11 May 2017
Dear Ladies and Genlemen,
We herewith inform you about important changes of the GHG calculation methodology which is requested by the European Commission (EC) and has to be implemented by voluntary schemes. Please share this information with all relevant members of staff.
1. Implementation of the Updated GHG Emission Calculation Methodology
The EU Commission (EC) has now informed all recognised voluntary schemes that “all voluntary schemes that have been recognised by the EC since August 2016 are required to implement an improved GHG emission certification methodology…”. In the letter the EC requests that the requirements are fully implemented at the latest by end of August 2017. The implementation deadline of end of August 2017 applies to all schemes whose recognition by the EC will have been extended by end of August 2017 (ISCC EU, RSB EU RED, 2BSvs, Bonsucro EU, RedCert EU, Ensus, Red Tractor, NTA 8080).
This means, that by that date System Users have to implement all new requirements according to ISCC System Document 205 “GHG Emissions” (v3.0).
The main adjustments cover:
- GHG information transfer for all individual elements of the GHG calculation formula along the supply chain
- Calculation and forwarding of all GHG values per dry-ton matter
- Application of feedstock factor based on mass (for feedstocks and intermediates) and based on energy content of input and main output for final biofuels
In case operators receive proofs demonstrating compliance with GHG emission requirements that are not issued in accordance with the updated requirements, the EC recommends to apply the following approach, until further notice:
- Accept sustainability proofs regarding compliance with the land-use criteria (Art. 17(3) – (5) RED
- Apply the corresponding default value, or disaggregated default value, instead of the actual GHG emission data stated in an incompatible format
The EC will inform the voluntary schemes about the phasing out of this transitional approach, and ISCC will inform the System Users and CBs accordingly.
2. ISCC GHG Training, 21 – 22 June 2017, Cologne
All new GHG requirements and the transition approach will be covered in the 1.5-day Training.
Practical case studies will further help the participants to understand how to apply and implement the new requirements. ISCC GHG experts will be available throughout the training to answer your questions.
Note for certification bodies: If a CB is conducting audits and certifications covering the verification of individual GHG calculations, the CB has to ensure that at least one GHG expert has participated in an ISCC GHG Training (see also ISCC System Document 103 “Requirements for Certification Bodies and Auditors”).
3. Calculation of GHG Emission Savings of Biodiesel
The EC provided clarification to all voluntary schemes regarding the application of the emission factor for fossil methanol for the GHG emission saving calculation for biodiesel.
In the “Note on conducting and verifying actual calculations of GHG emission savings” (v2.0), the EC recommends voluntary schemes to apply for the purposes of biofuel sustainability certification the standard calculation values (emission factors) dedicated to the GHG emission savings methodology (this list is not exhaustive). However, whenever an item is covered by the list, the use of alternative values must be duly justified. In case alternative values are chosen, this must be flagged up in the documentation of the calculations to facilitate the verification by auditors.
The note and the list with the standard values for emission factors are available as downloads on the website of the European Commission.
4. NUTS2 Values available on the EC Website refer to gCO2eq/dry-kg
In the ISCC System Update from 14 March 2017 ISCC informed the System Users that the EC had published an overview of average greenhouse gas (GHG) emissions for cultivation in gCO2 equivalent per kg feedstock for different NUTS 2 regions.
The EC has now clarified that the NUTS2 values as included in the overview refer to gCO2eq/dry-kg feedstock.
The values included in this list are based on information the EC has received from the EU Member States. The list does not yet cover all regions but may be updated by the Commission as soon as the Commission receives additional information from the Member States.
NUTS 2 values in gCO2eq/dry-kg feedstock provided in the list have to be applied under ISCC in case NUTS2 values shall be used.
Please check the EC website for updates of the overview on a regular basis.
5. ISCC EU and PLUS Basic Trainings – Upcoming Date
10 – 12 July 2017, Cologne
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 that have last participated in an ISCC Basic Training before July 2016, have to again attend an ISCC Basic Training until 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