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. New Guidance Document for the Certification of Algae
We are happy to publish a newly developed guidance document for the certification of algae which are cultivated on land in ponds or photobioreactors. The new guidance document is available in the public consultation section of the ISCC website and can be downloaded here. ISCC would highly appreciate to receive further stakeholder feedback via the contact form on our website. The public consultation will last for 60 calendar days, until 06 November 2021.
Please note that the guidance document and the processes described therein can be applied with immediate effect. This means that the certification of algae as a sustainable raw material according to ISCC will be possible as of today (see also the adjusted ISCC EU list of materials under item 4 of this update).
2. Clarification on “Place of receipt” on Sustainability Declarations/PoS
Sustainability Declarations (SD) and Proofs of Sustainability (PoS) issued under ISCC must generally include the “address of receipt/receiving point of the sustainable material”.
In case the recipient of sustainable material is responsible for organizing the transport of the material from the supplier, the supplier may not know the address of receipt/receiving point. This can be the case if it is agreed that the delivery is made e.g. on “FOB” or “free-on-board” basis. If the supplier, due to the contractual arrangements, does not know the address of receipt/receiving point, the supplier can indicate on the Sustainability Declaration or the PoS that the “address of receipt/receiving point” is the same as the address of the recipient. In addition, a reference has to be made (e.g. in the field “additional information”) that the recipient is responsible to determine the “address of receipt/receiving point” due to the contractual arrangement. It is the obligation of the recipient to ensure the traceability of the material and to provide the necessary evidence to the auditor.
In scenarios such as the above, the supplier will also generally not know necessary information for the determination of GHG emissions for transport, such as the means and distance of transport. This information is available at the recipient as being the responsible party organising the transport and calculate the GHG emissions from transport (if actual GHG values are used). Please note that all other required GHG information must still be provided by the supplier.
3. Temporary Measure for the Application of Default Value “waste cooking oil biodiesel”
Due to frequent inquiries, we herewith clarify the following scenario:
The RED I included (disaggregated) default values for “waste vegetable or animal oil biodiesel”. These values could be applied for biodiesel produced from different kinds of waste vegetable or animal oils, provided that the application of the default values was accepted by authorities in the target market. These default values were revised and renamed under the RED II. The revised default values now explicitly refer to “waste cooking oil biodiesel” (i.e. biodiesel produced from used cooking oil). They are thus no longer applicable to other biodiesel pathways, i.e. biodiesel produced from other waste vegetable or animal oils.
This has created a challenging situation for materials in the supply chain for which System Users have so far applied the default values from RED I for “waste vegetable or animal oil biodiesel” for biodiesel pathways from other waste vegetable or animal oils. To avoid market disruption for those materials ISCC has defined the following exceptional and temporary measure:
Affected System Users shall promptly take the necessary actions for applying individual GHG calculations. These actual GHG values will need to be verified by the certification body (CB) remotely before they can be used by the System User. On-site verification by the CB must follow during recertification at the latest.
During the time the calculation and verification of actual GHG values is conducted, System Users who forwarded sustainable material using the default values for “waste vegetable or animal oil biodiesel” from the RED I can temporarily use the default values for “waste cooking oil biodiesel” from the RED II. Collecting Points can issue Sustainability Declarations with default values for “waste cooking oil biodiesel” for deliveries taking place until 30 September 2021 at the latest. Economic operators in the downstream supply chain (i.e. processing units and traders/storage facilities) can issue Sustainability Declarations with default values for “waste cooking oil biodiesel” for deliveries taking place until 31 December 2021 at the latest.
Raw materials and intermediate products with the default value must be processed into biodiesel until 31 December 2021 and the respective Proofs of Sustainability (PoS) must be issued. The biodiesel producer can state the respective disaggregated default values for “waste cooking oil biodiesel” from the RED II on the PoS.
From 01 January 2022, the RED II default value for “waste cooking oil biodiesel” can only be used for UCO and the biodiesel produced from UCO. For waste and residue materials which are not covered by this default value actual GHG values must be used.
Please note that the acceptance of biodiesel produced from a waste vegetable or animal oil (except UCO) for which the default value was applied by a Member State ultimately depends on the regulations within the Member State, as was already the case under the RED I.
4. Updates on ISCC Documents
ISCC EU Material List
Table 1 “Raw material” – The following raw material was added:
ISCC EU Sustainability Declaration and Proofs of Sustainability
Please note that the template for the Sustainability Declaration for Raw and Intermediate Products (ISCC EU) (v2.1) and the Proofs of Sustainability for final biofuels, bioliquids and biomass fuels (ISCC EU) (v2.1) and for biogas/biomethane (ISCC EU) (v2.1) have been updated to include the materials listed in the ISCC System Update as of 05 August 2021.
In addition, the GHG section of the Sustainability Declaration template has been slightly adjusted and no longer includes the field “Ep (OM)”, where System Users could indicate the disaggregated default for the oil extraction step of Ep. Instead, the section now includes the statement “disaggregated default value for oil extraction only is applied”, which can be ticked with “Yes” where applicable.
Further, instead of including the respective statements, the specific start date of operations for the production of the final biofuel, bioliquid or biomass fuel now needs to be indicated on the Proof of Sustainability templates. The updated templates are available here in the ISCC client section on the ISCC website.