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 EU: Updated ISCC EU System Documents
2. ISCC PLUS: Not Affected by the Revised ISCC EU 203 Traceability and Chain of Custody System Document
1. ISCC EU: Updated ISCC EU System Documents
In a communication dated 3rd January 2024 the European Commission has officially approved the updated ISCC EU System Documents that were revised to reflect the legal requirements of Implementing Regulation (EU) 2022/996 on rules to verify sustainability and greenhouse gas emission saving criteria and low indirect land-use change-risk criteria (Implementing Regulation).
With the update of the documents, we also incorporated relevant requirements from previous ISCC system updates since the last update of the documents in July 2021 and from the ISCC Terms of Use and Terms of Certification (further information on this to follow shortly). At the beginning of each document, you find a detailed summary of changes. For a high-level overview we have prepared an overview of changes.
ISCC has published the revised ISCC EU System Documents and the overview of changes on the ISCC website.
Date of Application
The EC requires that with immediate effect all ISCC EU certified economic operators have to comply with the requirements of the Implementing Regulation.
ISCC EU certificates that have been issued prior to today (i.e. verifying compliance of the economic operator with the requirements based on the old system documents) remain valid until their respective expiry date. It is not required to conduct immediate re-certification audits of the economic operators which currently hold a valid ISCC EU certificate.
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 (EU) 2018/2001 (RED II) until the date of this communication may be considered as sustainable and providing accurate information about the greenhouse gas emissions under the updated requirements reflecting the Implementing Regulation.
Updated audit Procedures/APS
With immediate effect, all ISCC EU audits (certification and surveillance audits) will have to be conducted in accordance with the updated requirements. The same applies to scope extensions.
The new requirements will be incorporated into APS. We expect to provide the updated APS in February 2024).
For audits that are taking place until the new APS is in place, ISCC has prepared “gap” audit procedures that address the requirements of the Implementing Regulation. The gap audit procedures must be used for ISCC EU audits with immediate effect. These audit procedures must be used in addition to the currently applicable audit procedures/APS version.
The gap audit procedures can be found here (https://www.iscc-system.org/certification/iscc-documents/iscc-audit-procedures/) on the ISCC website.
For certification bodies and auditors word versions of the gap audit procedures are available in the CB section of the ISCC website (login required).
Note for Certification Bodies/ISCC HUB: The gap audit procedures have to be submitted as part of the certificate submission or submission of certificate modification in the ISCC HUB. They have to be uploaded in the section “Sample Audit Reports – Additional Files” for the main audit and each sample/additional audit where required. For surveillance audits the gap audit procedures have to be provided via email to certificate@iscc-system.org until the updated APS is available.
Updated ISCC EU Templates for Sustainability Declarations and Proofs of Sustainability
ISCC has updated the ISCC EU templates of the Sustainability Declarations (SDs) and Proofs of Sustainability (POS) reflecting the new requirements. The templates (v3.0) are available in the system user section of the ISCC website (login required).
Additional Information for the Scopes Collecting Point and Central Office for Points of Origin for Waste and Residues
If certified collecting points and central offices for points of origin of waste and residues are using external storage facilities and/or dependent collecting points (only possible under the scope collecting point), the dependent collecting points and external storage facilities have to be covered by the certification of the main party. The European Commission has confirmed only recently that according to the rules set out in the Implementing Regulation the sampling of dependent collecting points and external storage facilities used by collecting points and central offices is no longer possible.
We are aware of the impact of this requirement on the audit time and process for affected collecting points and central offices. In case of recertification audits that are scheduled to take place in the first three months of 2024 and where it is not possible to schedule the additional audits and still allow a continuous certification of the system user, the additional audits must be conducted as quickly as possible but no later than two months after the date of issuance of the new certificate. If during the additional audits non-conformities (e.g. with mass balances) are detected, the required measures and sanctions must be applied (see ISCC EU Document 102 “Governance”, v4.1). In case of non-conformities related to traceability and mass balance, the auditor must quantify the amounts that lead to the non-conformity.
2. ISCC PLUS: Not Affected by the Revised ISCC EU 203 Traceability and Chain of Custody System Document
ISCC PLUS standard is not bounded by Renewable Energy Directive II due to the covered markets. Nevertheless, ISCC PLUS refers to certain ISCC EU system documents, which are explicitly mentioned in the ISCC PLUS System Document.
ISCC PLUS traceability and chain of custody requirements are not affected by the revised ISCC EU 203 Traceability and Chain of Custody System Document v4.1.
During the transition period from ISCC PLUS v3.3 to v3.4.1, ISCC EU 203 v4.0 shall be used.
After the transition period, the relevant content from the ISCC EU 203 v4.0 will be incorporated into the ISCC PLUS System Document. This incorporation will maintain the context and requirements of ISCC EU 203 v4.0. The incorporated ISCC PLUS System Document (ISCC PLUS v3.4.2) will be published on 06 March 2024, end of the transition period.
For the other ISCC EU System Documents which are referred to in the ISCC PLUS System Document, the latest version shall be used.
We wish you all the best for the new year.
Your ISCC Team