24 October 2016
Dear Ladies and Gentlemen,
We herewith inform you about the transitional period applicable for the re-recognized ISCC EU system.
1) ISCC EU Re-Recognition and Transitional Period
As already communicated on 10 August 2016, the European Commission has adopted the decision to re-recognize ISCC EU as a voluntary certification scheme on 09 August 2016. This decision was published on the ISCC website and can be applied. An overview on the main changes under ISCC EU resulting from the re-recognition is also available on the ISCC website.
ISCC EU System Users must implement the changes resulting from the re-recognition by 01 January 2017 the latest.
Exception for GHG changes:
The adjusted methodology for actual GHG emission values (see overview on the changes under ISCC EU) results from the Commission’s “Note on the conducting and verifying actual calculations of GHG emission savings”. This Note was provided to ISCC and two other voluntary schemes on 17 July 2016. The initial version of this Note is available on the Commission’s transparency platform. According to the cover letter of this Note, the principles from the Note “should be implemented by all voluntary schemes that have been recognised at the latest by July 2016. The changes should be applied by the operators participating in the scheme at the latest by end of 2016“.
It is currently not clear if it is ensured that all recognized voluntary schemes will implement these principles in a harmonized way by the end of 2016. We point out that a non-harmonized implementation of the Commission’s Note may result in market distortions. The reason for this is that the adjustments resulting from the Note do not only affect individual economic operators and their GHG calculation methodology, but all elements of the supply chain and the way GHG information is forwarded through the supply chain. For an unhindered flow of materials between different voluntary schemes it is important that all voluntary schemes operate on the same basis with respect to GHG calculation methodology and forwarding GHG data (regardless whether the scheme is already re-recognized or not). Therefore, a clear guidance and a distinct implementation date by the Commission obligatory for all recognized voluntary schemes are required to avoid market fragmentation. ISCC has contacted the European Commission to clarify when the GHG Note must be applied by all recognized voluntary schemes and their system users.
To ensure the continuous flow of sustainable material throughout the supply chain and to avoid market and trade distortions the adjustments resulting from the GHG Note are not obligatory to implement until further notice.
2) Acceptance of Schemes with an Expired Recognition
Out of seven voluntary schemes that were due for re-recognition in August 2016, ISCC EU was among the first three schemes to be re-recognized. Besides ISCC, the RSB EU scheme and the 2BSvs scheme have been re-recognized by the Commission. The remaining four voluntary schemes Bonsucro EU, RSBA, Greenergy, RTRS have not been re-recognised yet as stated on the Commission’s transparency platform. In the letter from 02 August 2016, the Commission recommended “to the voluntary schemes to continue accepting evidence from those … schemes” even in case of a gap between the recognition periods. ISCC will follow the recommendation by the European Commission. This means, ISCC EU certified system users can continue to accept sustainable material from economic operators certified with a valid certificate under those schemes that have applied for re-recognition and are affected by a gap in the recognition period.
This exception applies until 02 November 2016 the latest.
3) Update ISCC List of Materials
The ISCC List of Materials has been updated. The latest version is available in the client section of the ISCC website.
If you have any further questions, please do not hesitate to contact us.
With kind regards,
Your ISCC Team