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. ISCC Update on the Union Database
We would like to provide you with an update on the current implementation process of the UDB and what has been done in the previous weeks:
- Besides daily communication with the European Commission to discuss and finalize details within the UDB, ISCC has created a template in line with the UDB requirements to collect additional information, needed for the onboarding of Economic Operators into the UDB (e.g., materials and GHG values per scope, name and addresses of the sites covered by certificate, etc.). This template has been already provided to our ISCC EU system users via an e-mail on 22 May 2023. ISCC kindly reminds you to fill it out and send it back to us if you have not done it yet. Please note that without this information we cannot proceed further with your onboarding into the UDB. Once the UDB is actively operational, ISCC will be collecting this data online via the ISCC Hub during the registration and certification stages and streamlining the UDB onboarding promptly via system-to-system connection.
- In the template provided the National Trade Register Identifier (NTR ID) has been requested as well. This ID is required by the UDB for the Economic Operators to uniquely identify themselves to other parties (sellers/buyers) so that UDB can ensure consistency across all Voluntary Schemes. The NTR type is differentiated per country. If the NTR type for your country is missing, please let us know and we will request it from the EC UDB team.
- The UDB FAQ page has been updated and can be found on the ISCC website.
- ISCC has been collaborating with several Access Point (AP) providers to enable direct communication with the UDB e-delivery. Details and technical information will be made available mid-June to enable system users whose backend systems are ready for system-to-system communication integration to onboard an AP.
2. FAQ About the ISCC System Updates Content of 18 and 28 April 2023
Some questions were raised about specific requirements on the content of the ISCC System Update on 18 April and the ISCC System Update on 28 April 2023. You can now find the related questions and answers on the ISCC website.
We would further like to specify the following points of the System Update, valid as of 01 August 2023 for initial and recertification audits conducted from this date onwards (earlier application is possible):
1. Audits for individually certified Points of Origin, Collecting Points, and Central Offices handling waste/residues from processing of animal or vegetable oils / soapstock, food waste, POME oil, brown grease/grease trap fat, sewage sludge and/or UCO need to be conducted under high risk level.
ISCC EU System Document 204 “Risk Management” provides the guideline that for audits with high risk level, the documents from three consecutive months should be checked. We herewith clarify that in cases where the amount of documents from three consecutive months exceeds a reasonable audit scope (e.g., due to high numbers of deliveries from small PoOs such as UCO from restaurants), the sample size of the documents can be reduced. If the audit includes sampling of third-party locations, e.g., Points of Origin or storage facilities, the minimum sample size must be multiplied with the risk factor 2.0.
ISCC will discuss more detailed indications for high-risk audits to reduce the risk of fraud and provide further information shortly.
2. For waste/residues materials that are generated at an oil mill, refinery or other processing unit, the information of the Point of Origin (name and address) must be forwarded on Sustainability Declarations. We herewith clarify that this requirement is limited to Collecting Points and Central Offices (for groups of Points of Origin) forwarding waste/residue materials that were generated from processing units. Collecting Points and Central Offices need to indicate the name and address of the Point(s) of Origin on the Sustainability Declaration to their recipients. ISCC will shortly provide adapted templates of Sustainability Declarations that include a field for the relevant information.
3. Modification of the requirement that the certificate of Collecting Points will have to be suspended for 40 days by the CB if no material was collected within the first three months of the validity period of the certificate: After considering stakeholder feedback received, this requirement has been modified. As described in the ISCC System Update of 18 April 2023, System Users may not be certified as a Collecting Point if no materials are collected from Points of Origin with self-declarations. If a recertification audit identifies that in the previous certification period, no material was collected, the scope Collecting Point must be removed from the certificate.
If it was not possible to collect material reasonable and verifiable reasons must be presented to the auditor. If deliveries from Points of Origin are expected for the next certification period and this can be demonstrated by the Collecting Point the scope can be included on the certificate again. Further guidance will be provided in due time.
Also, ISCC will update the due-diligence processes and requirements for new registrations with ISCC to verify that the certified scope is applicable.
4. The individual certification as Point of Origin for Palm Oil Mills and Refineries will be mandatory. This applies to all kinds of refineries (not only to refineries handling palm-based materials)
We would like to point out that individual on-site audits for all Palm Oil Mills supplying liquid waste and residue materials is already obligatory since 01 November 2022. In this regard, the individual certification will permit an easier certification process, as the concerned Points of Origin can choose Certification Bodies depending on their availabilities instead of being covered by the same Certification Body that conducts the audit of the certified Collecting Point.
5. Material deliveries to barges and vessels require storage facilities at the port that need to be covered by a mass balance and fulfill the requirements of a Dependent Collecting Point/Dependent Storage Facility. We herewith clarify that this requirement is applicable for cases in which the material needs to be transferred from one container to another at the port. The requirement does not apply to already packaged goods in e.g., ISO standardized shipping containers.
6. Non-compliant Points of Origin (PoO) for waste and residue materials will be excluded as suppliers of sustainable material for five years and cannot be covered under the respective certificate of any Collecting Point. They must be removed from the supply base immediately.
This does not apply to farms and plantations supplying agricultural residues.
Non-compliant means that the supplied material of the Point of Origin does not consist exclusively of the waste or residue material indicated in the Self-Declaration, the requirements on the signed Self-Declaration are not fulfilled, or the Point of Origin denies the access to the auditor.
ISCC will inform Certification Bodies and System Users about PoOs that were added to the list via notification email.
Please note that the FAQs will be updated continuously.
3. ISCC Documents
3.1. New ISCC PLUS Certificate Template
The newest version of the ISCC PLUS certificate template which is mandatory as of 01 July 2023 is available.
In Annex I, the column “ISCC waste process applied” is replaced by the column “Raw material category”. The specification of bio, bio-circular, circular and/or renewable-energy-derived must be stated in this column to make the material annex clearer. The voluntary information if post-industrial or post-consumer waste (only for the category circular) is used can also be stated in this column. The column for add-ons does not contain the add-on SAI Gold and the drop-down for SAI FSA does not include SAI Silver anymore, as ISCC reached Gold level equivalence. The new add-on Food Security Standard (FSS) is added. Therefore, the explanations in the footnotes of annex I are amended. Annex II can now also be used to publish the list of traders of limited risk distributors (LRD) which is voluntary.
The updated ISCC PLUS certificate template is available for Certification Bodies in the client section of the ISCC website (login required). You can also find the updated certificate template guidance document next to it.
3.2. Updated ISCC EU Certificate Template
The EU Certificate Template has been updated according to the recognition of ISCC against the SAI FSA 3.0 Gold Level Equivalence standard. Therefore, the drop-down for SAI FSA does not include SAI Silver anymore. The explanation in the footnotes of annex I are amended accordingly.
The updated ISCC EU certificate template is available for Certification Bodies in the client section of the ISCC website (login required). You can also find the updated certificate template guidance document next to it.
3.3. Adjustment in the ISCC EU PoS Template Based on User Feedback
Based on stakeholder feedback, minor changes were made to the template of the ISCC EU Proof of Sustainability (PoS) for biofuels, bioliquids and biomass fuels. The fields for information on the start of installations for producers of biofuels, bioliquids and biomass fuels as well as for the users of bioliquids and biomass fuels have been structured more clearly. The updated template (v2.6, 12 May 2023) is available in the client section of the ISCC website (login required).
4. Update on Requirements Regarding the Place of the Audit in Case of Scope Extensions
In case of any desired change of the certificate, the Certification Body can adjust the scope or materials during the validity period. The adjusted certificate has to be provided to ISCC together with the audit procedures and any other relevant documents confirming the compliance of the System User with the respective requirements (see ISCC EU 201 – System Basics).
The requirements that are in place for (re-)certification audits apply equivalently for scope extension audits. Accordingly, the option to conduct a scope extension remotely which was implemented due to the Covid 19 pandemic is withdrawn. This means that scope extensions must be conducted on-site unless specified otherwise in the ISCC system documents. Remote scope extensions will only be accepted based on the same decision-making process that applies for (re-)certification audits within the respective ISCC system.