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Certification in practice

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

A valid certificate says a company was audited. The Proof of Sustainability says that this consignment is what it claims to be. Buyers reject cargo on the second one far more often than on the first, so this page is about the document that travels with the oil.

A Proof of Sustainability, called a Sustainability Declaration in the ISCC documents, is the per-consignment document that travels with certified material. The certificate proves the company is in the system; the PoS proves this batch is. It has to reflect the product group actually delivered, carry the GHG figure for the fuel, and place the material in the right Annex IX category, because that category decides whether the buyer can count it at all.

What a document actually has to prove
  1. 1Origin of the material
  2. 2Chain of custody
  3. 3Mass balance bookkeeping
  4. 4Scheme certificate
  5. 5Claim on the invoice

A claim is only as good as the weakest box to its left.

A certificate is not a Proof of Sustainability

This is the single most common confusion we see, and it costs people weeks. A supplier sends a scan of their ISCC EU certificate and considers the certification question answered. It is not. The certificate says that an audit took place and that the company holds a scope for certain materials until a certain date. It says nothing about the parcel in front of you.

The Proof of Sustainability is issued per delivery. It is what the buyer's compliance desk books against, what an auditor asks for two years later, and what a national authority looks at. Before we take an offer to a buyer we read both, plus the specification and the CoA, and we check that they describe the same material.

  • The certificate names the certificate holder, the scope, the materials and the validity period. Check it in the public ISCC register rather than against a PDF you were sent, and check that the scope actually covers the material you are being offered.
  • The Proof of Sustainability is per consignment. It must at minimum reflect the product group of the material physically delivered, and the GHG value of the final fuel has to be stated on it.
  • They have to agree. A certificate covering used cooking oil and a declaration describing acid oil is not a paperwork detail; it is a different chain, and the buyer cannot book it.

Part A or Part B decides whether your buyer can book it

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.

Mass balance, and when your own company needs a certificate

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.

The Union Database

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.

National schemes alongside ISCC

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.

Where we come in

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.

Frequently asked questions

What exactly is a Proof of Sustainability?

It is the per-consignment document that travels with certified material, called a Sustainability Declaration in the ISCC documentation. It must reflect the product group of the material physically delivered and state the GHG value of the final fuel. The market says PoS; the scheme documents say Sustainability Declaration; they are the same thing.

What is the difference between a Proof of Sustainability and a certificate?

The certificate is about the company: it was audited, it holds a scope for certain materials, and it is valid until a date. The PoS is about the consignment: this batch, this volume, this feedstock, this GHG figure. A buyer needs both, and rejects far more often on the PoS than on the certificate.

What has to be on an ISCC EU delivery note?

At minimum it has to reflect the product group of what was physically delivered, and the GHG value of the final fuel has to be stated. The full requirements are set out in ISCC EU 203, Traceability and Chain of Custody, which is public. If a buyer has queried a declaration you hold, send it to us and we will read it against what they have to book.

Does the GHG figure have to be on the document?

Yes. The GHG value of the final fuel must be stated in the proof of sustainability. If a supplier offers certified material without a GHG figure, that is not a formality they forgot; the buyer cannot complete their side without it.

What is the biogenic percentage, and where does it come from?

For co-processed and mixed streams the question is what share of the output counts as renewable, and it follows from the mass balance rather than from a measurement on the finished product. It is set out per consignment. Ask for it in writing at offer stage, because it changes the value of the parcel and is not something you can establish afterwards.

What are the voluntary add-ons on a declaration?

ISCC offers optional add-ons that a certificate holder can be audited against and that are then reflected in the documentation. Buyers with their own reporting commitments sometimes require one. Whether a given add-on is on the declaration is a question to settle before contracting, not at loading.

Do I need to be certified to buy, or only to sell?

If you take title to certified material and pass it on as certified, you are in the chain of custody and you need to be certified, or work through a counterpart that is. This catches out European trading entities buying from a certified producer outside the EU: the production being certified does not put the trader in the chain.

Can Annex IX Part A material be sold as Part B, or the other way round?

No. The letter follows the feedstock, and the declaration has to carry the right one. They are two different products with two different chains, and if the letter is wrong the buyer's system will not accept it. Settle the category before you quote.

What does the Union Database change for me?

Every transaction of renewable fuel placed on the EU market is logged there and the entry links back to the PoS. The practical effect is that the declaration has to stand on its own, because someone downstream has to make an entry from it.

Can I hold a national scheme alongside ISCC?

It comes up most often for the Italian national scheme, and the answer depends on where your volume is going. The question worth asking first is commercial rather than technical: does the buyer you want actually require it? A second audit is real money, and it is worth knowing whether it opens a market before you commit.

My supplier's certificate is recent. Is that a problem?

Not in itself. Plenty of legitimate producers certified recently, particularly in pyrolysis oil where the material only became eligible relatively lately. What matters is that the certificate is valid in the public register today, that the scope covers the material offered, and that the declarations are consistent with it.

Can you help us get certified?

We do not certify anyone and we are not a consultancy. When certification work is genuinely needed we can introduce you to ISCC consultants and auditors we have worked with, and to laboratories for the analysis that goes with it. We do that because material we cannot document is material we cannot place.

Market news

Recent headlines from across the feedstock and renewable fuel sector. Nothing specific to this market has come through the wires lately, so this is the wider view. The links go to the publisher; we do not host or edit their reporting, and a headline here is not our endorsement of it. Scroll for more.

18 headlines, updated automatically. Last refreshed .

Sources and further reading

Primary sources for the rules and figures on this page, so you can check them yourself. Legislation is amended: always read the consolidated text on the date that matters to you.

Who to ask about Proof of Sustainability

Just ask. Sending a first certified parcel, or holding a PoS that a buyer has queried? Send the certificate and the declaration and we will read them against what the buyer has to book. You get Bart van den Brug on the other end, same working day, in English or Dutch, and across the team also in French, Portuguese, Polish, Czech and Russian.

On how we work: on the feedstocks and fuels on this site we are a broker. We never take title, we do not trade our own book, and we are paid a commission on business that concludes. Additives are the one exception: those we also buy and sell for our own account, and we say in which capacity we are acting before you commit to anything. Either way you will hear it from us when the answer is no, or when your parcel is not ready for the conversation you want to have. A market read or a second opinion on a specification costs nothing and commits you to nothing.

Happy to look at whatever you have, even if it is half an analysis and a question.

+31 6 115 83 448
bart@sustainablecommodities.eu
Sustainable Commodities 3 B.V., Lemmer, the Netherlands

Ask about Proof of Sustainability

A direct line to the desk. We answer the same working day in almost all cases, and we will tell you plainly when a cargo is not something we can place.

Prefer email? bart@sustainablecommodities.eu · +31 6 115 83 448

Last reviewed 02 September 2026. Regulatory references are given for orientation and are not legal advice: verify against the current Official Journal text before contracting.