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. Introducing the ISCC HUB
ISCC HUB in a nutshell:
As we have already announced in our previous System Update: The ISCC HUB will go live between 4-8 December 2023, marking a significant milestone in our commitment to enhancing user experience and streamlining processes. This online platform will improve the management of registration and certification-related data for both, System Users and Certification Bodies (CBs).
To reiterate, both System Users and their CBs will have direct access to the ISCC HUB, enabling them to manage and modify System User data. Access is facilitated through by a single sign-on in the ISCC client section/ISCC CB section. The future integration of the ISCC HUB with the European Commission’s Union Database and the ISCC Transaction Database will establish a comprehensive one-stop-shop solution for System Users. Further details on this integration will be communicated in future updates.
As a reminder, this communication serves to draw attention to the System Update of 27 October for more comprehensive details. With regard to recent requests, there is no need for existing System Users to manually register for the HUB. The transition will occur automatically. However, please note that certificate submission has ceased, and company registration submission, along with the adjustment of contact persons, must be completed by 28 November 2023:
Benefits at a glance
Improved User-Friendliness and Process Efficiency
Our continuous efforts aim to improve user-friendliness and speed up processes. Therefore, the registration process is now better structured, with active CB involvement.
Immediate Certificate Submission and Publication on ISCC Website
Certificates can now be submitted by CBs directly in the ISCC HUB and are published immediately in the ISCC HUB and on the ISCC website, eliminating the need to wait for ISCC to publish them. This facilitates System User’s ability to verify the existence of a valid certificate of their suppliers.
Data Accuracy and Verification
The ISCC HUB uses various verification and validation measures to reduce input errors and missing data. Automatic notifications are sent to relevant parties when data is updated or changed, facilitating information dissemination and confirmation requests. It’s important to recognise that the ISCC HUB is already a significant achievement. Still, we are committed to ongoing improvements to further enhance the efficiency in the ISCC HUB itself and in between the ISCC HUB and other tools such as the APS (Audit Procedure System).
As part of our commitment to transparency and education, we are pleased to offer free ISCC HUB Introduction exclusively for CBs and staff on 29 November 2023, from 2:00 pm to 3:30 pm CET. Feel free to register here!
2. Update on the Union Database (UDB)
Completion of the process of onboarding of Economic Operators (EOs)
The process of onboarding of EOs will have to be completed by 3 January 2024. In this respect Economic Operators which after the official launch of the system on 3 January 2024 would either not be registered at all in the UDB or would not have provided all the required information to complete their registration, will not be able to start using the UDB. This status will be considered to be in breach of the legal obligations of Economic Operators in accordance with Article 28(2) of the Renewable Energy Directive (EU) 2018/2001 (RED II) “to enter in a timely manner accurate data into the Union database on the transactions made and the sustainability characteristics of the fuels subject to those transactions, including their life-cycle greenhouse gas emissions”. Article 17.1(c) of the Implementing Regulation on sustainability certification (1) further elaborates and specifies this legal obligation, which Voluntary Schemes need to pass to the Economic Operators certified by them.
Voluntary schemes are urged to take proportionate actions to remedy such situations by suspending the sustainability certificates of those economic operators who would be in the situation described above on 3 January 2024.
In a communication from 22 May 2023 ISCC informed all ISCC EU certified system users about their obligation to onboard and has provided them with a template to be filled in and sent back to us. If you have not done it yet, ISCC kindly reminds you to fill in the template and send it back to us at the latest by 11 December 2023. Please note that according to the information provided in point 3, non-responding to ISCC communication will be treated as major-non-conformity. This means that the System User will be sanctioned with the suspension of the certificate in the event of no response received or action taken within the provided timeline.
Scope of traceability of UDB regarding transactions in the supply chain of liquid fuels
The scope of the traceability system of the UDB in the supply chain of liquid fuels will start from the first gathering point/collecting point of the raw material/ biomass until the respective fuels are put on the market in the EU. This means that first gathering points and collecting points will be the first economic operators to enter consignments of raw materials in the UDB. To ensure their traceability, all the points of origin (e.g., farmers, restaurants) that are supplying a respective first gathering points/collecting point will have to be registered in the UDB.
Gaseous fuels supply chain in UDB
In order to complete the preparation of the UDB, all Economic Operators will have to be onboarded by the end of 2023. However, the launch of the application to register injection and consumption of energy units from the supply chain of gaseous fuels will only start after the technical links between UDB and respective national registries of Guarantees of Origin (GOs) will be established.
Integration/link of UDB with existing national databases
The UDB team already launched a technical process with all Member States which have expressed their interest to use the option of linking their national databases to the UDB. The objective of the UDB team is to establish the technical pre-conditions and proceed with the effective technical linking before the launch of the system in January 2024.
Public wiki page
The UDB team has created a publicly available wiki page. There you can find, among others, functional information, training materials and FAQ.
3. Non-Responding to ISCC Communication Will Be Treated as Major Non-Conformity
It will be treated as a major non-conformity if System Users do not respond to communications (such as ISCC System Updates) from ISCC although requested to do so and/or do not take a requested action (such as providing specified information) within a specified timeframe. Major non-conformities may lead to the suspension of the certificate.
The communication from ISCC with the request to respond and/or take a requested action must meet the following conditions in order to trigger a major non-conformity:
- The communication is submitted by ISCC in writing to the System User (e.g. by email)
- The System User is asked to reply and/or take necessary action within a specified period of at least 14 calendar days. For urgent matters, the time given to the System User to react shall not be shorter than three working days since the communication was issued.
- The communication states that the System User will be sanctioned with the suspension of the certificate in the event of no response received or action taken within the provided timeline.
If the first timeline is missed, a reminder in the form of a second communication will be submitted in writing to the System User by ISCC with warning of the sanction taking effect in case of further missed response or action by the System User within a final term stated in the second communication. Such term shall be set at least 14 calendar days from issuing of the second communication (or, for urgent matters, at least three working days since the second communication was issued). If the System User does not react by the second deadline, ISCC shall announce the sanction in writing to the System User with a third communication. Suspension of the certificate of the System User takes effect 48 hours after the third and final communication.
The CB will be included in the communications sent by ISCC to System Users in the context of no response triggering the suspension of the certificate. If the System User does not respond or act accordingly within 40 days from the third and final communication, the CB shall withdraw the certificate.
In this context we would like to highlight both the importance of the role of the contact person(s) for ISCC that have to be named by each System User as well as the importance of communication from ISCC, such as ISCC System Updates.
Importance of role of contact person(s) for ISCC
Along with other basic information, the System User has to provide the name and contact details of at least one member of staff who can be contacted by ISCC for all matters regarding the registration or certification. The contact person(s) will receive any official communications ISCC sends out to CBs and System Users (e.g. ISCC System Updates). The contact person(s) are responsible for internally distributing any ISCC communication to all relevant members of staff and to initiate necessary action upon request by ISCC. In case of absence of the ISCC contact person(s) at the time of issuance of the communication the System User has to ensure that any official communication from ISCC is received by other responsible personnel without delay. ISCC must be informed immediately about any changes to the contact person(s). If ISCC is not informed about any changes, ISCC assumes that the information notified to date is valid.
Importance of System Updates and other communications
By means of ISCC System Updates, ISCC communicates to the System Users and CBs any updates, adjustments and/or specifications of requirements. Any such new, adjusted or specified requirement must be considered by the System Users and CBs, where applicable. The member(s) of staff of a System User named as contact person(s) for ISCC will be automatically put on the distribution list for ISCC System Updates. Any further personnel may be added to the distribution list upon request.
4. ISCC EU and PLUS Material List
The ISCC EU and PLUS Material Lists have been updated. The newly added and revised materials are marked in bold.
Please note that it will no longer be possible to indicate the material “Bio marine fuel” under ISCC EU. All materials that could be declared as “Bio marine fuel” are already covered by the ISCC EU List of Materials. If you have any questions, please contact ISCC.
The updated Material Lists can be found in the documents section of the ISCC website.
5. New Guidance Document and Template for Sustainability Declarations (SDs) under ISCC PLUS
A separate guidance document for the use of the ISCC PLUS SDs is available following several requests for the correct method of filling in the Sustainability Declarations. The ISCC PLUS template for the SD has been updated (V3.5.2) to reflect the updated Material Lists.
The SD V3.5.2 and the Guidance document can be found in the client section of the ISCC website (login required).
If you have any questions, please do not hesitate to contact ISCC.
Your ISCC Team