio ethanol used in the extraction of ingredients from medicinal plants that cannot be used for food, feed or subsequent pharmaceutical purposes and would otherwise be disposed of.)
  • Sugar beet betaine residue
    (Info: High colour (>20,000 ICUMSA) residual extract following the recovery of betaine through chromatography separation of sugar beet molasses.)

Table 2 “Intermediate and final products” – The following raw materials were added/ameended:

  • Biogasoline
  • Co-processed oil for the replacement of diesel/petrol/jet fuel produced from biomethane
  • Tall oil rosin

 

ISCC PLUS Material List

Table 1 “Raw material” – The following raw materials were added:

  • Celler glass (waste from glass fiber production)
  • Chickpeas
  • Faba beans
  • Lentils
  • Mung beans
  • Renewable electricity
  • Waste PA

Table 2 “Intermediate and final products” – The following products were added/amended:

  • 1-butene
  • 1-decene
  • 1-dodecene
  • 1-hexene
  • 1-octene
  • 2-butene
  • 2-ethylhexyl acrylate
  • Acetic acid
  • Acrylic monomer
  • Aniline
  • Artificial grass
  • C12 (alcohol ethoxylates)
  • C12 (primary alcohol)
  • C13 (alcohol ethoxylates)
  • C13 (primary alcohol)
  • C14 (alcohol ethoxylates)
  • C14 (primary alcohol)
  • C15 (alcohol ethoxylates)
  • C15 (primary alcohol)
  • Compounds
  • Cyclohexane
  • Ethylene oxide
  • EVOH (ethylene vinyl alcohol)
  • Formalin / Formaldehyde / Methanal
  • Formate salts
  • Fructose-glucose syrup
  • Glass fiber
  • Glucose syrup
  • Medical measures
  • MDA (Methylendianilin)
  • MDI (Methylendiphenylisocyanate)
  • MDI prepolymers
  • Pasta
  • Pesto
  • PC blends
  • Pipes
  • Pyridin
  • Rubber
  • Semolina
  • Trimethylolpropane

Additionally, the prefix for products in the fields of industrial applications produced from waste/residue materials of non-biological origin (e.g. mixed plastic waste) was changed to “circular”. The application of prefixes is clarified on the first page of the ISCC PLUS material list.

Please note that both ISCC lists of materials can be amended. In case a material should be certified which is not listed yet, please note that ISCC must be contacted prior to the issuance of the certificate via info@iscc-system.org.

The current versions of the ISCC EU lists of materials (as of 07 January 2021) and the ISCC PLUS lists of materials (as of 07 January 2021) are available here in the client section of the ISCC website (login required) (LINK).

 

Updated and New ISCC PLUS Templates

Please note that the template for the ISCC PLUS Sustainability Declaration (SD) received a minor update. The checkboxes to indicate the raw material category were slightly changed in the ISCC PLUS Sustainability Declaration (V2.9) in order to match the updated terminology as laid out in the ISCC PLUS material list. The updated version can be found here in the client section of the ISCC website (login required).

Furthermore, ISCC has developed a new self-declaration template for Points of Origin providing all types of waste and residues under ISCC PLUS. The template is available here in the client section of the ISCC website (login required).

 

ISCC PLUS System Document open to Public Consultation

The ISCC PLUS System Document has been revised and is now open to public consultation until 26 February 2021. ISCC is keen to gather feedback from system users, certification bodies, interested third parties and reviews revised or newly developed documents based on the responses. The document can be downloaded here on the ISCC website. ISCC is pleased to receive feedback submitted via this contact form.

 

 

If you have any questions, please do not hesitate to contact us.

Your ISCC Team