13 December 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. Equivalence Assessment of the Danish National Waste Register

According to ISCC System 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 aim of such an equivalence assessment is to analyse, if ISCC requirements for points of origin are already covered by existing systems operated by governmental authorities on a local, regional or national level. Relevant requirements being analysed in such an assessment are: traceability of the waste from the collecting point back to the point of origin, correct identification and classification of the material, ensuring that the material meets the definition of waste, application of national legislation, and documentation of waste quantities.

ISCC has conducted an equivalence assessment of the Danish National Waste Register (in the following referred to as DNWR) against the ISCC requirements for waste materials. The DNWR is operated by the Danish Environment Protection Agency (EPA) being part of the Ministry of Environment and Food of Denmark. All collectors of waste and operators handling waste in Denmark must be registered with the DNWR and must report information on wastes collected, received and treated to the Waste Data System (ADS) operated by the EPA. For the classification and identification of waste material, European and National waste codes are being applied.

Based on the findings of the equivalence assessment, ISCC has come to the conclusion that the DNWR is a system that is equivalent to the requirements under ISCC. Particularly the DNWR equivalently ensures:

  • the traceability of waste from the collecting point to the point of origin,
  • the correct identification or classification of the material,
  • that the material covered meets the waste definition,
  • the correct determination and documentation of waste quantities.

This means that ISCC certified waste collectors (collecting points) in Denmark, who are registered with and supervised by the DNWR, do not have to receive and manage self-declarations from supplying points of origin. A risk-based auditing of their suppliers (points of origins) as part of the certification process of the collecting point is usually not required (unless there is indication of non-conformity or fraud).
However, the DNWR does not ensure that auditors from certification bodies, staff of ISCC and inspectors from national bodies have the possibility to conduct on-site examinations also at points of origin if required. This may be the case, for instance, to verify the claims made by the collecting point. Such an authorisation must be granted by the points of origin explicitly, e.g. as part of a 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 this is required. Collecting points registered with and supervised by the DNWR still need to become certified based on an on-site certification audit and can only sell material as sustainable under ISCC that is included on the ISCC list of materials.
Auditors must explicitly indicate in the ISCC audit procedures if the certified collecting point is registered with and supervised by the DNWR and how the right for third parties to access the point of origin is granted (e.g. as part of a contractual agreement with the certified collecting point).

2. Clarifications:

2.1 UCO and Food Waste

As already communicated in the ISCC system update as of 11 April 2017, ISCC has received reports about alleged re-labelling of waste and residues to be declared as used cooking oil (UCO).

We herewith point out again that UCO is oil that has been used to cook food for human consumption (please also see ISCC list of materials). UCO is usually generated at restaurants, canteens, or similar operations where food is cooked. At such points of origin other waste or residues like food waste (e.g. leftover food that was thrown away) may be generated in addition to UCO. However it is not allowed under ISCC to declare, classify or label any materials as UCO that does not meet the definition of UCO. Such materials, for instance food waste, are different materials and must be reported separately.

The certified collecting point is responsible for the correct declaration of the waste or residue and for keeping feedstock-specific mass balances. All materials that are collected as sustainable under ISCC must be included on the annex to the collecting point’s ISCC certificate. This means, a collecting point that collects UCO and food waste as sustainable must keep separate mass balances for both materials and both materials will be stated on the annex to the certificate. If different sustainable materials are received, it is not allowed to keep one mass balance for UCO only and sell all outgoing material (e.g. UCO and food waste) entirely as UCO. If food waste is processed to retrieve oil, the retrieved oil can also not be labelled UCO. Such practice is a fraudulent re-declaration and a very serious infringement of ISCC requirements. If such practices are revealed, this will lead to the consequences specified in the ISCC Terms of Use, including the immediate withdrawal of the certificate and a suspension from recertification of up to 60 months.

2.2 Categorisation of Animal Fat / Tallow

We herewith point out that the categorisation of animal fat / tallow according to the categories 1, 2 and 3 must be done by veterinarians or inspectors of competent authorities in accordance with the EU animal by-product legislation (Regulation (EC) 1069/2009 and Commission Regulation (EU) 142/2011). Points of origin for animal fat / tallow (e.g. rendering plants) require an adequate permit demonstrating which materials can be handled. ISCC auditors must verify the respective evidence demonstrating the category of the material before issuing a certificate and before stating a specific category on the annex to an ISCC certificate. This is especially important if the rendering plant (point of origin) is located outside of the European Union.

If the category of the animal fat / tallow according to the applicable EU animal by-product legislation cannot be demonstrated and verified during the audit, the animal fat / tallow must be considered as “uncategorized” under ISCC.

Further information on the EU animal by-products regulations is available on the website of the European Commission, including lists of approved EU and Non-EU animal by-product establishments specifically indicating the respective categories of animal fat / tallow.

3. Update: ISCC List of Materials

ISCC has updated the ISCC list of materials. Cotton and whey permeate were added to table 1 (raw materials) and flour / meal was added to table 2 (intermediate and final products). Furthermore, information about the waste status of particular materials in Ireland, the Netherlands and the United Kingdom was included.

The ISCC list of materials is available in the client section of the ISCC website (login required).

4. ISCC Trainings – Forthcoming Dates

ISCC EU and PLUS Basic Training (3 days)
22 – 24 January 2018, Cologne, Germany (fully booked, waiting list)
07 – 09 March 2018, Bogotá, Colombia
24 – 26 April 2018, Cologne Germany

Click here for further information and registration

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 a certification body is conducting audits and certifications that include the verification of actual greenhouse gas calculations, the certification body must ensure that at least one GHG expert has participated in an ISCC Greenhouse Gas Training.

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

The ISCC Team wishes you a happy holiday season and all the best for 2018!

Your ISCC Team