Dear Ladies and Gentlemen,
We herewith would like to inform you about the communication sent by the European Commission (EC) to the Voluntary Schemes with a guidance on the practical aspects to ensure continuity in the certification process in the transition period from RED I to RED II.
The date of the transposition of the RED II (Renewable Energy Directive (EU) 2018/2001) is 30th June 2021. The EC has communicated to the Voluntary Schemes that “As of 1st of July 2021 RED II rules apply, therefore certificates to be granted to biofuels, bio liquids and biomass fuels have to apply REDII requirements.” This means that as of 01st July 2021 all ISCC EU audits (certification and surveillance audits) of economic operators have to be conducted according to the requirements of the RED II.
ISCC EU certificates that have been issued prior to 1st July 2021 (i.e. verifying compliance of the economic operator with the requirements of the RED I) remain valid until their respective expiry date. It is not required to conduct immediate re-certification audits of the economic operators which hold a valid ISCC EU certificate on 1st July 2021. However, the EC requires that of 1st July 2021 all certified economic operators have to comply with the sustainability and greenhouse gas saving criteria requirements of the RED II.
ISCC has published revised ISCC EU System Documents here on its website.
From 1 July 2021, System Users are obliged to comply with the RED II requirements as specified in the revised ISCC EU System Documents.”. These versions of the documents have been submitted to the European Commission in the framework of the recognition process of ISCC EU under the RED II. The recognition of voluntary schemes in the framework of the RED II is pending. Please also note that the documents may be subject to change depending on further legislation and further requirements of the European Commission. At the beginning of each document, you find a comprehensive summary of changes compared to the previous version.
ISCC will shortly provide a short document that specifically highlights the RED II requirements that have to be applied by the economic operators as from 1st July 2021.
With regards to sustainable material that is in the supply chain on 1st July 2021 the EC provided the following specification*: “At the beginning of the operation of the scheme, as a one-time measure, all raw materials and fuels in stock that have been certified as sustainable under a voluntary or national scheme recognised by the Commission under Directive 2009/28/EC may be considered as sustainable and providing accurate information about the greenhouse gas emissions under recast Renewable Energy Directive (Directive (EU) 2018/2001).”
This also means, that for all outgoing deliveries which are physically dispatched on or after 1st July 2021 the sustainability declarations have to reflect the RED II requirements. ISCC will shortly provide the update templates for ISCC EU sustainability declarations and proofs of sustainability (PoS).
Further information for certification bodies and auditors:
As of 01st July 2021 all audits under ISCC EU (certification and surveillance audits) have to be conducted in accordance with the RED II requirements. This means that from this date auditors must verify that economic operators have applied the RED II requirements from 1st July 2021.
The new requirements will be incorporated into APS in due time. In the meantime, ISCC will shortly provide a checklist with the RED II requirements that must be used by the auditor during the audit in addition to APS for all audits conducted as from 1st July 2021. This checklist has to be submitted to ISCC together with the certification documents.
ISCC will also shortly provide an adjusted certificate template (with reference to the RED II) in the CB section of the ISCC website.
We respectfully request that you refrain from sending us enquiries on this topic for the time being as we are working intensively on pragmatic solutions for mitigating this unpleasant situation. Please be assured that we will inform you about any updates as soon as possible.
*Note: This specification is included in the Assessment Protocol Template provided by the EC. The Assessment Protocol Template contains the requirements that have to be fulfilled by Voluntary Schemes to become recognised under the RED II. This document is publicly available here on the EC website.