Dear Ladies and Gentlemen,
We herewith inform you about additional measures ISCC is implementing to strengthen the ISCC certification process, particularly focusing on waste and residue-based supply chains. 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: In 2018, ISCC founded the ISCC Technical Stakeholder Committee (TC) “Waste, Residues and Advanced Low Carbon Fuels”. The TC supports the constructive dialogue on the sustainability certification of waste and residue-based and advanced low carbon fuels. As part of the TC, a working group was established with the goal to develop specific suggestions on how the ISCC certification for waste and residues can be further improved and made even more secure. The measures that were suggested and discussed by the working group since the beginning of 2019 were presented and discussed during the second meeting of the TC on 02 July 2019 in Shanghai (the presentation of the meeting is available here). This System Update informs about the additional measures that will be implemented by ISCC.
1. New Requirements under ISCC
All of the following new requirements shall come into effect for audits taking place from 01 January 2020 onwards.
1.1 Verification of the Existence of Points of Origin
Collecting points shall submit the list of all points of origin (PoO) that have signed the ISCC Self-Declaration to the auditor prior to the audit of the collecting point. Based on this list, the auditor shall verify the existence of a sample of the PoOs on the list. This verification can be done remotely e.g. through an internet research, through a telephone call, or through other substantiated evidence.
The auditor has to verify the existence of at least the square root of all PoOs that have signed the ISCC self-declaration within 12 months prior to the audit (rounded up to the next full number).
Example: 500 PoOs have signed the self-declaration: √500 = 22,36. This means the auditor shall verify the existence of 23 PoOs.
1.2 Mass Balance Verification prior to the Audit
All System Users shall submit the mass balance prior to the audit to the certification body (CB) conducting the ISCC audit. Time during an audit is often limited and mass balances are often complex calculations. Therefore, this new requirement shall enable the auditor to get a detailed understanding of the mass balance prior to the on-site audit. During the on-site audit, the auditor must verify the documentation and evidence supporting the mass balance calculation (e.g. delivery notes, sustainability declarations, weighbridge tickets).
1.3 Submitting Individual GHG Calculations to ISCC
ISCC is increasingly contacted by authorities such as the European Commission and national authorities of EU Member States investigating about the compliance of actual GHG emission values. To further facilitate a prompt investigation by ISCC in case of alleged non-compliance of actual GHG emission values, ISCC has decided that individual GHG calculations shall generally be submitted to ISCC by the CB together with the certification documents. Please note that it is already a requirement, that the system user must submit the calculation to the CB to be verified by a GHG expert prior to the on-site audit.
Please also be aware, that it remains the obligation of the system user to conduct the individual GHG calculation according to the methodology that is specified in the ISCC System Document 205 “Greenhouse Gas Emissions”. Furthermore, we point out that it remains the sole responsibility of the GHG expert at the CB and its auditors to verify the compliance of the actual GHG calculation.
1.4 Mandatory Surveillance Audits
Following the suggestions made by the ISCC Technical Working Group “Waste, Residues and Advanced Low Carbon Fuels”, ISCC has decided to introduce mandatory surveillance audits after the first (initial) certification of any system user in a high-risk supply chain. A high risk applies to such economic operators that are collecting, processing, storing or trading materials, which are or may be eligible for extra incentives in individual EU Member States (e.g. double-counting), such as waste and residues or waste and residue-based products.
If a new system user belongs to a high-risk supply chain, the CB shall conduct a surveillance audit six months after the first certification of the respective system user. This surveillance audit may be conducted remotely if a risk assessment for the individual system user by the CB has demonstrated a regular risk. If the risk assessment has shown a risk higher than regular, the surveillance audit shall be conducted on-site.
For collecting points and traders that are dealing with both, waste and residues (e.g. used cooking oil or animal fat) and with virgin vegetable oils (e.g. palm oil, rapeseed oil), the surveillance audit shall be conducted three months after the first certification (covering the first mass balance period). This surveillance audit shall be conducted in addition to the audit that takes place six months after the first certification and shall follow the same risk-based approach.
This new requirement applies for new system users who aim to become certified for the first time. System Users that are already certified and want to become recertified will not be subject to the above surveillance audits.
2.1 Availability of Evidence during the Audit
Due to recent inquiries, we herewith point out that each ISCC system user is obligated to keep the evidence that is required to verify compliance with the ISCC requirements. This evidence must be provided to the auditor during the audit. This obligation is laid down in the ISCC System Document 204 “Audit Requirements and Risk Assessment”:
“System Users must have a documentation and quality management system which can be audited by the CB. Such a system must include evidence related to the claims the System Users makes under ISCC, e.g. Sustainability Declarations, Proofs of Sustainability, or related contracts. The relevant documentation must be kept for at least five years. System users are responsible and obliged for preparing any information related to the auditing of such evidence and documentation.“ (page 8)
„It is the responsibility of the first gathering point or collecting point to provide evidence to the CB, which sustainable materials are (or will be) received from farms or from points of origin. Evidence regarding the type of sustainable material can include self-declarations, delivery documentation, or contracts with suppliers. The respective materials will be published on the ISCC certificate.“ (page 15)
„The entire documentation relevant for ISCC for a complete year must be available during an ISCC audit in order to evaluate the mass balance calculation and allow for plausibility checks between company reporting and mass balance results.“ (page 28)
2.2 Auditing of Mass Balance of Storage Facilities
We herewith point out that in case a certified system user (e.g. a trader with storage) uses external storage facilities (located at different addresses) to store sustainable material, the system user must keep a site-specific mass balance for each individual storage facility. During the certification audit of the system user a sample of all storage facilities (that do not hold an own certificate) must be audited on-site. In addition, the auditor has to check the mass balance of each individual storage location. Mass balance audits have to be conducted according to the process defined in ISCC System Document 204, chapter 4.3. Checking only a sample out of multiple different mass balances that are kept by the system user is not sufficient.
3. Notification about Withdrawn Certificates and Suspended System Users
ISCC has implemented a notification service for withdrawn certificates and suspended system users. This service is intended to support system users who want to be regularly informed about the validity of certificates. Please note that it does not release system users from the obligation to ensure and verify that suppliers have a valid ISCC certificate.
The notification e-mails will only contain basic information about the withdrawn certificates and the suspended companies. Due to our data protection policy, we are not allowed to share further information about the reasons for the withdrawal of a certificate or the suspension of a company. Serious infringements committed by a system user lead to the withdrawal of the certificate and the suspension of the registered unit. For more information and examples for serious infringements please consult the ISCC System Document 102 “Governance”, chapter 10.
4. Updated Self-Declaration UCO
ISCC has adjusted the template for the Self-Declaration for used cooking oil (UCO). As suggested by the ISCC Technical Working Group “Waste, Residues and Advanced Low Carbon Fuels”, the self-declaration shall now contain information about the approximate amount of UCO produced per month, and a phone number of the point of origin. Furthermore, the definition of UCO and the statement that the UCO meets the definition of waste according to ISCC and the RED was added. In addition, the information regarding the origin of the UCO was simplified. The point of origin may now indicate if the UCO is entirely of vegetable origin. If this optional information is not stated on the self-declaration, it shall be assumed that the UCO is of animal origin or at least a mix of vegetable and animal oil. 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. Other EU Member States do not require this differentiation. If Germany is not the target market this statement can thus be considered as optional.
ISCC is keen to gather feedback regarding the updated self-declaration for UCO from system users and other interested stakeholders before its implementation. For this reason, the updated self-declaration is open to public consultation until 15 October 2019 and can be downloaded here. ISCC is pleased to receive feedback submitted via this contact form.
Please note that this version is a draft. The final version of the updated self-declaration will be published after the public consultation period. System users will be informed in a system update and an appropriate transitional period to implement the final version will be given.