The Proof of Sustainability, and what has to be on it

The percentage on a declaration is not an opinion and it is not negotiable. It comes out of a formula set in the Directive, measured against a fixed fossil comparator that depends on what the fuel is used for.

The emissions total is built up term by term:

• E = Eec + El + Ep + Etd + Eu, minus Esca, minus Eccs, minus Eccr, in grams of CO2 equivalent per megajoule.
• Eec is extraction or cultivation of the raw material. For genuine waste and residues this is zero, which is the single largest reason waste based material carries a high saving.
• El is annualised emissions from carbon stock change due to land use change, spread over 20 years.
• Ep is processing. On a waste based chain this is usually the biggest term on the sheet.
• Etd is transport and distribution, including downstream distribution up to and including the filling station.
• Eu is emissions from the fuel in use. For bioliquids and biomass fuels the non-CO2 gases, N2O and CH4, have to be included here.
• Esca, Eccs and Eccr are subtracted: soil carbon accumulation through improved agricultural management, carbon capture and geological storage, and carbon capture and replacement.

The saving is then (EF minus EB) divided by EF, where EB is the total for your fuel and EF is the fossil comparator. Which comparator applies depends entirely on the end use, and that is where a saving gets quoted wrongly.

EF is not one number. It is set per end use, and the same cargo therefore has more than one correct saving figure.

Two practical consequences. First, the same cargo has more than one correct saving figure, because the comparator differs by end use, and a declaration will normally carry several. A buyer reading the transport line when the material is going to heat is comparing the wrong pair of numbers. Second, a saving above the threshold is not the same as a saving that will be accepted: the calculation has to hold up against the chain behind it, and the certification body is entitled to ask for the workings.

For what the thresholds are and how they interact with the Annex IX categories, see RED III quotas and caps and Annex IX feedstocks.

Annex IX of the Renewable Energy Directive splits eligible waste and residue feedstocks into Part A and Part B. That letter is not a label; it changes what the fuel is worth to the party that has to meet a target, because the two parts sit under different sub-targets and caps in the member states.

We have seen offers stall entirely on this. Two products from the same yard, two different chains, and the declaration carried the wrong letter. The buyer's system simply would not accept it. If you are not certain which part your material falls under, settle that before anyone quotes a price, not after.

Certified material moves under mass balance: the certified volume in and the certified volume out have to reconcile over a defined period, per site. That is the mechanism, and it is also the thing an audit tests hardest.

The consequence that catches traders out is about their own position in the chain. If production sits outside the EU and the commercial entity sits inside it, that European entity has to be in the chain of custody itself. Either it holds its own certificate as a trader, or it works through a counterpart that is certified. There is no third option where the material is certified but the seller is not part of the chain.

Every transaction of renewable fuel placed on the EU market is logged in the Union Database, and the entry links back to the Proof of Sustainability. In practice this means the document is no longer a piece of paper between two parties: it is the thing the entry is built on. Declarations that were tolerated when they were vague are now a problem for the party that has to make the entry.

ISCC is the scheme most of this trade runs on, but it is not the only one, and some markets ask for their own. Italy's national scheme comes up regularly in our conversations, and it is a fair question whether it can be held alongside ISCC. Poland asks about waste codes before anything else. Whether a second scheme is worth the audit depends entirely on where the volume is going, which is a commercial question rather than a certification one, and it is worth answering before you commit to the audit.

We are a broker, not a certification body and not a consultancy, and we do not issue or verify documents. What we do is read them before they reach a buyer, and say plainly when something will not clear.

When the answer is that certification work is genuinely needed, we can put you in touch with ISCC consultants and auditors we have worked with, and with laboratories for the analysis that usually comes with it. That introduction is not a service we sell; it exists because a supplier who cannot produce a clean PoS is a supplier we cannot place.