10 March 2021

Dear Ladies and Gentlemen,

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

 

  1. Clarification on esca

In the ISCC system update as of 27 August 2020, ISCC has introduced an additional level of assurance for GHG Emissions Savings from Soil Carbon Accumulation via Improved Agricultural Management (esca). High GHG savings, especially due to bonuses as esca, increasingly raise queries from authorities. ISCC would like to support the application of esca but as it is of crucial importance to ensure that these values are calculated correctly and verified adequately, ISCC has developed the following guidance:

As specified in the system update, ISCC System Users receiving sustainable material with an esca value must reconfirm with ISCC whether the esca values have been approved or not. Please note that in case the sustainable material is received from a supplier who is certified according to another recognized voluntary scheme, reconfirmation shall take place with the respective voluntary scheme of the supplier.

Due to questions from stakeholders, we herewith clarify that calculating and forwarding esca values is still possible under ISCC if the requirements specified in ISCC document 205 chapter 4.3.3 and in the system update as of 27 August 2020 are complied with. Please find in the following further information that must be taken into account when applying and verifying esca:

  • Either application of IPCC values or individual measurements can be applied to calculate the esca values
    – For each farmer using esca, an individual value (not calculated at regional level) must be calculated from the starting date of esca practices (cut-off date: January 2008). The individual value must come from esca calculation for the single farmer fields.
  • This can result in different esca values per farmer
  • The averaging of the emission values of farmers who use esca and of farmers who do not use esca is not permitted
  • The esca measures must have been applied continuously for each farmer since the starting date of the respective esca measure
  • In case of benefiting from a change in tillage practices (e.g. from reduced to no-tillage): Gains from esca are accounted only for the fields with no tillage (in case farmer have some fields with conventional tillage and others with no tillage), and only for the years the bioenergy crop is planted on those fields.
  • Additional, clear and verifiable evidence for all farmers accounting for esca is necessary and must be provided to the auditor. This implies that auditors not only have to verify the correctness of the chosen IPCC factors with all relevant desk and on-site information but also that for instance the change to reduced tillage practices is actually documented and can be verified:
    • Farmers should overlay their single fields/polygons with IPCC climate zones and IPCC soil types maps to obtain default SOC values. For each field/polygon the farmer should choose the input level and tillage practice before and after the change. The auditors should have access to a digital format of the farmers’ audited fields and should try to reproduce the results for a sample farmers/fields.
    • Explanatory approach for land category chosen, i.e. rationale on used IPCC soil type map, climate map, management factor.
    • Detailed description of the improved agriculture practice, with references (starting date, continuity of practice, application on complete cultivation area or only share of total area, yield in the start year, e.g. if increased input is included, evidence must be provided).
    • Evidence documents: e.g. invoices of new machinery to apply reduced tillage, invoices of buying manure, increased use of fertilizer and herbicide application.
  • In case the companies wish to apply values other than those of the IPCC, a report must be prepared which contains the complete calculation methodology validated by a third party. This report must be submitted to ISCC so that ISCC can assess how to proceed and whether these values are acceptable.

 

  1. Procedure to Submit Complaint Forms

Conflict resolution and the investigation of fraud cases is essential for ISCC in order to maintain reliability and integrity. ISCC encourages third parties and stakeholders to submit complaints in case of possible fraudulent behavior. For this purpose, ISCC has developed a complaint template, which is available on the ISCC homepage. Please note that for a better and more efficient documentation, ISCC will only accept complaints submitted through the online template. Complaints received via e-mail or post will not be accepted for a further investigation.

When filling the complaint template, please make sure that you have sufficient evidence in order for ISCC to obtain an idea and unambiguous understanding of the situation. As of 1st of January 2021, all received complaints can be found on the ISCC homepage, including the status of the particular case.

  

  1. Information Letter About Nabisy-Update and Updateed Documents

We herewith inform you about an update of the German Nabisy database. Please share this information with all relevant members of staff within your organisation.

The major changes and news include:

  • Adjustments regarding the security requirements in Nabisy
  • Closing of DE discharge accounts
  • Outlook on the implementation of RED II

Please refer to the attached 10th Nabisy Information Letter for detailed information. The letter is also available for download here in the client section of the ISCC website (login required).

Besides the update of Nabisy, the following documents in the help section were updated as of 09 March 2021:

  • FAQ
  • Handbook for Nabisy for
    • Last interfaces
    • Suppliers
    • Installation operators (only in German)
    • Grid operators (only in German)
  • List of types of biomass
  • Discharge accounts

The updated documents can found in English and German on the website of the German Federal Office for Agriculture and Food.

 

  1. Updates on ISCC Documents

ISCC EU Material List

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

  • Municipal grass cuttings (formerly: Roadside grass cuttings)

(Amended info: Grass cuttings collected from municipal sites such as sports grounds or roadside verges, where animal feed is not a possible end use, due to contamination and/or site location.

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

  • Co-processed oil to be used for replacement of
    naphtha

ISCC PLUS Material List

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

  • Almond

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

  • Adhesives
  • Blend of C12 and C13 primary alcohol
  • Blend of C12 and C13 primary alcohol ethoxylates
  • Blend of C12, C13, C14 and C15 primary alcohols
  • Blend of C12, C13, C14 and C15 primary alcohol
    ethoxylates
  • Blend of C14 and C15 primary alcohols
  • Blend of C14 and C15 primary alcohol ethoxylates
  • Butadiene rubber (BR)
  • C7
  • Circular coal
  • Cracker oil
  • Crude C4
  • Ethylene propylene diene monomer (EPDM)
  • Hydrowax
  • Label material
  • Linear alkylbenzene (LAB)
  • Mixed xylenes
  • Nitrile butadiene latex (NBL)
  • Optical products (e.g. lenses or glasses)
  • Potassium carbonate (K2CO3)
  • Potassium hydroxide (KOH)
  • Raffinate 1 / C4R1 (C4 without butadiene)
  • Refinery offgas
  • Sodium hydroxide (NaOH)
  • Styrene butadiene rubber (SBR)
  • Toluene
  • Tools (e.g. snow shovels)

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 10 March 2021) and the ISCC PLUS lists of materials (as of 10 March 2021) are available here in the client section of the ISCC website (login required).

Updated Sustainability Declaration Templates

Please note that the template for the Sustainability Declaration for Raw and Intermediate Products (ISCC EU) (V.4.7) and the ISCC PLUS Sustainability Declaration (V.3.0) were updated with the above mentioned new materials. In addition, in both templates there is now a separate field for each transport mode to specify the transport distance to simplify the entries when several transport modes are used. The updated versions can be found here in the client section of the ISCC website (login required).

 

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

Your ISCC Team