22 December 2021

Dear Ladies and Gentlemen,

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

1. Suspensions of Certificates and Exclusions of System Users

We herewith highlight the introduction of an additional status of ISCC certificates with the update of the ISCC EU System Documents due to provisions from the European Commission in the framework of the REDII.

ISCC introduced the status of “suspended” certificates which refers to certificates that have been made temporarily invalid by the certification body due to major non-conformities detected or due to well-founded and urgent suspicion of severe non-conformities or fraud.

We would like to highlight that during a suspension period, the system user is not allowed to handle material as sustainable under ISCC or to use the ISCC logo or make any claims referring to an ISCC certification or ISCC certified material. This also means that the system user is also not permitted to act e.g. as dependent collecting point or dependent storage facility for a certified system user.
Information on the suspension period of certificates will be published here on the ISCC website in the list of certificates. This information will remain visible after the suspension period ended as certification bodies must be able to verify in ISCC audits if suspension periods where respected by any affected system user.

Please kindly note that before the update of the ISCC System Documents the term “suspension” referred to System Users that were excluded from ISCC certification for a specified period of time. (e.g. due to serious non-compliance or fraud). In the revised System Documents, this is now referred to as “excluded” system users.

Please see chapter 10 of ISCC System Document 102 “Governance” (v4.0) for further information. The document can be found here on the ISCC website.

2. Indication of the Specific Start Date of Operations for Final Biofuel Producers

We herewith remind you that all proofs of sustainability (PoS) issued by producers of final biofuels, bioliquids or biomass fuels must include the specific date when the producer started the operation. This information was included in the template of the PoS with version 2.1 from 7 September 2021. In this context, we would like to clarify an approach to avoid the risk of the rejection of PoS that have been issued without this specific information.

  • Companies should try to get the missing date from the supplier/producer.
  • If the companies cannot get the specific date, but they can get the information whether the producer started operation on or before 05 October 2015, between 06 October 2015 and 31 December 2020 or on or after 01 January 2021, this information can be provided.
  • If the companies cannot get either of the information above, the field can be left blank without this being evaluated as a non-conformity in the next ISCC audit. However, please note that for these PoS there may a risk that the Member States authorities may not accept such PoS. We therefore recommend that you investigate and provide the information on the specific date whenever possible.

3. Forwarding of Actual Calculated GHG Emission Values

Please note that the REDII provides the following options to calculate and forward GHG emission values: (disaggregated / total) default values, NUTS 2 values and individual GHG emission values. In case of the latter, we would like to clarify that the exact value that has been verified and approved by a certification body must be forwarded to the next operator in the supply chain. Altering actual values in any direction is not permitted. A respective verification must take place during the certification audit. This understanding was also recently confirmed by the European Commission.

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

Your ISCC Team