ISCC (international Sustainability and Carbon Certification) has been quick to seize the moment after the latest instalment of the long running waste-based biofuels drama, which centres on fraudulently passing off virgin palm oil as a processing waste or used cooking oil, to take advantage of generous EU incentives. This crisis is at least partly of the European Commission’s own making, and they are looking to divert the blame. ISCC is an easy target, as it is by far the biggest EU approved certification scheme for sustainable biofuels, with thousands of certificate holders.
A rapidly arranged meeting in Brussels for stakeholders, including the great and good of the biofuels industry, hammered out a series of improvements to the certification of waste-based biofuels. A position paper has been drafted, with input from those present, for the upcoming Commission’s revisions to the Implementing Regulation 2022/996 designed to strengthen the framework of biofuels sustainability certification.
A wide-ranging set of changes was proposed, discussed, and voted on at the meeting. It is clear that there will be no ‘silver bullet’ to solve the problem. Several changes, focussing on high risk areas of the world, will be needed. Strengthening ISCC’s own due diligence on companies seeking certification, is an obvious first step. As are technical checks of the capabilities of processing plants. There has been an instance of a facility becoming certified for waste processing when they have not installed the necessary technology.
Secondly, the auditors who approve these fraudulent materials must be weeded out. ISCC already has its own Integrity Programme, which carries out spot checks on auditors and can withdraw operator certificates and expel auditors. But a harder-hitting approach is needed. Most of the fraud originates in China and SE Asia, so local auditors could be less diligent or even worse, implicated. A new proposal, that all CBs (certification bodies - the companies that employ the auditors) must have an office in the EU, granting authorities the right to enter and inspect their operations, would dramatically increase the level of supervision.
Thirdly, the new Union Database (UDB), to monitor flows of raw materials and processed biofuels, will be key to flagging up any suspicious new quantities of material. Its implementation must be speeded up.
But digging a bit deeper raises additional questions. What happens when a company has its ISCC certificate removed? First of all, their guilt is advertised on the ISCC website, where there is a list of withdrawn certificates. But what are the consequences of this behaviour for their customers? Well, very little at present; the Proof of Sustainability (PoS) that confirms the authenticity of a consignment of waste-based biofuel, remains valid if it was issued before withdrawal of the certificate, even though it may legitimise otherwise banned feedstocks, for instance, palm oil from deforested land. However, if these past PoSs were to be invalidated, the value of the associated biofuel would drop, with severe financial consequences for some operators. It would force companies to do much more of their own supply chain due diligence if they can’t count on an ISCC PoS. This could diminish the role of ISCC and other schemes, with operators questioning the long term worth of becoming certified.
Looking forward, as the world seeks to protect the environment from irresponsible practices, independent schemes such as ISCC, will always be needed to provide external checks on sustainability credentials of companies and raw materials. These sustainability schemes were originally designed to oversee the production of commodities from parts of the world where environmental damage, such as deforestation, and abuse of workers’ rights, are a real risk. They are now being asked to supervise wastes, residues and recycled materials.
Europe wants a more circular economy. Requiring the recycling of waste material, core to a circular economy, carries its own risks, which are just as serious as those associated with virgin materials. National authorities and sustainability schemes must adapt to these new threats, which exist wherever recycling is incentivised, be it for plastics, metals or, as in this case, biofuels. ISCC is in the vanguard of this fight against fraud, and the new measures it takes will not only be for the sake of its own reputation but also that of the circular economy.
Published: 23 June 25
