The management of the ISCC system recently discretely informed about a new clause that is, according to us, clearly in contradiction with the RED spirit. In a newsletter sent this week, it says “delivery notes or proofs of sustainability related to waste, residue and/or material eligible for double- or quadruple-counting which are issued under other certification systems shall in the future not be accepted by an ISCC certified unit anymore.
» The direct implication of it is a segregation of DC supply chains; given the ultra dominance of the scheme internationally, it basically forces all the participants (from the collectors of UCO and tallow to the suppliers of UCOME and TME) to get the ISCC certification. ISCC said « this procedure has become necessary, because a sufficient control and traceability could otherwise no longer be guaranteed for points of waste and residue origination and collectors/first gathering points.
» According to us, that position clearly denigrates other schemes’ work and raises serious questions regarding RED compliance. Any Member State is forced by the RED to accept all voluntary schemes recognized by the Commission so there is little evidence that the ISCC latest move is even legal. The requirement is subject to a transitional period until August 31st 2013.
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