The International Sustainability and Carbon Certification (ISCC) has issued a framework to provide 'Proof of Compliance' (PoC) for the use of low emission fuels in the aviation and maritime sectors.
The PoC is intended to address challenges arising from the unavailability of Proof of Sustainability (PoS) documentation for downstream operators, such as airlines and shipowners. These downstream operators are typically the obligated party in showcasing compliance with EU regulations such as the EU emissions trading system ETS and FuelEU Maritime. A major biofuel supplier expects that the framework could be used as soon as next month.
ISCC said that the PoC was developed in alignment with regulatory requirements and will serve to supplement the ISCC EU scheme. The ISCC has also published a guidance document, template, and audit procedures for PoC documents.
According to the guidance document, the issuance of a PoC document for a batch of certified fuel is only possible if the underlying PoS document has been surrendered to relevant competent authorities, and that a claim for the same batch of fuel further downstream is not prohibited by the relevant competent authorities. The PoC document must also include a reference to the original underlying PoS to allow for cross-referencing, as well as information on which scheme the fuel has already been counted under in which the PoS was surrendered. ISCC added that the PoC document can in principle also be used for claims in voluntary markets but recommended that involved parties examine the implications of claiming the same fuel volumes towards voluntary targets.
This comes after market participants reported regulatory uncertainty regarding the use of some marine biodiesel blends throughout the year. In the Netherlands, shipping companies which purchase marine biodiesel blends including fatty acid methyl esther (Fame) might not receive PoS for RED-certified biofuel, as suppliers further up the chain would probably have already submitted these to redeem the corresponding class of Dutch renewable tickets (HBEs). Buyers could instead receive a raw material and intermediary product delivery document, in the form of a sustainability declaration with many of the same relevant details.
