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. Update ISCC Documents
ISCC Audit Procedures
ISCC has adjusted the ISCC audit procedures. Adjustments within the updated audit procedures include:
Adaption to the adjusted ISCC document 203 “Traceability” coming into effect on 01 January 2019
Improvements in wording, language and layout
Adjusted structure of the templates
The updated audit procedures must be used for ISCC audits from 01 January 2019 onwards. An earlier application is possible on a voluntary basis.
ISCC List of Materials
ISCC has updated the ISCC list of materials:
Table 1 “Raw materials”:
Ethanol used in the cleaning/extraction of blood plasma was added
Table 2 “Intermediate and final products”:
Co-processed oil to be used for replacement of diesel, petrol, jet fuel, and liquefied petroleum gas was added
Bio-LNG was added
The current version of the ISCC list of materials (as of 08 November 2018) is available here in the client section of the ISCC website (login required).
ISCC has recently updated the templates for the “Sustainability Declaration for Raw Materials and Intermediate Products” and for the “Proof of Sustainability”. The updates concern adaptions of the layout and additional raw materials from the ISCC EU list of materials.
Please also be informed that ISCC has recently developed a specific template for a Sustainability Declaration for Biogas and Biomethane. This document is adjusted to the specific needs of gaseous products and the development was based on feedback from ISCC system users.
All adjusted templates can be downloaded from the client section of the ISCC website (login required). The use of the templates provided by ISCC is voluntary.
2.1 GHG Emissions for Extraction and Cultivation: Field Emissions of Synthetic and Organic Fertilisers
We herewith point out, that in case of an individual calculation of GHG emissions for the extraction and cultivation of raw materials (eec) the N2O-field emissions from the application of synthetic and organic fertilisers and from crop residues being left on the field must always be included in the GHG calculation. If, for instance, palm oil mill effluent (POME) is applied on the palm plantation, the POME generates field emissions. These N2O field emissions must be covered in the GHG calculation for cultivation of palm fresh fruit bunches (FFBs).
For synthetic fertilisers other than nitrogen (e.g. P2O5, K2O, CaO) only the emission factor for fertiliser production (EF production) is relevant and must be applied in the GHG calculation. For organic fertilisers such as POME, emissions for production are not relevant and only the N2O field emissions have to be considered.
Please find further information on this in chapter 188.8.131.52 of the ISCC System Document 205 “GHG Emissions”.
2.2 Sourcing Biomass via “Local Agents” or “Country Dealers”
ISCC has received inquiries regarding the certification of first gathering points (FGPs) and the role of so-called “local agents” or “country dealers”. We herewith point out that this scenario is addressed in the ISCC System Document 201 “System Basics”:
“First gathering points are economic operators that receive or buy sustainable biomass or agricultural crop residues directly from farms or plantations. First gathering points distribute, trade or further process this raw material. First gathering points conclude contracts with the supplying farms or plantations for the delivery of biomass or agricultural crop residues. (…) A first gathering point may use the service of so-called local agents who facilitate contracts for the delivery of sustainable biomass or agricultural crop residues between farms or plantations and first gathering points. In any case, the first gathering point has to comply with all relevant requirements. If the local agents are acting on behalf of the first gathering point they are not considered first gathering points themselves and thus do not require certification.”
Traceability and access to the individual farmers delivering sustainable biomass must be ensured during the audit of the FGP. Therefore, it is required that all self-declarations from ISCC compliant farmers are available at the FGP. The contracts between FGP’s and farmers need to be audited in order to verify the amount of sustainable biomass provided by the individual farmers.
If local agents only act on behalf of a (certified) FGP and support the FGP by setting up contracts with the farmers, the local agents do not need to be considered as an FGP. In this case an individual certification of the local agent is not required. However, if the local agents act in their own name (i.e. by buying biomass from farmers, holding the self-declarations from the farmers, and selling the biomass in their own name) these local agents act as first gathering points and must become certified individually.
3. Nabisy Release in January 2019
The BLE has informed ISCC that a new version of the web application Nabisy will be released at the end of January 2019 (calendar week 4, 2019).
The main modification will be the display of the individual elements of the GHG calculation formula in case of actual GHG values. This modification will apply for all Proofs of Sustainability (PoS, German: NNw) that are newly registered into Nabisy after the modification has been implemented. This modification will also apply for all resulting “Partial Proofs of Sustainability” that are traded within Nabisy. This modification will not be provided for Proofs of Sustainability that have been merged in the past, as this is technically and economically not feasible. In agreement with industry associations, the BLE will stop the possibility to merge (Partial) Proofs of Sustainability.
The BLE points out that already existing (Partial) Proofs of Sustainability, that were registered in Nabisy prior to the release of the new version, cannot be updated.