24 April 2020
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. Updated and New ISCC Documents
ISCC EU material list
Table 1 “Raw material”
- Additional information for crude glycerine was amended (now specifies: Glycerine that is not refined)
ISCC PLUS material list
Table 1 “Raw material”
- Waste PS was added
Table 2 “Intermediate and final products”
- Styrene monomer was added
Please note that both ISCC lists of materials can be amended. Please contact ISCC in case a material should be certified which is not yet on the list prior to the issuance of the certificate via firstname.lastname@example.org.
The current versions of the ISCC EU lists of materials (as of 24 April 2020) and the ISCC PLUS lists of materials (as of 20 April 2020) are available here in the client section of the ISCC website (login required).
ISCC PLUS self-declaration for post-industrial material
ISCC has developed a new self-declaration template for Points of Origin providing post-industrial material under ISCC PLUS. Post-industrial material covers e.g. material derived from waste streams during the system user’s manufacturing processes. For further information, please see ISCC PLUS Document, page 13.
The template is available here in the client section of the ISCC website (login required).
2.1 New Requirements Under ISCC Mandatory Since 01 January 2020
ISCC has gathered questions regarding the new requirements under ISCC which were introduced with the ISCC System Update from 19 October 2019 and which are mandatory for all audits since 01 January 2020. We herewith provide clarification regarding the following requirements:
Verification on the Existence of Points of Origin
Please note that this verification does not necessarily have to be carried out by the lead auditor. This task can generally also be carried out by competent staff in the office of the certification body. Furthermore, we like to clarify that in case the existence of a Point of Origin cannot be verified remotely, an on-site verification is mandatory before the Point of Origin is allowed to supply into ISCC supply chains.
Mass Balance Verification Prior to the Audit
Please note that the mass balance(s) should be submitted by every individually certified operational unit for each site (external storage facility or dependent collecting point) covered by the certificate.
Mandatory Surveillance Audits
Firstly, we would like to clarify again that this new requirement only applies for new System Users belonging to high-risk-supply chains who aim to become certified for the first time. A recertification after a certification gap is not considered as first certification. Hence, additional surveillance audits are not necessary. In case of a certification gap, the auditor must verify the System User’s compliance with ISCC requirement during the previous certification period.
Please note that generally, the classification of a System User as being part of a high-risk supply chain does not depend on the fact where waste/residues are collected or in which final market waste/residue based products are sold. A high-risk supply chain always applies if there is or may be some kind of extra incentive for the respective material (e.g. double-counting, classified as advanced, etc.).
The system user is obliged to inform the certification body which materials will be handled as sustainable under ISCC. Should a new system user, contrary to expectations, collect, process, store or trade waste or residual materials (or products made from them), the system user has to inform the certification body immediately and the surveillance audit has to be carried out accordingly. If such cases become apparent in the daily business of certification bodies, the certification body should additionally consult ISCC. The same procedure applies in cases where new Collecting Points or Traders with storage, contrary to expectations, deal with both, waste and residues (e.g. used cooking oil or animal fat) and with virgin vegetable oils (e.g. palm oil, rapeseed oil).
Since (paper) Traders do not receive physical possession of traded materials, there is no risk of physically mixing waste and non-waste materials. Hence, only the surveillance audit after six months must be conducted for (paper) Traders belonging to a high-risk-supply chain. The additional surveillance audit after three months is not required.
Moreover, we would like to clarify that the surveillance audits should mainly focus on traceability requirements, e.g. the verification of delivery documents and mass balances. The surveillance audit does not need to be an additional full audit, including the verification of management criteria or the verification of the sample. However, the risk factor determined by the auditor in the previous certification audit shall be applied during the surveillance audit. The surveillance audit must generally be planned in such a way that a completed mass balance period can be verified.
Finally, we would like to clarify that an earlier recertification of System Users, for whom a surveillance audit is required after three and six months, is not an option to avoid the additional surveillance audit after six months. According to the ISCC System Update from 01 October 2019, the responsible certification body must conduct a surveillance audit six months after the initial certification. An earlier recertification of the System User (e.g. three months after the initial certification) does not release the certification body from conducting the second surveillance audit.
2.2 Biogas and Biomethane
Any trade of sustainable material under ISCC always refers to a specific batch of sustainable material. For a delivery of sustainable material, a Sustainability Declaration or a Proof of Sustainability (PoS) shall be issued to the recipient. This Sustainability Declarations or PoS is always linked to a specific amount of physical sustainable material. Trading Sustainability Declarations or PoS without the equivalent amount of sustainable material is not allowed under ISCC as this would be considered as book-and-claim which is not allowed under the RED and FQD (see ISCC Document 203, p. 32) (LINK).
This means that in case of biomethane that is traded via the gas grid, the producer feeding the biomethane into the grid issues a PoS to the recipient. If the recipient is a (paper) trader, i.e. not receiving the material physically, this trader can sell the respective batch of ISCC certified material and forward the respective PoS to the recipient, e.g. to the party taking the biomethane (physically) out of the grid. The grid in this case is considered as transport. Please note that it is not allowed for a (paper) trader to buy or sell a PoS for biomethane without the respective amount of physical sustainable material linked to the PoS.
Lastly, we clarify that sustainability credits for biomethane cannot be transferred to Bio-LNG. Although both products may be chemically identical, biomethane and Bio-LNG must be handled as different products with different GHG values as the GHG emissions of the liquefaction of bio-LNG have to be taken into account. Please note that a Bio-LNG (liquefaction) plant is a processing unit and must be certified accordingly.
2.3 Correct Classification of Crude Glycerine
According to the RED only glycerine that is not refined can be classified as crude glycerine. During the audit of Points of Origin, the auditor must generally check whether or not the material generated at the Point of Origin is correctly classified and named. This means that for crude glycerine, the auditor must check if the material corresponds to the definition from the RED (i.e. no refining step has been carried out).
3. ISCC EU: Extension of the Recognition by the Commission of the “Scottish Quality Farm Assured Combinable Crops Limited’ Voluntary Scheme
The Commission Decision recognising the “Scottish Quality Farm Assured Combinable Crops Limited” voluntary scheme for demonstrating compliance of biofuels with the EU sustainability criteria under Directives 98/70/EC and 2009/28/EC will expire on the 8th of June 2020.
In a letter from 15 April 2020, the European Commission recommended that the recognised voluntary schemes continue to accept evidence from the voluntary scheme “Scottish Quality Farm Assured Combinable Crops Limited” until 01 July 2021.
ISCC follows the recommendation of the European Commission. This means that ISCC EU certified system users may accept deliveries from suppliers that are certified according to the above-mentioned scheme until 01 July 2021 at the latest.
A German translation of this system update will follow shortly.
If you have any questions, please do not hesitate to contact ISCC.
Your ISCC Team