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.
Strengthened Requirements for Waste and Residue Supply Chains
Based on recent experiences and findings during Integrity Assessments, especially the denial of access to Point of Origins and negligent declaration of wastes and residues, ISCC herewith defines further requirements for the certification of waste and residue supply chains under ISCC EU (such as waste/residues from processing of animal or vegetable oils / soapstock, food waste, POME oil, brown grease/grease trap fat, sewage sludge and UCO supply chains). Recent developments further demonstrate that some ISCC regulations were not taken sufficiently into account for every audit, thus, this System Update also emphasizes and focuses on aspects that were already implemented prior to this System Update but are especially crucial in the context of waste and residues supply chains.
Preamble: Wrong declaration of material is considered a critical non-conformity and leads to the immediate withdrawal of a certificate.
The following requirements will become effective as of 01 August 2023 for initial and recertification audits conducted from this date onwards (earlier application is possible):
1. For audits (certification and surveillance audits) of all System Users that handle waste/residues from processing of animal or vegetable oils / soapstock, food waste, POME oil, brown grease/grease trap fat, sewage sludge and/or UCO the risk level must always be high.
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 through the supply chain on Sustainability Declarations and Proofs of Sustainability.
3. A Collecting Point can only be certified under ISCC if an up-to-date list of Point of Origins is available, at least one Point of Origin is listed with a valid Self-Declaration and deliveries from at least one Point of Origin are expected within the first 3 months of the validity of the certificate.
4. The certificate of Collecting Points will have to be suspended for 40 days by the CB if no material was collected within that time period. For initial audits the certificate must be suspended immediately if during the mandatory surveillance audit six months after the initial certification, it is found that no material was collected within the 6 months-period. This does not apply for agricultural waste and residue supply chains. During the 40 days, the Collecting Point must implement corrective measures, i.e. schedule the collection of the respective material immediately and provide evidence to the certification body. The Certification Body shall end the suspension period to enable the transaction. If corrective measures cannot be implemented within the 40 days period, the Certification Body must withdraw the certificate. This requirement is also applicable if the System User is certified for multiple scopes.
5. All certificates will require a material annex per scope. On the material annex(es) of certificates the Certification Body must indicate which scope handles which materials (applicable if more than one scope is covered by the certificate). The Certification Body has to add this information for every certified scope.
6. The individual certification as Point of Origin for Palm Oil Mills and Refineries that want to supply waste and residues material under ISCC will be made mandatory.
7. All 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 to be covered by an ISCC certification.
8. If it is found in an audit 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 if access to auditors is not granted by the Point of Origin, Certification Bodies and System Users will be informed by an ISCC notification via email and the Point of Origin will be listed on the ISCC website as non-compliant.Non-compliant Points of Origin cannot be covered under the respective certificate of the Collecting Point and have to be removed from the supply base immediately.
9. The Certification Bodies must review the list of non-compliant Points of Origin during each audit and check whether the System User is supplied by a non-compliant Point of Origin. If the System User is supplied by a non-compliant Point of Origin the Certification Body must include this Point of Origin to the sample irrespective of the amounts of material supplied to the System User.
Additionally, from now on the following requirements must be complied with in all initial and recertification audits. Newly established regulations listed below will, thus, also become effective from now on:
10. The Collecting Point is responsible for the traceability and correct declaration of the collected material. This includes that the Collecting Points must check the plausibility of the received amounts of material for each delivery from a Point of Origin and assess whether the collected amount is verifiable.
11. Material declarations on the Sustainability Declarations must be consistent with the ISCC material list. For cases where the legally required material description in the export documents does not match the ISCC material list, the Sustainability Declarations must not reflect the export declarations but the wording from the ISCC material list.
12. Fulfilling the traceability requirements of the material back to the Point of Origin is mandatory, meaning that access must be given to Point of Origins for any auditor of Certification Bodies or ISCC Integrity Auditors. When signing a Self-Declaration, the Point of Origin allows on-site access for auditors of Certification Bodies and ISCC Integrity Auditors. If an auditor requests access to a Point of Origin, it is the responsibility of the Collecting Point to ensure that the access is granted.
13. If access to a Point of Origin is not granted, the Certification Body and/or ISCC will impose sanctions accordingly. If access to a liquid waste and residues supplying Point of Origin at a Palm Oil Mill or Refinery is not granted, the certificate of the Collecting Point must immediately be withdrawn by the Certification Body.
14. The Certification Body must inform ISCC immediately about non-compliant Points of Origin.
15. After each audit of a Collecting Point, the Certification Bodies must submit the updated list of Points of Origin for each audited material to ISCC.
16. The list of Points of Origins must always be kept up-to-date and shall be made available to the Certification Body and/or ISCC upon request. For the following ISCC materials, specific conditions will further need to be considered:
- POME oil: The material requirements from the ISCC material list must be fulfilled. The ISCC Guidance Document for the audit of waste and residues from Palm Oil Mills must be followed.
- Sewage sludge: Point of Origins for sewage sludge can only be wastewater treatment facilities. The ISCC eligible material sewage sludge is a remainder of the wastewater treatment process.
- Brown grease / grease trap fat: Points of Origin with valid Self-Declarations must fulfil the material requirements from the ISCC material list. Material removed from the sewage system cannot be classified as brown grease / grease trap fat. It shall be checked during the audit if the listed Point of Origin generates brown grease / grease trap fat.
- UCO: Points of Origin with valid Self-Declarations must fulfill the material requirements from the ISCC material list. Municipal UCO collecting stations such as public containers must be audited on-site on a sample basis, irrespective of the amount of material collected from each collecting station.
Thresholds for different waste categories will be developed together with System Users and Member States and successively published. ISCC will implement trainings adapted for Point of Origins.