29 May 2020
Dear Ladies and Gentlemen,
We herewith inform you about updates and clarifications in the ISCC System. ISCC is implementing an update of several requirements in its standard, aiming for more clarity as to their exact meaning and scope of application. Please note that it is the responsibility of system users and certification bodies to take the ISCC System Updates into account and inform all relevant members of staff about the updates.
Background: ISCC regularly engages in Benchmarking processes comparing different sustainability certification systems. The results of these benchmarks are used to improve and strengthen the ISCC standard. As part of this process, ISCC has decided to update some of its requirements for reasons of clarification of already implemented requirements as well as to strengthen their application where necessary. The following changes are made to the current ISCC standard, valid as of 01 July 2020.
1. Update ISCC System Documents and Procedures
1.1 Strengthened Sustainability Requirements for Farms/Plantations under ISCC (ISCC Document 202)
Prohibition of Chemicals under ISCC (Major must criterion 07.01.24)
Chemicals listed in the Stockholm Convention on Persistent Organic Pollutants as well as listed in WHO classes 1a and 1b are prohibited under ISCC. While substances listed in the Stockholm Convention have been prohibited before, up to now chemicals listed on WHO 1a and 1b were required to be avoided under ISCC. Therefore, the auditor from now on has to additionally verify that no chemicals listed in WHO 1a and 1b are applied on the farm. In order to grant an appropriate transitional period, a phase-out plan must be set-up in cases were WHO 1a and 1b chemicals are still used. The plan must contain steps to abandon the substances concerned by 01 January 2023 latest. In cases where there is no adequate alternative to these chemicals available, this must be evaluated and confirmed by an external expert. Some of the WHO 1a and 1b chemicals are not covered under current EU legislation – this requirement must thus be verified by the auditor also for farmers covered under EU cross compliance.
Requirements to Lower Greenhouse Gas Emissions from Operations (Minor must criterion 07.01.53)
ISCC requires producers to reduce fossil energy consumption and to lower greenhouse gas emissions. To provide more guidance on how to monitor and achieve this, ISCC strengthened this requirement by asking producers to set-up an improvement plan, recording the total direct use of fuels over time for all activities. The plan also includes an assessment of major air pollutants for the unit of certification (e.g. carbon monoxide, nitrogen oxides, particulate matter, etc.).
Provision of Adequate Information on Legal, Social and Environmental Issues to Relevant Stakeholders (Minor must criterion 07.01.63)
ISCC Principle 4 requires compliance with Human, Labour and Land Rights. In this regard, negative environmental, social, economic and cultural impacts are to be avoided and regular meetings with communities and local governments are required. To strengthen this aspect, ISCC now asks for adequate information to relevant stakeholders on legal, social and environmental issues related to the ISCC certification. This information must be presented to stakeholders in an appropriate language.
Process of Free Prior and Informed Consent (Major must criterion 07.01.85)
ISCC has strong requirements for the legitimacy of land use and the respect of the rights of indigenous communities. To clarify these criteria and provide for an internationally applied procedure, the process of Free Prior and Informed Consent is to be applied from now on in case of new land acquisitions.
Please find the adjusted requirements in the ISCC Document 202, v. 3.1.
1.2 ISCC Risk Approach: Selecting Samples and Determination of Risk-Level
ISCC System Document 206 sets criteria on how to audit groups under ISCC and the selection of samples. With regard to the verifiability of all group members within a certain time frame, ISCC states that “as long as there is no indication of non-conformity from specific group members, none of the successfully audited entities from the previous year shall be part of the sample in consecutive audits, as long as there remain some entities that have not yet been subject to an external audit”. The new addition to this provision includes the general requirement for entities to aim for selecting samples in a way to ensure that all group members are equally covered, generally within a timeframe of five years. Please find the adjusted requirement in the ISCC Document 206, v. 3.1.
Application of ISCC Criteria to Determine the Risk-Level of Operations
The ISCC Risk Assessment (as explained in chapter 4.2 of ISCC Document 204), provides guidance to the respective auditor on how to evaluate the risk level of the System User to be certified. Risk indicators are listed to support the guidance (e.g. general risk indicators, risk indicators for farms and plantations, risk indicators for waste and residues). To make the risk assessments and respective indicators better comprehensible for ISCC, auditors are now asked to indicate how the ISCC criteria to determine the risk-level of operations (in accordance with ISCC Risk Assessment requirements – ISCC 204, 4.2) have been applied. This is to be indicated in the findings section of the respective audit procedure.
1.3 Clarification of the Definition of Farms as Legal Entities (ISCC Document 201)
In order to be covered by an ISCC certification a farm has to be “defined as a distinct legal entity having control regarding the compliance with the ISCC requirements”. To clarify this definition, the corresponding passage has been amended in ISCC Document 201, v.3.1. This definition is now valid throughout all related ISCC Documents.
1.4 Co-processing Requirements under ISCC PLUS
New questions were added to the ISCC and ISCC PLUS Audit Procedure for Chain of Custody v4.2 which specifically address co-processing under ISCC PLUS. The used approach to determine the sustainable share and the option for the attribution of the sustainable share shall now be stated specifically for ISCC PLUS (questions 00.05.15 and 00.05.17). Furthermore, new questions were added under section 02.06. These questions deal with the specific requirements for the different approaches to determine the sustainable share and with the correctness of its determination, application and attribution.
The updated audit procedures including all changes from point 1.1, 1.2 and 1.4 must be used for all ISCC audits from 01 July 2020 onwards. An earlier application is possible on a voluntary basis.
Please click here to find the updated ISCC audit procedures as pdf files. The word files can be found here in the client section of the ISCC website (login required). The updated version of APS will follow shortly.
2. Updated ISCC Documents
ISCC PLUS Material List
Table 1 “Raw material”
- Contaminated paper and cardboard was added
Table 2 “Intermediate and final products”
- Fabrics/Scrimcs (The following info was added: “Can be further specified (e.g. nonwovens)”)
- Pesto was added
Please note that the ISCC PLUS list 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 version of the ISCC PLUS list of materials (as of 29 May 2020) is available here in the client section of the ISCC website (login required).
ISCC EU Self-Declaration for Used Cooking Oil (UCO)
After the evaluation of the Public Consultation feedback for the draft version of the updated Self-Declaration for used cooking oil (UCO), version 2.0 is now available herein the client section on the ISCC website (login required). The Self-Declaration shall now contain the Point of Origin’s phone number and information whether the production threshold of 10 metric tons per month of waste is reached. In addition, information regarding the origin of the UCO was simplified. The point of origin shall now indicate if the UCO is entirely or partly of animal origin. If this information is not ticked off, it shall be assumed that the UCO is of vegetable origin. Please note that the differentiation of the UCO origin (vegetable or animal) became necessary due to the German law which excludes UCO of animal origin to be counted towards the German quota. Further updates are the integration of the definition for UCO and the statement that the UCO meets the definition of waste according to ISCC and the RED, as well as a statement regarding the right of the collecting point’s certification body and ISCC to receive and review the self-declaration.
Version 2.0 of the UCO Self-Declaration shall become effective for all Points of Origin of UCO by 01 April 2021. Points of origin are free to implement version 2.0 of the UCO Self-Declaration at any earlier point in time. Please contact us via email@example.com if you need an ISCC Self-Declaration translated into another language.
ISCC PLUS Sustainability Declaration V2.5
ISCC has updated the ISCC PLUS Sustainability Declaration with all materials that are eligible for certification under ISCC PLUS. Further, a definition of “Raw materials” has been added in the footnotes. The updated template (v2.5, May 2020) is available here in the client section of the ISCC website (login required).
3.1 Accounting for Green Electricity in GHG Calculations
ISCC has been contacted recently increasingly by System Users and auditors regarding the accountability of “green electricity” and respective emission factors. Hence, ISCC would like to point out that the DIRECTIVE 2009/28/EC states the following in Annex V, C, 11: “In accounting for the consumption of electricity not produced within the fuel production plant, the greenhouse gas emission intensity of the production and distribution of that electricity shall be assumed to be equal to the average emission intensity of the production and distribution of electricity in a defined region. By derogation from this rule, producers may use an average value for an individual electricity production plant for electricity produced by that plant, if that plant is not connected to the electricity grid.” This means that if the plant is connected to the electricity grid, no alternative emission factors for electricity can be used.
3.2 Receiving Materials as Sustainable prior to the Certification Period
We received feedback from the market that some certification bodies ask for the existence of amounts of sustainable material during initial (first) certifications. Please note that “the receipt of sustainable material is also only possible if the recipient has a valid certificate” (ISCC System Document 203, chapter 3.3.2).
The only exceptions to this apply for First Gathering Points (FGP) and Collecting Points (CP) (see ISCC Document 203, chapter 3.4.3 & 3.4.5). An FGP or CP may receive materials as sustainable up to three months prior to the start of the validity of the certificate. This is only possible under the condition that signed Self-Declarations for the Points of Origin or Farms/Plantations are in place at the date of the receipt of the material and that the FGP and CP fulfil the chain of custody requirements. The material received this way can only be dispatched and merchandised as being sustainable following the start of the validity of the certificate.
4. Updated Nabisy-FAQ
Please note that the German Federal Office for Agriculture and Food (BLE) has published an updated version of the Nabisy-FAQ (in German). The new version can be downloaded here on the website of the Federal Office for Agriculture and Food (BLE).
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