16 August 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 EU: Updated Audit Procedures
The updated versions of the ISCC EU Audit Procedures (v3.2) are now available.
The Audit Procedures contain the updated GHG requirements reflecting the adjusted GHG methodology that must be implemented by 01 September 2017. Furthermore, feedback from System Users and Certification Bodies regarding formatting and wording issues has been taken into account.
The updated version of APS (Audit Procedure System) with exactly the same content as the Audit Procedures (in pdf) that will be published shortly. Furthermore, with this update of APS the Summary Audit Report (implementation date for audits conducted as of 01 September 2017) can be generated automatically from the tool.
The new Audit Procedures (APS (v3) or pdf (v3.2)) must be applied for ISCC EU audits as of 01 September 2017. An earlier application is possible.
2. ISCC EU: Templates ISCC PoS (“Blue PoS”) and Sustainability Declaration
ISCC has updated the template for the “Proof of Sustainability for Biofuels and Bioliquids” (“Blue PoS”) (v4.1). This update includes the new methodology to forward information on actual GHG emissions.
Based on feedback from System Users, ISCC has developed a template for a “Sustainability Declaration for Raw Materials and Intermediate Products” (v1.1). This template can be applied by all elements in the supply chain upstream the production of final biofuels and bioliquids.
The use of both templates ensures that System Users forward all relevant sustainability information to their clients. Both templates are available as download in the client section of the ISCC website.
Please note that the use of both templates is voluntary. ISCC does not make any provisions regarding the layout of sustainability declarations and proofs of sustainability. As long as it is ensured that all relevant sustainability information are included, companies may also set up own templates or attach the sustainability information to already existing delivery documents (e.g. bill of lading).
3. Reminder: Adjusted GHG Methodology
3.1 Implementation from 01 September 2017
We herewith remind you that according to a communication of the EC to all voluntary schemes recognised by the EC since August 2016, the adjusted GHG emission calculation methodology has to be fully implemented by all System Users by 01 September 2017. This was already communicated by ISCC in System Updates dated 11 May and 30 June 2017. For detailed information on the new methodology please see ISCC document 205 “Greenhouse Gas Emissions” and the “Note on the conducting and verifying actual calculations of GHG emission savings” published by the European Commission (EC).
In case operators receive proofs demonstrating compliance with GHG emission requirements that are not issued in accordance with the updated requirements, the EC recommends applying 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.
3.2 Downstream Combustion Emissions of Fossil Methanol
As communicated in our System Updates as of 11 May and 30 June 2017, 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.
The EC has confirmed that the emission factor for fossil methanol from the list of standard values for emission factors (“standard calculation values v.1.0″) published by the EC includes the combustion emissions of the fossil methanol and that this concept must be applied in all Member States and under all recognized voluntary schemes. This means that the combustion emissions of fossil methanol must be taken into account for the GHG calculation for the biodiesel production.
Please note that points 3.1 and 3.2 apply 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).
3.3 Actual calculations – Alternative Values for Emission Factors
In the “Note on the conducting and verifying actual emission savings” the European Commission (EC) highly recommends to apply the standard values for emission factors that are provided in a list available on the website of the EC. This list is not exhaustive. The EC further states, that in case an item is covered by the list, alternative values used must be “flagged” in the GHG calculation and “duly justified”.
The following scenarios and proceedings are possible:
- An emission factor is available on the list and is applied:
- No further steps required
- No emission factor is available on the list. The system user uses a value from other sources. Other sources can be factors from databases, literature and individual calculations*:
- The value has to be flagged, and the source of the value has to be provided
- An emission factor is available on the list, but the system user wants to apply an alternative value:
- The value has to be flagged, the source (database, literature or individual calculation*) of the value has to be provided, and the user has to explain the reason for applying an alternative value. One reason for applying alternative emission factors would be a deviation of emission factors between worldwide production and regional production. If ISCC only refers to worldwide production, but the system user can show that a chemical product was regionally sourced, he could also use the emission factor for regional production instead of worldwide production. Another reason could be, if the system user uses a chemical product whose composition is not entirely in line with the materials on the list
* In case of scenario 2 and 3: If an alternative emission factor is based on an individual calculation, the party providing the calculation has to state, that the calculation methodology is compliant with the calculation methodology of the RED (e.g. all GHG emissions incl. CH4 and N2O are taken into account, an energetic allocation was applied for co-products, emission factors for energy supply include direct (from combustion) and indirect (upstream emissions) effects, the emission factor for the regional electricity mix was used if the electricity is consumed from the grid, and green certificates (“Grünstromzertifikate”) have not been taken into account).
4. Clarification: Mass Balance Period
The mass balance calculation requires the definition of the timeframe. The maximum timeframe (period) for a mass balance calculation is three months.
The mass balance periods for the certification period must be clearly documented by the System User (beginning and end date), and any changes in the mass balance periods must be reported to the Certification Body. For each mass balance period a mass balance calculation including credit transfer to the next period must be documented and provided during the audit.
Mass balance periods shall be continuous in time, i.e. there shall be no gaps between the mass balance periods. This means that also for periods without movements of sustainable material mass balances have to be kept.
5. ISCC EU and PLUS Basic Trainings – Upcoming Dates
29 – 31 August 2017, Bali, Indonesia
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