17/11/2022

EU ETS Monitoring and Reporting – CF Training event

Training Event on Biomass No. 1

[email protected] 20 October 2022

Set-up of the training

• Topics:
• EU ETS monitoring & reporting of emissions from biomass – relation to RED II
requirements
• Target audience:
• CAs and verification bodies – dealing with installations
(aviation will be discussed in next training)
• As the topic is relatively new, all are welcome, from newcomers to experienced staff
• Objectives
• To enable you to check monitoring plans (MPs) and annual emission reports (AERs) of
operators using biomass

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Agenda 20th October 2022

# Time Session
1. 10:00 – 10:15 Opening, welcome and introduction (DG CLIMA)
2. 10:15 – 10:45 Overview MRR requirements for biomass (RED II criteria)
10:45 – 11:15 Q & A and Discussion
3. 11:15 – 11:30 Coffee break
RED II - Certification systems - requirements, recognition of national and
4. 11:30 – 12:00
voluntary schemes
12:00 – 12:15 Q&A
5. 12:15 – 13:30 Lunch break
6. 13:30 – 14:30 MS case studies
● Checking processes and procedures
● Common challenges
● Best practices
7. 14:30 – 14:40 Coffee break
8. 14:40 – 15:25 Certification systems in practice
● From viewpoint of certification systems
● From auditor point of view
15:25 – 15:40 Q&A
9. 15:40 – 16:00 Wrap-up and close of the meeting (DG CLIMA)
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Agenda 27th October2022

# Time Session
1. 10:00 – 10:15 Opening, welcome and introduction (DG CLIMA)
2. 10:15 – 10:30 Biogas in grids - Requirements
10:30 – 11:00 Example of a biogas registry and ERGaR
11:00 – 11:15 Q&A
3. 11:15 – 11:25 Coffee break
4. 11:25 – 11:40 Other Biomass issues: Determining the biomass fraction, CEMS, etc.
11:40 – 11:50 Q&A
5. 11:50 – 12:15 Biofuels for Aviation: Requirements
12:15 – 12:30 Q&A
6. 12:30 – 14:00 Lunch break
7. 14:00 – 14:25 The role of the verifier in assessing biomass requirements - main requirements
14:25 – 14:40 Q&A
8. 14:40 – 15:00 Verifier’s checks on compliance with RED II criteria
15:00 – 15:15 Q&A
9. 15:15 – 15:25 Coffee break
10. 15:25 – 15:40 Verifier’s checks on compliance with RED II criteria
15:40 – 15:50 Q&A
11. 15:50 – 16:00 Wrap-up and close of the meeting (DG CLIMA)
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Mentimeter
• What is your role in the EU ETS?
• Your level of experience with EU ETS?

Overview of MRR requirements

for biomass

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Guidance document 3
Guidance document 3 – “Biomass issues in the EU
ETS” has been published:
https://climate.ec.europa.eu/system/files/2022-
10/gd3_biomass_issues_en.pdf

DG CLIMA’s MRVA website:

https://climate.ec.europa.eu/eu-action/eu-emissions-
trading-system-eu-ets/monitoring-reporting-and-
verification-eu-ets-emissions_en

MRR and RED II

• MRR 2018 (with 2020 and 2022 amendments) contains requirement to apply
RED II criteria for biomass/biofuels
• MRR (Commission Implementing Regulation (EU) 2018/2066 of 19
December 2018 on the monitoring and reporting of greenhouse gas
emissions pursuant to Directive 2003/87/EC of the European Parliament and
of the Council and amending Commission Regulation (EU) No 601/2012):
Consolidated version: http://data.europa.eu/eli/reg_impl/2018/2066/2022-08-
28
• RED II (Directive (EU) 2018/2001 of the European Parliament and of the
Council of 11 December 2018 on the promotion of the use of energy from
renewable sources): http://data.europa.eu/eli/dir/2018/2001/2022-06-07
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Monitoring Reporting Regulation

• Article 38 “Biomass source streams” – Paragraph 5:
• Biomass emissions from combustion can be zero rated if:
• Sustainability criteria are fulfilled  Article 29 (2) to (7) of Directive (EU) 2018/2001
(RED II),
AND
• GHG saving criteria are fulfilled  Article 29 (10) of Directive (EU) 2018/2001 (RED II)
• Biofuels, bioliquids and biomass fuels produced from waste and residues are
required to fulfil only GHG saving criteria, not the sustainability criteria
• However, residues from agricultural, aquaculture, fisheries and forestry have to fulfil both,
sustainability and GHG saving criteria

Definitions I
• Article 3 of the MRR copies the biomass-related definitions from the RED II as follows:

• ‘biomass’ means the biodegradable fraction of products, waste and residues from biological
origin from agriculture, including vegetal and animal substances, from forestry and related
industries, including fisheries and aquaculture, as well as the biodegradable fraction of waste,
including industrial and municipal waste.

• ‘bioliquids’ means liquid fuel for energy purposes other than for transport, including
electricity and heating and cooling, produced from biomass;

• ‘biofuels’ means liquid fuels for transport produced from biomass;

• ‘biomass fuels’ means gaseous and solid fuels produced from biomass;

• ‘biogas’ means gaseous fuels produced from biomass;

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Definitions II
• ‘waste’ means waste as defined in point (1) of Article 3 of Directive
2008/98/EC [Waste Framework Directive], excluding substances that have
been intentionally modified or contaminated in order to meet this definition;
• ‘residue’ means a substance that is not the end product(s) that a production
process directly seeks to produce; it is not a primary aim of the production
process and the process has not been deliberately modified to produce it;
• ‘agricultural, aquaculture, fisheries and forestry residues’ means
residues that are directly generated by agriculture, aquaculture, fisheries and
forestry and that do not include residues from related industries or
processing;

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Which parts of RED II apply?

Change to
RED I

• Sustainability and GHG savings criteria are relevant not only for liquid, but
also for solid and gaseous biomass Art. 29 RED II

• Verification of compliance with the sustainability and greenhouse gas

emissions saving criteria Art. 30 RED II

• Calculation of the greenhouse gas impact of biofuels, bioliquids and biomass

fuels Art. 31 RED II

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“Land-related” sustainability criteria (1)

• Article 29 Paragraph 2 to 7
• (2) Operators or national authorities [must] have monitoring or management plans in
place in order to address the impacts on soil quality and soil carbon (not for forest
biomass)

• (3) excludes raw material obtained from land with a high biodiversity value, namely land
that had a specified status in or after January 2008, whether or not the land continues to
have that status:
a) primary forest and similar

b) highly biodiverse forest and similar

c) areas that are nature protected

d) highly biodiverse grassland (details in an implementing act).

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“Land-related” sustainability criteria (2)

• Article 29 Paragraph 2 to 7
• (4) prevents the use of land which was converted from land with high carbon stocks,
namely land that had a specified status in or after January 2008 and no longer has that
status, in particular wetland and continuously forested areas.

• (5) excludes biomass from former peatland, except if evidence is provided that no
drainage of previously undrained soil is involved.

• (6) and (7) regulate forest biomass: It must meet certain criteria to minimise the risk of
using forest biomass derived from unsustainable production and must meet specified
land-use, land-use change and forestry (LULUCF) criteria. Details are given in an
implementing act.

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GHG savings criteria

• For biofuels, biogas consumed in the transport sector and bioliquids, savings must be
• at least 50% if produced in installations in operation before 5 October 2015,

• at least 60% for installations starting operation until 31 December 2020,

• at least 65% for installations starting operation from 1 January 2021.

• For biomass fuels (i.e. solid and gaseous biomass) consumed in EU ETS installations, GHG
savings must be
• at least 70% in installations starting operation from 1 January 2021 until 31 December 2025,

• 80% for installations starting operation from 1 January 2026.

• Savings relate to life cycle emissions compared vs. a given fossil comparator.

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Alignment of EU ETS and RED II

• The applicable RED II criteria have to be met in order to apply an emission
factor of zero to biomass.
Art. 38 (5) MRR
Criteria not met  treat material like a fossil fuel
• Article 38(5) is invoked by the following articles of the MRR:
• Article 18: Unreasonable costs
• Article 19: Categorisation of installations, source streams and emission sources
• Article 38: Biomass source streams / determination of biomass emission factor
• Article 43: Determination of emissions by CEMS
• Article 47: Installations with low emissions
• Article 54: Specific provisions for biofuels for aircraft operators

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Alignment of EU ETS and RED II

• MRR Article 38(5) has to be applied from 1st January 2022
• Article 38(6) : “… Member States, or competent authorities as appropriate,
may consider as fulfilled the sustainability and greenhouse gas emissions
saving criteria … for biofuels, bioliquids and biomass fuels used for
combustion from 1 January 2022 to 31 December 2022”

In most Member States, RED II criteria have to be applied by operators only

from 1 January 2023 (as to be reported in 2024).

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Source streams
• Combustion / source streams used as fuel:
• Pure fossil – no RED II criteria apply
• Pure biomass
• Emissions zero rated, if compliant with RED II criteria, or if no RED II criteria apply
• Otherwise: treated like fossil fuels (EFfinal = EFpreliminary)
• Mixed fuels: Consist of at least 2 of the following:
• Fossil fraction
• Biomass compliant with applicable RED II criteria
• Biomass not compliant with applicable RED II criteria
These three fractions are to be reported separately in the annual emissions report
• Process materials, no energy purpose – RED II criteria do not apply

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RED II: Which criteria apply?

Start for Need to
biomass Mixed analyse fossil /
Is X a mixed material
source stream or only biomass? biomass
X 1 fraction
Biomass

Is X used for No
energy purpose?
2
Yes

Yes
Is X Solid Municipal
Waste?
3
No

Yes Agricultural or
forestry biomass? Assume EF = 0
19 4 For the
biomass
fraction
No

19

Yes
No

Assess sustainability
criteria
5 Evidence under national or
voluntary scheme available?
If no, make own assessment

Assessed Yes Solid or gaseous Yes

Criteria complied (biomass fuel)?
6 with? 7

No Liquid
No
Installation started
after 2020?
8

Yes

Assess GHG savings

9 Evidence under national or

voluntary scheme available?
If no, make own assessment

Treat as fossil Assume EF = 0

No GHG saving Yes
fuel (use For the
20 criteria met?
preliminary biomass
EF) 10 fraction

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RED II: Which criteria apply? (3)

• Step 1: Source stream consists exclusively of biomass, or is it mixed with a
fossil fraction? Possibility to apply an emission factor of zero applies only to
the biomass fraction of the source stream.
Biomass part may have to be split in RED II compliant and non-compliant
parts.
• Step 2: Is the source stream used for energy purposes? If yes, the following
steps are needed. (No: assume EF=0)
• Step 3: If the source stream is municipal solid waste, no further criteria
need to be taken into account. The biomass fraction may be zero-rated.

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RED II: Which criteria apply? (4)

• Step 4: Determine if the source stream is any type of forest or agricultural
biomass, or “(produced from) residues from agriculture, aquaculture,
fisheries or forestry”, as for such source streams the “land-related”
sustainability criteria (Article 29(2) to (7) of RED II) apply.
• For other residues or waste (including all kinds of industrial wastes, if
containing biomass), only GHG savings criteria need to be complied with.
• For biomass stemming from animals, aquaculture and fisheries, Article
29 of the RED II does not list specific land-related sustainability criteria.
Operators will have to determine only GHG savings based in the
calculation methodologies outlined in Annex V and VI of the RED II
(therefore go to step 7)
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RED II: Which criteria apply? (5)

• Step 5: Depending on step 4, the (land-related) sustainability criteria for
the production of biofuels, bioliquids or biomass fuel are to be assessed.
The operator can rely on the certification of the used material/fuel under a
national system or an (international) voluntary scheme recognised by the
Commission or the installation’s (or aircraft operator’s) Member State.
If no proof of sustainability under a certification scheme is available, the
operator would have to perform the assessment of the relevant criteria itself,
and get the verifier’s confirmation.
• Step 6: If the previous step shows that relevant sustainability criteria are
not complied with, then the operator has to treat the material as if it were
fossil (preliminary emission factor becomes the emission factor)

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RED II: Which criteria apply? (6)

• Step 7: If the source stream is liquid, the assessment of GHG savings is
mandatory. Go to step 9.
• Step 8: As the additional requirement for “biomass fuels”, i.e. solid or gaseous
biomass fuels, applies only to installations starting operation from 1 January
2021, older installations do not have to carry out further assessment.
• Step 9: Required GHG savings according to Article 29(10) of the RED II
have to be calculated in accordance with Article 31(1) of the RED II.
• If the GHG savings are above the applicable threshold, the biomass can
be zero-rated, otherwise it has to be treated as if it were fossil.

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Beekast - examples
• Please follow link given in chat and answer the multiple-choice questions:
• Which RED II criteria shall apply in the following cases:
• Limbs & branches (collected in the forest) – the installation started after 2020

• Bark (collected in the saw mill) – the installation started before 2020

• An installation uses solid biomass (first time in 2019). In 2023 a new boiler starts
operating using a bioliquid. Which criteria are relevant for the bioliquid?

• An installation changes from coal to wood pellets in 2023. Which criteria are relevant for
the pellets?

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RED II criteria: Demonstrate compliance

• Options:
• National systems

• Voluntary national or international schemes that the MS accepts

• By providing all relevant evidence and GHG calculations themselves,

having the information appropriately audited (if accepted by MS)

For zero-rating biomass emissions under the EU ETS MRV rules,

the burden of proof concerning a biofuel, bioliquid or biomass fuel
meeting the applicable sustainability and/or GHG savings criteria
26 remains with the EU ETS operator or aircraft operator!

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National systems I
• Currently partly still under development
• No complete overview available of Member States’ national systems on
providing evidence of biomass sustainability and GHG savings available.
Operators and aircraft operators should obtain information on national
systems from the relevant competent authority
 See examples in MS presentations in the afternoon
• The RED II does not explicitly require a Member State to publish dedicated
information. However, it is considered best practice to provide transparent
information to operators.

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National systems II Art. 30 (6) RED II

• Possibility to notify a national scheme to the Commission for recognition. The

relevant information will be published on the Commission website, and all
other Member States are required to accept the resulting certificates. (Similar
to the case of voluntary international schemes recognised by the
Commission)

However, the use of international voluntary systems may be desirable in

many cases where the biofuel, bioliquid or biomass fuel is not used in the
Member State where it is produced!

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Voluntary schemes I
• Biofuels, bioliquids or biomass fuels certified under a scheme recognized by
the Commission have to be accepted as fulfilling the RED II criteria in all
Member States.
• Regarding schemes not (yet) recognised by the Commission, Member States
may accept those schemes, if they come to their own conclusion that the
scheme ensures compliance of the biomass with RED II criteria.
• Member States may have specific provisions (e.g. allowing only schemes
recognised by the Commission)
• Operators have to check with their competent authority or national legislation
how to provide evidence that the biomass used complies with the RED II
criteria (exception: using schemes recognised by the Commission)
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Voluntary schemes II
• Proof of sustainability (=declaration of compliance with the scheme) issued by an economic
operator certified under a recognised voluntary scheme means that the emission factor can
be zero-rated in the EU ETS.
• Limitations:
• Voluntary scheme may be approved only for some fuel types, some of the required criteria, or only
regarding some steps of the value chain
• GHG savings criterion depends on transport distance  required for each site where the biomass
is used
• Some sustainability schemes cover a wider scope  use only certificates which explicitly refer to
those “EU RED II compliant versions” of the voluntary schemes
• Some schemes are recognised with limited geographical scope
• The Commission’s recognitions of voluntary schemes are usually valid for five years

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Voluntary schemes III

• Details on all voluntary schemes recognised by the Commission can be
found here: https://energy.ec.europa.eu/topics/renewable-
energy/bioenergy/voluntary-schemes_en

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How do RED II certification schemes work? (1)

RED II
MS
Low-ILUC criteria
Art. 26(2)
Basis for Supervises
approval Certification
Forestry biomass Logo
criteria Art. 29(8) scheme
Verification rules
Art. 30(8) Scheme Certification
rules scheme operator

NAB
Trains,
Recognises, accepts, Accredits
supervises supervises

European Commission
Certification bodies
(Auditors)
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How do RED II certification schemes work? (2)

Provides the authority
Certification Certification bodies
scheme Logo (Auditors)
Issues
certification Carries out
Scheme Certification
audits
rules scheme operator

Economic operator
Same person?
EU ETS installation’s
Issues Proof of operator
sustainability to user

Biomass Use for EU ETS

Emissions report

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How do RED II certification schemes work? (3)

Economic operator

Issues Proof of
Mass
sustainability to user
balance

Biomass Points of Origin

(Farms / Plantations)
First gathering points
(Collection points)
Certificate covers Processing unit(s)
one or more of
these steps
Transport

Storage / Traders
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How do RED II certification schemes work? (4)

• Certificate

• Certifies that an economic operator complies with the rules of the certification scheme

• Proof of Sustainability (PoS):

• Issued by the economic operator for confirming that a certain consignment of
biomass material, biofuel, biogas or biomass fuel fulfils the sustainability and GHG
savings criteria

EU ETS operators needs the “proof of sustainability” for

each of the consignments (batches) of biomass used so
that emissions from biomass can be zero-rated in the
annual emissions report.
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How do RED II certification schemes work? (5)

• Step 1: Certification scheme operators set up their certification scheme’s
rules. Rules have to comply with Implementing Regulation (EU) 2022/996
(pursuant to Article 30(8) of the RED II) and must be published by the
certification scheme.
• Step 2: Commission checks the scheme
• Step 3: Commission recognised certification scheme  accepted in all
Member States (valid for a maximum of five years)
• Also all other certification schemes recognized by the Commission must
accept PoS from recognized schemes (e.g. for parts of the value chain
already certified before)
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How do RED II certification schemes work? (6)

More information about ETS
• Certification bodies (auditors)
verification in relation to biomass:
• Accredited by NAB and supervised by MS Training event on 27 October!

• Not necessarily EU ETS verifiers, but results of RED II audits should be made available
to EU ETS verifier.

• Issues certification to economic operators and carries out audits regarding RED II criteria

• Economic operator
• Certifies (steps of) the value chain of biomass  certifies only for these operations, and
not necessarily the whole value chain (mass balance)

• Issues proof of sustainability to user (used e.g. for EU ETS emission reporting)
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Example

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Example
Under a certification scheme
Primary waste collector 1
EU ETS Installation boundaries

Waste supplier 1
Waste collector 1
Primary waste collector 2 
Primary waste collector 3


Waste collector 2 
Primary waste collector 4 MI 1 Electricity
Industrial
waste CHP
Primary waste collector 5 Heat

Waste supplier 2
Waste collector 3
Primary waste collector 6 
Primary waste collector 7

Primary waste collector 8 

Waste collector 4

Operator‘s own assessment

39
… indicates lack of information flow (claimed commercial confidentiality)

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Example (continued)
• EU ETS installation is using industrial wastes with a biomass fraction in its
combined heat and power (CHP) plant
• The installation has started using biomass after 1 January 2021
 GHG savings criteria apply
• Wastes consumed by the installation are coming from 2 different waste
suppliers. Each supplier receives the wastes from 2 waste different collection
centers. Those, in turn, mix wastes from 2 different primary collection waste
centers.
• The operator of the EU ETS installation doesn’t know who are the primary
waste collection centers.
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Example – Questions
• Q1: Which RED II criteria apply?
• Q2: What evidence should the operator of the EU ETS installation provide so
that the biomass fraction of the source stream “industrial waste” could be zero
rated when using a voluntary scheme?
• Q3: What evidence should the operator of the EU ETS installation provide so
that the biomass fraction of the source stream “industrial waste” could be zero
rated if the operator does not use any voluntary scheme (self assessment)?
• Q4: How does GHG savings calculation work?

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Answer Q1: Which RED II criteria apply?

• Industrial waste = no agricultural or forest material
 No sustainability criteria
• Solid, started after 2021 (but before 2026)
 GHG savings >70% required
• Value chain starts at first collection point = primary
waste collectors. Life cycle emissions before that point
are zero
• Mass balance is required for tracking the biomass
fractions in total material mix

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Answer Q2
• Q2: What evidence should the operator of the EU ETS installation provide so that the
biomass fraction of the source stream “industrial waste” could be zero rated when using a
voluntary scheme?
• A: Certifier needs to assess mostly information not received from EU ETS operator, but from
the waste collectors – therefore the issue of confidentiality might be avoided):
• Is it really industrial waste, or are agricultural / forest residues added at some point? Are wastes not
intentionally contaminated to become waste?
• Is the mass balance along the value chain (from one collector to the next) complete and
consistent?
• Are there any processing steps involved which lead to GHG emissions?
• What are the modes of transport and distances involved between the waste collectors and the EU
ETS installation?

43 • Using the above information, GHG savings can be checked (see Q4)

43

Answer Q3
• Q3: What evidence should the operator of the EU ETS installation provide so that the
biomass fraction of the source stream “industrial waste” could be zero rated if the operator
does not use any voluntary scheme (self assessment)?

• A: The operator must attempt to gather the same information as listed under Q2 (previous
slide).
• However, if the waste collectors insist that some required information is not available due to
confidentiality, then the operator cannot provide evidence that the RED II criteria are
complied with.  The related fraction of waste (and if the mass balance is incomplete,
probably the whole amount of waste) must be considered as fossil.
• Note: Such situation is unlikely, as there is mutual interest of waste collectors (need to
dispose of the waste, i.e. want the EU ETS operator to take it) and operator, who wants to
zero-rate the biomass emissions, as otherwise conventional fuels might be the better option.
Confidentiality can usually be agreed in delivery contracts etc.
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Answers Q2 + Q3 Assume that auditor

Under a certification scheme can assess this information

Primary waste collector 1

EU ETS Installation boundaries

Waste supplier 1
Waste collector 1
Primary waste collector 2 
Primary waste collector 3


Waste collector 2 
Primary waste collector 4 MI 1 Electricity
Industrial
waste CHP
Primary waste collector 5 Heat

Waste supplier 2
Waste collector 3
Primary waste collector 6 
Primary waste collector 7

Primary waste collector 8 

Waste collector 4

Operator‘s own assessment

45
… indicates lack of information flow (claimed commercial confidentiality)
Zero-rating possible Assume fossil

45

Answer Q4: How does GHG savings calculation

work? – Step 1

 
• E = eec + el + ep + etd + eu – esca – eccs – eccr   
eec = emissions from the extraction or cultivation of raw materials;
el = annualised emissions from carbon stock changes caused by land-use change;
ep = emissions from processing; [assumed not applicable in example]
etd = emissions from transport and distribution;
eu = emissions from the fuel in use;
esca = emission savings from soil carbon accumulation via improved agricultural
management;
eccs = emission savings from CO2 capture and geological storage;
eccr = emission savings from CO2 capture and replacement.

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Answer Q4: How does GHG savings calculation

work? – Step 2
• E = etd + eu
• etd = emissions from transport and distribution: shall include emissions from
the transport of raw and semi-finished materials and from the storage and
distribution of finished materials  In this case all transports from waste
collectors to the installation, starting from the primary waste collectors
• eu = emissions from the fuel in use; Here the total biomass material’s CO2
emissions are set to zero, but emissions from N2O and CH4 (default values in
the RED II) are then added

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Answer Q4: How does GHG savings calculation

work? – Step 3
• Split E = etd + eu into parts for electricity and heat. Use Formula from RED II
section B of Annex VI, point 1(d)
• Compare resulting emissions per MJ separately for heat and electricity
against the applicable fossil comparators:
• SAVING = (ECF – ECB) / ECF
• ECB= total emissions from the biomass fuel;
• ECF = total emissions from the fossil fuel comparator
• Take into account the generation efficiency η for heating, cooling or electricity: EC = E / η
Purpose Value of the fossil fuel comparator

Production of electricity: ECF(el) 183 g CO2eq/MJ

Production of useful heat, and heating

48 80 g CO2eq/MJ
and/or cooling: ECF(h&c)

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Thank you for your attention

Consultant core team contacts:

[email protected] (lead on biomass topics)
[email protected] (project lead)
[email protected]
[email protected]

Commission contact:
© European Union 2021 [email protected]

Unless otherwise noted the reuse of this presentation is authorised under the CC BY 4.0 license. For any use or reproduction of elements that are
49owned by the EU, permission may need to be sought directly from the respective right holders.
not

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RED II – Certification systems:

Requirements, recognition of
national and voluntary schemes

Galin GENTCHEV, European Commission, DG ENER,

Unit C2 Decarbonisation and Sustainability of Energy Sources
1

EC recognised national and voluntary

certification schemes (VSs)
• EC-recognised VSs are the main compliance mechanism under REDII;
• National certification schemes can be used by MSs as well but only one such
scheme notified and recognised by Commission to date (AACS);
• However, there are national schemes operating nationally without being
notified and recognised by the Commission;
• 14 voluntary schemes and 1 national scheme were officially recognised by
the Commission to date;
• 1 VS technically compliant but still not formally recognised.

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EC recognised national and voluntary

certification schemes (VSs)
• VSs are diverse in scope:
 majority certify agricultural biomass: RED II, article 29 (2-5) and (10);

 some certify forest biomass: SURE and SBP officially recognised/ KZR INiG technically
compliant to extend its scope on forest biomass but no formal decision published yet;

• All 15 formally recognised certification schemes will have to update their

documentation to be compliant with the Implementing Regulation (IR) on
sustainability certification adopted in June 2022 in order to keep their status
of recognised schemes.
• All the information on the process, assessment protocol, and status of
certification schemes can be accessed at:
3 Voluntary schemes (europa.eu)

National & Voluntary schemes assessment

process under REDII
• Technical assessment uses a publicly available Assessment Protocol
template (published in 2020) which covers all relevant aspects: – Land
criteria (agriculture and forest) – GHG emission savings – Mass balance –
Audit Quality and Scheme governance;
• Assessment Protocol was updated in line with Implementing Regulation on
sustainability certification;
• All voluntary schemes already re-submitted their updated documents for re-
assessment by the Commission.
• The re-assessment process is expected to be completed in Q1 2023.
4

2
 17/11/2022

Main areas covered in the IR on certification

• General rules on governance, internal monitoring, complaints procedures and
transparency of voluntary schemes (Articles 3-9);
• Specific rules on audit process, audit scope, qualifications of auditors and
audit supervision (Articles 10-17);
• Specific rules on implementation of the mass balance system and the Union
database, as well as on establishing GHG emissions and biological fraction of
fuels (Articles 18-23); [see second part of this presentation]
• Specific rules on compliance with the requirements on low ILUC (Indirect
Land Use Change) certification (Articles 24- 27).
5

Governance, internal monitoring, complaints

procedures and transparency of voluntary
schemes
• Ensure balanced representation of stakeholders, mitigate risk of conflict of
interest in decision-making, including integrity of auditors, and access to
technical support;
• System to deal with non-conformities, based on a harmonised definition;
• Minimum standards for VSs on operating a monitoring system on the quality
of the audit process: Its results summarised in annual activity reports;
• Mandatory transparency requirements about minimum information to be
made available on the website of VSs.

3
 17/11/2022

Audit process, audit scope, qualifications of

auditors and audit supervision
• Levels of assurance depending on risk profile of Economic Operators (EOs);
• Four eyes principle: technical review of audit results;
• Annual audit review- re-certification or surveillance audits;
• Classification of audit findings and remedies;
• Minimum content of the audit reports;

Audit process, audit scope, qualifications of

auditors and audit supervision
• Qualification and technical expertise of auditors, special focus auditing of
residues/ waste, mass-balance, GHG calculation, highly biodiverse grassland
and group audits approach;
• Minimum standards for keeping record by EOs, VSs and Certification Bodies
(CBs).
• Technical support and training for auditors to be ensured by VSs and
reviewed based on the results of internal monitoring system;

4
 17/11/2022

Audit process, audit scope, qualifications of

auditors and audit supervision
• Accreditation of CBs to ISO standards (ISO 17065, ISO 14065) and
accreditation or recognition to the scope of RED II or the VSs (alternative
option for independent oversight upon approval by competent authorities of
MSs);
• Cooperation in audit supervision of CBs by MSs.
• Supervision of VSs by the Commission: annual activity reports and notification
of substantial changes.

Implementation of mass balance system

(MBS) and Union database, Calculation of
GHG emissions and biological fraction of
fuels
• Requirements for data entry and verification in the Union Data Base (UDB);
• Specific rules for implementing the MBS: period of net MB, concept of product group;
• Specific rules for calculating GHG emissions: standard values, methodology on Esca* and
cultivation emissions.
• Specific rules on determining wastes/ residues: positive list, monitoring of residues from
agriculture;
• Reference to the methodologies on RFNBOs*, RCFs* and co-processing.
* Esca = emission savings from soil carbon accumulation via improved agricultural management
RFNBOs = renewable liquid and gaseous transport fuels of non-biological origin
RCFs = recycled carbon fuels
10

10

5
 17/11/2022

Compliance with the requirements on low

ILUC certification
• Streamlined rules on the process of application and certification, based on an
on-site baseline audit to verify the management plan.
• Subsequent regular annual audits to ensure correct implementation;
• Proof of additionality if measures applied on abandoned or severely degraded
land or by small holders, based on definitions,
• In all other cases, additionality to be proven by applying either a financial
attractiveness or barrier analysis assessment.
• Method for calculating the additional biomass eligible for Low ILUC
certification.
11

11

Some information on steps in Implementing

the IR on sustainability certification

• The Commission carried out technical meetings dedicated to specific topics in

order to support the voluntary schemes with the implementation of the new
rules (e.g. Esca methodology, Implementation of the Mass-balancing system,
etc.);
• CA-RES task force was set up to support the initial process of reflection on
the MSs side on how to implement the provisions of article 17 on cooperation
of MSs competent authorities in supervision of CBs.

12

12

6
 17/11/2022

Thank you for your attention!

13

13

Implementation of the mass-

balance system (MBS)
Article 19 of IR

14

14

7
 17/11/2022

Article 19.2(a)-(e): The concept of a mixture

• A single MBS can be applied only if the raw materials or fuels can be
considered part of the same mixture, which means being in one the situations
below:

• physically mixed in a container, at a processing or logistical facility, or at a

transmission and distribution infrastructure or site;

• physically identical/ not mixed/ but stored in the boundaries of the MBS;

• belong to the same product group and stored in the boundaries of the
MBS.
15

15

Article 19.2(a)-(e): The concept of a mixture

• Special additional requirement for raw materials- to be considered part of a
mixture they have to belong to the same product group, except where the raw
material is mixed for the purpose of further processing (processing site).
• Fuels introduced into a logistical facility or a transmission or distribution
infrastructure are considered part of a mixture only if that infrastructure is
interconnected- to cover the case of gaseous fuels part of the interconnected
EU grid or liquid fuels part of an interconnected pipes infrastructure!
• EOs to keep separate mass balances for raw materials and fuels not
considered part of a mixture. Transfer of sustainability and GHG emissions
saving characteristics and sizes between different mass balances not
16
allowed!

16

8
 17/11/2022

Article 19.2(a)-(e): The concept of a Product

Group
• ‘product group’ means raw materials, biofuels, bioliquids, non-gaseous
biomass fuels with similar physical and chemical characteristics and similar
heating values or gaseous biomass fuels, and LNG with similar chemical
characteristics that all are subject to the same rules set out in Articles 7, 26
and 27 of Directive (EU) 2018/2001 for determining the contribution of
biofuels, bioliquids and biomass fuels towards achieving the targets for
renewable energy;

17

17

Objective of the MBS: Keep separate chain of custody

and traceability for raw materials that are treated
differently under RED II until the production site!
Practical examples
• Raw material for 1st generation biofuels can be mixed: rapeseed oil and
sunflower oil on a site can be considered a mixture- free allocation of
sustainability characteristics (since part of the same product group);
• REDII sub-target is included in the definition of product group- rapeseed oil,
palm oil and UCO on a site cannot be considered part of a mixture: different
MBSs to be applied!
• However, any biodiesel feedstock on a site to be processed for biodiesel can
be mixed- free allocation of the total available sustainability characteristics to
the outgoing by-products: e.g. FAME (Fatty Acid Methyl Ester)!
• Sustainability characteristics can be allocated freely for physically identical
18

feedstock like low ILUC and high ILUC palm!

18

9
 17/11/2022

Objective of the MBS for gaseous fuels: Allow for some

flexibility but avoid any double counting/ disclosure!
Practical examples
• No traceability of molecules but net MB of injected and withdrawn volume of
sustainable and renewable gas!
• Case of LNG:
 some flexibility allowed if LNG and bio-methane are part of the same
interconnected infrastructure, according to the definition of the IR- transfer of
sustainability and GHG emission saving characteristics possible!

 in such a case conversion factors and GHG emissions from liquefaction to be

taken into account in a LCA approach!

19

19

Article 19.2(f)- (i): Scope and accountancy of

inputs/ outputs in the MBS
• Mass balance system (MBS) to cover all information about the sustainability
and the GHG emissions characteristics and quantities of raw material and
fuels (including the quantities of raw material and fuels for which no
sustainability or GHG characteristics have been determined);
• Consignments of raw material or fuel delivered to an EO outside of the
certification system (not participating in a voluntary scheme or national
scheme) to be booked by withdrawing an equivalent quantity of raw material
or fuel AND the type of fuel shall correspond to the physical nature of the raw
material or fuel delivered (i.e. free allocation of sustainability characteristics
for these consignments not allowed!);
20

20

10
 17/11/2022

Article 19.2(f)- (i): Scope and accountancy of

inputs/ outputs in the MBS
• Consignment placed on the market (i.e. comply with an obligation placed on a
fuel supplier by a Member State) to be withdrawn from the mixture of the
mass balance as consumed!
• If biofuels, bioliquids or biomass fuels blended with fossil fuels, the
information about the sustainability and GHG emissions saving
characteristics assigned to the blend shall correspond to the physical share of
the biofuel, bioliquids or biomass fuels in the blend.
• For biofuels and bioliquids, Member States have the option to use the
methods under Article 23 to physically check the bio-share in the blend!

21

21

Article 19.2(j)- (k): Allocation sustainability

information in the MBS
• Sustainability and GHG emissions saving characteristics of a consignment of
raw material or fuel considered as a set.
• Free allocation of the sets of sustainability and GHG emissions saving
characteristics as long as they are not split and the mass balance is achieved
over the appropriate period of time;
• No use of average GHG values is allowed!
• Include information on whether support has been provided for the production
of the fuel or fuel precursor, and if so, the type of support;

22

22

11
 17/11/2022

Article 19.2(l): Timeframe to achieve net MB

• General rule: 3 months all economic operators;
• Specific case of primary producers of agricultural biomass and forest biomass
and first gathering points: 12 months
• Flexibility of defining the start and end of the period:
 Calendar year (or the four quarters of the calendar year);
 Economic year used for bookkeeping purposes;
 Another starting point (choice to be clearly indicated and applied
consistently).
23

23

Article 19.2(l): Timeframe to achieve net MB

• Achieving net mass-balancing:

 At the end of the mass balance period, the sustainability data carried
forward should be equivalent to the physical stock in the container,
processing or logistical facility, transmission and distribution infrastructure
or site!
 Sustainability data not assigned to consignments beyond the physical
stock at the net mass balancing date to be cancelled!

24

24

12
 17/11/2022

Article 19.2(m): Transfer of sustainability data

• Voluntary schemes to specify the minimum set of sustainability and GHG
emissions saving characteristics, (IR, Annex I) to be passed down the supply
chain as well as other information necessary to trace the consignments!
• For liquid or gaseous fuels part of an interconnected infrastructure and
subject to the same MBS- tracing of respective sustainability and GHG
emissions saving characteristics assigned to the consignments only entering
and exiting the interconnected infrastructure (inside trading not covered).
• Voluntary schemes to ensure that economic operators correctly enter all
relevant information in the Union database!

25

25

Thank you for your attention!

26

26

13
 17.11.2022

EU ETS AND RED II IN CZ

Jiří Chrpa
Emission Trading Unit, Ministry of the Environment, CZ

Webinar

20th October 2022

1
 17.11.2022

USE OF BIOMASS IN CZ (EU ETS)

• EU ETS Installations in CZ in 2021 (small annual increase):

– 61 out of 247 (24,7 %) installations using biomass;
– No or very limited share of biomass materials non complying
with RED II (no oversea import etc.)
– Sustainable biomass emissions: 6 432 871,90 t CO2e
– Fossil emissions: 57 678 273 t CO2e

RED II IMPLEMENTATION IN CZ

• Ministry of Industry and Trade implements RED II

• Ministry of the Environment is responsible for EU ETS
• Act on „Supported Energy Sources“
– Implements the criteria from RED II, referred to in Regulation
2066/2018, Art. 38
• Voluntary schemes, currently 3 available on the market in CZ (ISCC, SURE
and KZR INiG); no national scheme
• Complications:
– Transitional provisions are discussed to be adopted in the Act on Supported
Energy Sources, postponing the deadline for certification, which is, however,
a proof of sustainability from the EU ETS point of view
– Limited number of schemes available, some of them not yet approved by the
European Commission
– Administrative burden and significant costs for small EU ETS operators
4
– Overloaded certifiers, language barrier (Polish, English, German)

2
 17.11.2022

GUIDANCE DOCUMENTS AND INTERPRETATION

OF THE RULES – FLEXIBILITY FOR 2022

• Transition period according to Art. 38. (6)

– CZ (also for EU ETS) temporarily accepts a „Declaration of consent“
with the sustainability criteria in 2022 provided by the operator;
nevertheless, biomass obviously violating the RED II criteria would not
be considered as zero rated in EU ETS
• No biomass in a sharp non-compliance with RED II identified
• Weak (no) support in legislation, with an exception of Art. 38 (6)

GUIDANCE document nr. 3 and Regulation 2066/2018, Art. 38 (6): By way of derogation from
paragraph 5, first subparagraph, Member States, or competent authorities as appropriate, may
consider as fulfilled the sustainability and greenhouse gas emissions saving criteria referred to in
that paragraph for biofuels, bioliquids and biomass fuels used for combustion from 1 January 2022
to 31 December 2022.

GUIDANCE DOCUMENTS AND INTERPRETATION

OF THE RULES – RECOGNISED SCHEMES

• CZ accepts voluntary schemes recognized by the European Commission

• Nevertheless, at least in the transition year 2022 and (partly) 2023,
the schemes may be accepted even for the 2022/2023 time period (part of
the reporting year) before the approval by the Commission
– Condition: the biomass must be the same for the whole period, with all clearly
traceable processes complying with the (later) obtained certification under a
certain scheme
– Otherwise not possible to obtain the proof of sustainability for some biomass;
unequal treatment based on the date of approval of a scheme or certification
GUIDANCE document nr. 3: Details on all voluntary schemes recognised by the Commission can be found on the
Commission’s website31. Regarding schemes not [yet] recognised by the Commission, Member States may accept
those schemes, if they come to their own conclusion that the scheme ensures compliance of the biomass with RED II
criteria. Under the same conditions, the Member States may continue the acceptance of certificates issued by
schemes approved under the RED I. However, Member States may have also other specific provisions in their
legislation, e.g. allowing only schemes that have been recognised by the Commission. Hence, except when using
schemes recognised by the Commission, operators will always have to check with their competent authority or
national legislation how to provide evidence that the biomass used complies with the RED II criteria.
6

3
 17.11.2022

GUIDANCE DOCUMENTS AND INTERPRETATION OF THE

RULES – ALTERNATIVE GUARANTEE OF SUSTAINABILITY

• Alternative guarantee of sustainability by the operator, confirmed

by the verifier
– No support in legislation, a „last resort“ solution… but might be accepted after
an in depth check
– The biomass would have to clearly comply with RED II, based on traceable
data about consumption, purchase, origin etc.
Options according to GUIDANCE document nr. 3:
1) All evidence (i.e. the “proof of sustainability”) is provided by means of voluntary or national schemes by economic
operators other than the EU ETS installation which consumes the biomass; (POSSIBLE in CZ)
2) The operator becomes an “economic operator” certified by a recognised voluntary or a national scheme;
(POSSIBLE in CZ) or
3) The operator assesses the applicable sustainability and/or GHG savings criteria itself, if the (administering)
Member State’s legislation allows this approach. (NOT CLEAR IN CZ)

GUIDANCE document nr. 3: Competent authorities may require the operator to use a recognised scheme, where one
is available. If no proof of sustainability under a certification scheme is available to the operator, the operator would
have to perform the assessment of the relevant criteria himself, and get the verifier’s confirmation, provided the
national legislation and the competent authority allow this in the Member State where the biomass is used (in case of
aircraft operators, the administering Member State).
7

THANK YOU FOR YOUR ATTENTION!

Mgr. Jiří Chrpa

Emission Trading Unit, Ministry of the Environment, CZ
8
tel.: + 420 267 122 822 mob.: +420 735 164 490 e-mail: [email protected]

4
 17/11/2022

RED II IMPLEMENTATION FOR ETS

INSTALLATIONS IN FRANCE
20/10/2022

Anaïs VEDOVATI
Policy Officer
[email protected]

Direction générale de l’énergie et du climat/Service du climat et de l’efficacité énergétique/Sous-direction de l’efficacité énergétique et de la qualité
1
de l’air/Bureau de la qualité de l’air

Overview of biomass installations in France

• 2022 campaign for 2021 emissions

Total number of installations in France : 1056

Number of installations using sustainable or non-sustainable biomass : 268

Bioliquid source streams Solid biomass source streams Biogas Waste from biomass source streams

40 280 59 68
(~28 installations) (with 35 also included in solid source
streams)

RED II implementation :

Number of ETS installations using biomass for the first time in 2021 : 12

Total number of installations that would need to prove GHG reduction criteria : 12 solid or gaseous biomass + 28
bioliquid + new installations using biomass for the first time in the coming years

Total number of installations that would need to prove sustainabilty criteria : data not available yet

Direction générale de l’énergie et du climat/Service du climat et de l’efficacité énergétique/Sous-direction de l’efficacité

2
énergétique et de la qualité de l’air/Bureau de la qualité de l’air

1
 17/11/2022

RED II implementation in France

• Timeline for RED II implementation

National transposition of RED II Directive in the “Code de l’Energie” finalised :

- “Ordonnance” published : 03/03/2021
- “Décret” published : 30/12/2021
- “Arrêtés ministériels” (to clarify specific points on implementation) : 5 ministerial orders soon to be published

• RED II implementation in the EU ETS

- Article R283-1 from the “Code de l’Energie” : Only proofs from national scheme or voluntary schemes
recognised by the Commission are accepted
- But there is no national scheme in France
 Only proofs from voluntary schemes recognised by the Commission will be accepted
Some sectors are still working on integrating a voluntary scheme recognised by the Commission (example:
biomethane and wood sector)

- Regulation 2022/388 : We will consider as fulfilled all sustainability and GHG emissions saving criteria for
bioliquids and biomass fuels used for combustion during the 2023 campaign for 2022 emissions.

Direction générale de l’énergie et du climat/Service du climat et de l’efficacité énergétique/Sous-direction de l’efficacité

3
énergétique et de la qualité de l’air/Bureau de la qualité de l’air

Lessons learnt from RED I criteria for bioliquids

• Training and knowledge of Renewable Energy Directive for ETS operators, verifiers and CAs
Complicated subject that needs lots of explanation - time consuming

Difficulties for the classification of the material into the category of biomass or waste or residue :

 Operators claiming they fit into one definition only (for example residue, and then claim that they cannot be
also a bioliquid)
 Material with different states (with temperature)

• Proofs received from operators

Usually no problem to receive a sustainability proof from a voluntary scheme

Difficulties to obtain the GHG saving criteria proof from operators that do not have to demonstrate sustainability
criteria

 In phase 3, we received calculations from operators directly : difficulties for CA to assess the calculations
(ETS inspectors are different from RED inspectors, with no specific RED training)

Direction générale de l’énergie et du climat/Service du climat et de l’efficacité énergétique/Sous-direction de l’efficacité

4
énergétique et de la qualité de l’air/Bureau de la qualité de l’air

2
 17/11/2022

Main difficulties for RED II implementation

• Identify RED II installations in the ETS
No list of RED II installations (and criteria applicable) yet to compare with EU ETS installations

 Case by case assessment by ETS CA which criteria need to be fulfilled.

 Some ETS installations may have to demonstrate RED II criteria even if the installation is not under RED II
implementation. For example : an ETS installation with a gas boiler of 25 MW, and a solid biomass boiler of
14 MW, not under RED II but as it is included in an ETS installation, may need to prove sustainability or GHG
emissions saving criteria.

• Classify each material

Classification of the material into the category of solid/gas/liquid biomass or waste or residue

 GD 3 will be very helpful, but still complicated for borderline cases for ETS CA

Determine if the material is from agriculture and forestry

 Depends of the origin, and the purpose of the material (raw material, residue or waste) ?

Direction générale de l’énergie et du climat/Service du climat et de l’efficacité énergétique/Sous-direction de l’efficacité

5
énergétique et de la qualité de l’air/Bureau de la qualité de l’air

Main difficulties for RED II implementation

• Check the respect of criteria
In GD 3, detailed example of waste produced on site, with usually no criteria to be fulfilled.
For waste (and more broadly all biomass) not produced on-site, for which GHG reduction criteria need to be
fulfilled but no sustainability criteria apply.
- No possibilities for the operator to provide his own evidence
- May be complicated to obtain the proof from a voluntary scheme (from our lessons learnt)

 It is possible that biomass will be counted as fossil emissions for ETS installations unable to prove the GHG
saving criteria because they do not have a proof from a voluntary scheme recognised by the Commission.

 Important stake for ETS CA

Direction générale de l’énergie et du climat/Service du climat et de l’efficacité énergétique/Sous-direction de l’efficacité

6
énergétique et de la qualité de l’air/Bureau de la qualité de l’air

3
 17/11/2022

Practical cases
• Sunflower husk
Industrial installation producing sunflower oil from sunflower seeds, and using sunflower husk for combustion.

Should the sunflower husk be considered as coming directly from agriculture, as a residue/waste from agriculture,
or as processed, and thus an industrial waste or residue ?

Possibilities :
1) The sunflower seed with husk comes from agriculture directly. Is it considered as an industrial residue if the
seed and the husk are separated on-site (and thus no sustainability criteria apply), or as a residue from
agriculture (and thus sustainability criteria apply) ?
2) The sunflower husk was turned into granules or tablets before arriving to the ETS installation. In that case it
should not be considered as a residue from agriculture in line with section 9.5.9 of GD3 ?

• Sawdust
Industrial installation producing wood furniture from wood directly, and using the sawdust for combustion (or the
sawdust is used in another ETS installation for combustion).

Should the sawdust be considered as a residue, or waste from forestry, or as an industrial residue or waste?

Direction générale de l’énergie et du climat/Service du climat et de l’efficacité énergétique/Sous-direction de l’efficacité

7
énergétique et de la qualité de l’air/Bureau de la qualité de l’air

4
 20 October 2022
Helen van de Lagemaat

RED2 implementation in EU-ETS

The Netherlands

LHvd(N12 20th October 2022

Helen van de Lagemaat

Key points Dutch implementation

1. Biogas bought via the national grid based on purchase
records implemented in 2022

2. For all other biomass: in the first instance a ‘temporary’

implementation applicable for 2023 and 2024
• Achieve a balance between achievability for installations and
meeting the requirements laid down in the EU-ETS and RED2
• Based partly on the national subsidy rules for sustainability of
biomass for energy purposes

3. Further refinement of the implementation will include

lessons learnt and accommodate changes in European
directives and national initiatives

1
Slide 2

LHvd(N12 Lagemaat, H.C. van de (Helen) - NEa, 21/09/2022

 20th October 2022
Helen van de Lagemaat

National implementation
Cat. Type biomass Criteria derived Applicable criteria Demonstration
from

The national Sustainability & Conform the

1 Pellet form biomass subsidy ILUC as applicable national subsidy
(all biomass materials) instrument instrument for pellet
GHG reduction type biomass

2 Biogas via national grid Via national

database (Vertogas)

Fluid biomass According to the Conform the

3 As applicable:
(all biomass materials) RED2 criteria national subsidy
Sustainability &
made applicable instrument for
GHG reduction
Biomass from agriculture, through the EU- biomass that must
4 forestry, fishing and ETS MRV meet RED2 criteria
aquaculture (including
residues)
EU ETS monitoring
>2021 GHG reduction plan (MP) &
verification
5 Other wastes &
residues No criteria
<2021 applicable in EU- None EU ETS monitoring
ETS plan (MP)

20th October 2022

Helen van de Lagemaat

National subsidy instruments

• National legislation for the use of biomass in pellet form set
up in 2018 and used for subsidy.
• Transcribes applicable criteria, in line with RED2. ILUC and GHG
savings applicable.
• Transcribes the accepted certification schemes per biomass
type, including nationally approved schemes
• Defines a ‘verification per delivery’ route accepted under certain
conditions.

• National legislation for biomass in other forms set up for

application from 2021
• Translates the RED2 criteria applicable per biomass type
• Transcribes the accepted certification schemes per biomass type
• Defines a non-certification route for sewage slib and used wood

2
 20th October 2022
Helen van de Lagemaat

Demonstration
According to national subsidy rules

• Certification of delivery chain and end-user

required.
• Each batch covered by Proofs of Sustainability
(PoS) from a scheme approved by the EU
• For wood from forestry RED2 schemes approved
nationally are accepted

• A dedicated verifier (CBI) checks the PoS’s at

the end of the year and provides a statement
(CJV)

• The EU-ETS verifier uses the CJV to assess the

correct application of the zero emission in the
emissions report

20th October 2022

Helen van de Lagemaat

Demonstration
Via national database (Vertogas)

• Applicable for biogas added to the national grid in The

Netherlands

• Certification of chain and producer required.

Certification of end user not required

• Only certification schemes approved by the EU

accepted

• The EU-ETS verifier uses the national database to

assess the correct application of the zero emission in
the emissions report

3
 20th October
Helen van de Lagemaat

Demonstration
Via monitoring plan

• Only relevant for installations using wastes and residues

not from agriculture, forestry, fisheries or aquaculture,
burning biomass for the first time after 30 December 2020

• Assessment of GHG savings criteria described in

monitoring plan

• The EU-ETS verifier assesses the correct application of the

zero emission factor in the emissions report based on the
information in the monitoring plan and purchase records

7 June 2021

4
 11/17/2022

Danish implementation
of RED-II

OVERLAPPING RED-CRITERIA DANISH RE

EU ETS
LEGISLATION

INSTALLATION COVERED INSTALLATION COVERED INSTALLATION COVERED

BY EU ETS BY DANISH RE- BY BOTH EU ETS AND DK
LEGISLATION LEGISLATION

- Must comply with Directive - Must comply with the Danish - Must comply with the Danish
2003/87/EC and the MRR. legislation. legislation.

- Must at least comply with the - The criteria introduced in the

minimum requirements of the RE-legislation can be stricter
RED-II directive. than those in the RED-II directive

11/17/2022 Page 2

1
 11/17/2022

HOW TO COMPLY WITH RED-II IN DK?

INTERNATIONAL
NATIONAL OPERATORS
VOLUNTARY
SCHEMES PROVIDE EVIDENCE
SCHEMES

- Operator uses biomass from - Temporarily approved schemes (2023) - Operators provide all necessary
a certified supplier evidence and GHG calculations
- Temporary approval ceases if the
- Proof of sustainability is verified Comission rejects application for EU- - This evidence is audited by RED-II
during ETS audit approval auditor

11/17/2022 Page 3

VERIFICATION OF RED-CRITERIA

Biomass from certified supplier: Biomass from non-certified supplier:

If RED-II or DK legislation requirements are • RED-II audits are carried out by RED-II auditors
covered by a scheme  Only ETS verification

RED-II audit report is made available to the ETS verifier

• ETS-verifier checks the evidence provided
by the certified biomass supplier
• Currently, no ETS verifiers meets the required
competencies for RED-II audits

11/17/2022 Page 4

2
 11/17/2022

RED-II ISSUES – REPORTING/VERIFICATION DEADLINES

Pre-approval of compliance with RED-II may be necessary due to:

- Matching deadlines for ETS and RE reporting
- Staggered RE reporting period for biogas

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar
22 22 22 22 22 22 22 22 22 22 22 22 23 23 23
EU ETS reporting Reporting period Deadline

Danish RE reporting Reporting period Deadline

RE reporting - Biogas Deadline Reporting period

11/17/2022 Page 5

Biogas from the gas grid

• Biomethane (bionatural gas) is a seperate source stream in the MP

• Double counting is avoided by immediate cancellation of GO’s in

the Danish GO registry, when biomethane is sold to an end user

• Cancelled GO’s are compared with purchase invoices for the gas

• Most biomethane suppliers in DK are certified by voluntary

schemes

11/17/2022 Page 6

3
 11/17/2022

Questions?

Thank you

4
 Implementation of RED II
in the ETS in the Flemish Region
State of play

Tomas Velghe
Compliance Conference
Thu 20-Oct-2022

Short about VEKA

 stands for Vlaams Energie- en
Klimaatagentschap (VEKA), i.e.
Energy and Climate Agency of
Flanders
 since 1 January 2021
 on the basis of Flemish coalition
agreement
 purpose: powerful Flemish energy
and climate policy
 at the moment: +/- 150 colleagues
 more info:
https://www.energiesparen.be/ov
er_veka

1
 Implementation of ETS
in the Flemish Region
Good to know
• MP and MMP: drafts from operators are checked by ‘our’ VBBV (Benchmarking
Verification Bureau of Flanders) and approved of by VEKA

• AER and ALC: verification by external verifiers, and approval by VEKA

• The Flemish region uses:

• Excel-templates (DG CLIMA) for MP and MMP
• own reporting tool for AER (online ; with access for external verifiers)
• Excel-template (DG CLIMA) for ALC (together with “upload” facility)

• Considering to shift to reporting tools from DG CLIMA 2

Implementation of RED II under ETS

in the Flemish Region
Basic information
• Chosen to implement RED II as from 1 January 2023 (and not 2022)
• Awaited (a long time) endorsement of Guidance Document 3 on Biomass Issues
 now that it is there, we will certainly use it extensively
 and see it as a sort of “bible”
• Intention is to request operators to change (incl. getting approval) where
necessary MP by 31 December 2022 (no changes to MMP required)
• No specific legislation planned, as FL legislation refers to MR Regulation
2018/2066
3

2
 Implementation of RED II under ETS
in the Flemish Region
Impact of RED II

• Impact is expected to be very small (certainly in numbers of installations involved)

in the Flemish region, due to:
 small numbers of (mixed) biomass used at this moment in ETS
 cut-off date “Installation started after 2020?”
 in that case no need to assess meeting GHG savings criteria for gaseous and
solid biomass streams
 to be changed with proposed RED3?

Implementation of RED II under ETS

in the Flemish Region
Specific choices/circumstances
• The creation of national schemes to assess REDII-criteria is not planned

• Not in favour letting the operator assess REDII-criteria without using a POS
=> only voluntary schemes or national schemes that are approved by the COM
are accepted

• Compliance with REDII criteria can be proven by:

• POS generated by the consuming installation (consuming installation =
economic operator)
• POS generated by the biomass supplier (supplier = economic operator)
5

3
 Implementation of RED II under ETS
in the Flemish Region
Specific choices/circumstances

• There might be a different treatment of biomass under ETS and biomass for FL
subsidy schemes (more strict), but as long the differences are clear, that is not
perceived as problematic
• No national database for biogas, hence specific guidance note (elaborated in 2nd
half of 2021) will normally be extended for 2022 (and 2023?) emissions: Practical
aspects treatment of green gas in ETS in Flanders (EN courtesy transl.), meaning:
1) purchasing records of biogas
2) biogas injected meets RED II sustainability and GHG savings criteria (only for 2023 emissions)
3) cancellation of Green Gas GO (only in MS where there is an issuing body for GO Green Gas)

Implementation of RED II under ETS

in the Flemish Region
Practical issues with respect to changes to MP
• Point 8 of MRR Annex I, section 1, requires that the operator has in its
monitoring plan “a description of the procedure used to assess if biomass
source streams comply with Article 38(5)”. CA will assess this when they
approve the monitoring plan of installations or aircraft operators.

• Classification of biomass streams (solid/gaseous/liquid) has (a lot of) impact

and might create discussions (f.e. sewage sludge). Will need to be decided in
the MP (approval with the MP modification)

4
 MORE INFO
Tomas Velghe
Vlaams Energie- en Klimaatagentschap
www.energiesparen.be
T +32 478 34 43 34
[email protected]

5
 Certification systems in practice
–
Viewpoint of the certification system
Thomas Bock, System Manager, ISCC System GmbH
EU ETS Compliance Forum – Training Event on Biomass No. 1, 20 October 2022
© ISCC System GmbH: For personal use only. Reproduction and distribution is prohibited. 0

Certification via voluntary certification schemes aims to ensure sustainability and

GHG emissions reductions along global supply chains

ISCC certification aims to ensure

Sustainability in feedstock production Traceability of sustainable materials Verified reduction of GHG emissions
through the supply chain

© ISCC System GmbH: For personal use only. Reproduction and distribution is prohibited. 1
 The System Documents build the basis of the certification system. They are
based on the RED II and additional rules and guidance by the Commission

▪ The System Documents lay down all relevant certification requirements and processes for Certification
Bodies and System Users (i.e. certified companies) and are structured into different topics
▪ All System Documents are publicly available on the ISCC website

© ISCC System GmbH: For personal use only. Reproduction and distribution is prohibited. 2

Auditors verify compliance with the standard’s requirements via so-called audit
procedures. These are based on the System Documents

Economic operators generally use the audit

Example for Doc 202 procedures, too – for audit preparation Extracts

© ISCC System GmbH: For personal use only. Reproduction and distribution is prohibited. 3
 Requirements for certification bodies and
auditors to conduct ISCC audits
▪ Requirements for certification bodies
• Accreditation (ISO 17065 and, if applicable, ISO 14065) as well as
recognition by national public authority
• Audits carried out according to ISO 19011
• Deep integration of ISCC standard into certification body’s processes (e.g.
quality management, ensuring competence of auditors, etc.)
• Successful completion of a rigorous application process (under ISCC)
• Regular reporting to ISCC on auditing activities against ISCC standards

▪ Requirements for auditors

• Technical knowledge and good understanding of the audited activities of
the operator
• Sufficient audit experience
• Particularly stringent requirements for auditors conducting audits in
“higher risk supply chains” (e.g. waste and residue-based supply chains)
• Personal and professional behaviour in line with ISO 19011
• Successful participation in comprehensive ISCC Training Program
• Etc.

© ISCC use
© ISCC System GmbH: For personal System
only.GmbH: For personal
Reproduction use only. Reproduction
and distribution is prohibited. and distribution is prohibited. 4

Typical certification process. Recertification happens every 12 months

The company sets up its If corrective measures

The company selects were determined, these ISCC publishes
management system,
a Certification Body must be implemented by the certificate
traceability system and
(CB) and registers on ISCC website for third
Audit date

GHG emissions company at the latest 40

with ISCC days after the audit date parties to check
calculation

Registration process Risk assessment and conducting the audit After the audit date Certificate is issued

The CB conducts a risk CB conducts on-site If audit successful, CB

CB conducts up-front
assessment of the audit issues certificate to
desk check
specific supply chain (including verification of the company.
(including mass balance,
set-up and draws up a results from desk check, Company can start
employee handbook,
verification plan interviews of personnel handling sustainable
GHG calculation etc.)
etc.) material

© ISCC System GmbH: For personal use only. Reproduction and distribution is prohibited. 5
 Which kind of documentation do operators
need to provide for certification?
▪ Depends on type of operation in question (Farm? Trading
unit? Waste collecting point? Processing unit?)
▪ The main aspects audited relate to the operator’s
a) management system
b) traceability system / mass balance
c) GHG calculation

▪ A host of different data and documentation needs to be

provided by the operator to substantiate a) – c), including
• Description of site layouts, tank layouts, internal production process
• List of all suppliers / recipients of sustainable material
• Incoming and outgoing sustainability declarations
• Delivery notes, weighbridge tickets
• Contracts with (sub)contractors
• Production reports (yields, co-products, wastes, emission factors)
• Results of internal risk assessment & internal audits

© ISCC use
© ISCC System GmbH: For personal System
only.GmbH: For personal
Reproduction use only. Reproduction
and distribution is prohibited. and distribution is prohibited. 6

To enable certification, ISCC and other schemes classify different supply chain
elements according to their scope of operation

Feedstock sourcing Processing and distribution

Agricultural
and forest
biomass and
residues
Farm/Plantation First Gathering
Point

Processing Unit Trader/Storage Processing Unit Trader/Storage Market

Waste,
residues,
renewable non- Point of Origin Collecting
bio feedstocks Point

Sustainability requirements for

feedstock production

Traceability, Chain of Custody, GHG emissions

© ISCC System GmbH: For personal use only. Reproduction and distribution is prohibited. 7
 Every supply chain element is certified. Information on sustainable material is
forwarded and traced through supply chains via Sustainability Declarations

Farm/Plantation* First Gathering

Point

Processing Unit Trader/Storage Processing Unit Trader/Storage Market

Point of Origin* Collecting

Point

*Generally covered via certification

Self-
of subsequent supply chain element
Declaration Sustainability Sustainability Sustainability Sustainability Sustainability
Declaration Declaration Declaration Declaration/Proof Declaration/Proof
of Sustainability of Sustainability
© ISCC System GmbH: For personal use only. Reproduction and distribution is prohibited. 8

Complex and globally-spanning value chains can be covered through the

individual certification of supply chain elements
▪ Virtually every economic operator
can be classified according to the
existing ”scopes”, for which clear
audit requirements have been
established

▪ Requirements for compliance are

the same regardless of the country
the economic operator is based in

▪ Certification of each individual

supply chain element ensures
traceability without gaps

▪ Sustainable material and related

information is tracked via mass
balance system at each element

▪ Each operator must be certified to

be allowed to handle sustainable
material

▪ Operators can source from and sell

to operators that are certified
themselves, allowing flexibility in
the choice of suppliers and
recipients

▪ Regular audits to verify economic

operators’ compliance with relevant
© ISCC System GmbH: For personal use only. Reproduction and distribution is prohibited. requirements 9
 The mass balance approach: Sustainable and non-sustainable material can be
physically mixed but must be kept separated in the bookkeeping
Separate bookkeeping for sustainable material

Sustainable
feedstocks

First Gathering Processing Unit Trader/Storage Processing Unit Processing Unit Trader/Storage Market
Point / Central Office
Non-sustainable
feedstocks

Separate bookkeeping for non-sustainable material

© ISCC System GmbH: For personal use only. Reproduction and distribution is prohibited. 10

A mass balance ensures that volumes of outgoing sustainable material do not

exceed volumes of incoming sustainable material
Example

Mass Balance Period ▪ During the mass balance period:

• Possible to go short, i.e. to sell more material as
sustainable than available

▪ At the end of the mass balance period:

• Incoming sustainable products and outgoing
Incoming material sustainable products must in balance, OR
Total • More sustainable material was taken in than
Month 1 Month 2 Month 3
period taken out
Outgoing material − Credits of sustainable material may be transferred
into the next mass balance period
• A negative balance at the end of the mass
balance period is not permitted
− This is the case when more sustainable material was
taken out than taken in
Non-sustainable material
Sustainable material

© ISCC System GmbH: For personal use only. Reproduction and distribution is prohibited. 11
Example of a simplified mass balance calculation

Simplified example
Physical
Operational Unit (e.g. Processing Unit) Batch 126

Sustainable Batch 123 Batch 127 Mixture of

Mix of batch Batch 128 Sustainable and
Sustainable Batch 124
123 – 125 Non-Sustainable
Non-Sustainable Batch 125 Batch 129 Product
Batch 130

Bookkeeping

Input Company Internal Process Output

Batch Kind Amount (t) Batch Kind Amount (t) Batch Kind Amount (t)
123 Sustainable 500 123+124 Sustainable 2000 126 Sustainable 200
124 Sustainable 1500 127 Sustainable 800
125 Non-Sustainable 1000 125 Non-sustainable 1000 128 Sustainable 1000
129 Non-Sustainable 500
130 Non-Sustainable 500
Total 3000 Total 3000 Total 3000

Assumed conversion factor CF = 1

© ISCC System GmbH: For personal use only. Reproduction and distribution is prohibited. 12

Based on the RED II, ISCC provides the methodology and rules for calculating
and verifying GHG emissions reductions
ISCC integrates RED II
RED II lays down basic provisions in its system and Economic operators calculate
GHG methodology further details requirements GHG values of their operation
according to ISCC document.
Subject to regular audits.

© ISCC System GmbH: For personal use only. Reproduction and distribution is prohibited. 13
 RED II “certificate” vs “proof of sustainability”

Certificate Proof of Sustainability

Source: MRR GD No.3, 3rd draft

© ISCC use
© ISCC System GmbH: For personal System
only.GmbH: For personal
Reproduction use only. Reproduction
and distribution is prohibited. and distribution is prohibited. 14

The Proof of Sustainability (PoS): Essential for stating that all relevant RED II
criteria have been verified along the supply chain

▪ Chapter 1 of the PoS gives general information, including the type

of product and type of raw material / feedstock
▪ The PoS will have a statement that indicates “EU RED compliant
material”. This is ticked with ”Yes” if this batch of product can be
considered compliant

© ISCC System GmbH: For personal use only. Reproduction and distribution is prohibited. 15
The Proof of Sustainability (PoS): Essential for stating that all relevant RED II
criteria have been verified along the supply chain

▪ Chapter 2 of the PoS includes a series of statements on how the

raw material / feedstock for the product can be considered
▪ For agricultural and forestry biomass including residues from
agricultural, aquaculture, fisheries and forestry: The statement
“The raw material complies with the relevant sustainability criteria
according to Art. 29 (2) – (7) RED II” is ticked if raw material
compliant with RED II requirements
▪ For wastes and residues as well as products produced from
wastes and residues: The statement “The raw material meets the
definition of waste or residue according to the RED II” is ticked if
raw material compliant with RED II requirements
▪ Please note: Both statements are ticked with ”Yes” in case of
residues from agricultural, aquaculture, fisheries and forestry

© ISCC System GmbH: For personal use only. Reproduction and distribution is prohibited. 16

The Proof of Sustainability (PoS): Essential for stating that all relevant RED II
criteria have been verified along the supply chain

▪ Chapter 3 of the PoS gives information on Greenhouse gas (GHG)

emissions
▪ If ISCC PoS template is used by the economic operator, the GHG
emissions savings will be indicated on the PoS, depending on fuel
type (biofuel, bioliquid, biomass fuel) and end use (transport,
electricity, etc.)
▪ As knowledge of start date of operation is necessary to determine
the GHG minimum saving threshold, this information is included on
the PoS as well

© ISCC System GmbH: For personal use only. Reproduction and distribution is prohibited. 17
 Depending on the type of biomass, different
criteria are audited and must be complied with

▪ Under ISCC, the general auditing and certification principles

apply equally to all streams of biomass, as well as to all fuel types
(biofuels, bioliquids, biomass fuels)
▪ Auditors are required to use process depicted on the left to
determine the status and classification of a material at
beginning of the supply chain
▪ Depending on result, the material will have to comply with the
applicable criteria during the audit:
• Agricultural & forestry (co)products as well as residues from
agriculture, aquaculture, fisheries or forestry must comply with a) the
“land-related” RED II sustainability requirements as per Art. 29 (2) – (5),
and b) the GHG saving criteria

• Waste and processing residues do not need to comply with the “land-
related” RED II sustainability requirements, but do need to comply with the
GHG saving criteria

▪ If material (e.g. a waste) is generated directly in an installation,

Process to determine if a material is a waste or residue (to be done by the auditor)
the operator will have to prove plausibility of amounts generated
Source: ISCC document 202-5 “Waste and residues” © ISCC use
© ISCC System GmbH: For personal System
only.GmbH: For personal
Reproduction use only. Reproduction
and distribution is prohibited. and distribution is prohibited. 18

Thank you for your attention!

Thomas Bock, ISCC System GmbH

Hohenzollernring 72, 50672 Cologne, Germany
Follow us on Email: [email protected]
© ISCC System GmbH: For personal use only. Reproduction and distribution is prohibited. 19
 Practical Experiences
with Certification of Sustainable Biomass
in Germany

2022 EU ETS COMPLIANCE FORUM

Werner Betzenbichler

Topics

 Brief introduction

 Certification Schemes used by German operators

 Key Market drivers for SURE certification

 Specialties of “solid biomass market”

 Certification approach

 Open issues wrt to use under EU ETS

www.verico.eu

Werner Betzenbichler 2

11/17
/2022 1
 Brief introduction of verico SCE

 verico SCE (Societas Cooperative Europaea)

a European cooperative based in Langenbach, Bavaria
 Our members are small enterprises and freelancers;
recently 34 members (end of 2021) from 6 EU countries + 5 non-EU
countries
 Many members worked in high level management position in large
validation and verification companies
 All with a background in
- MRV (monitoring, reporting, verification) of GHG emissions
- MRV of energy generation (renewable and conventional)
- Energy management systems
- Capacity building activities
 verico SCE provides accredited services and a platform for multi-
www.verico.eu

sectoral services

Brief introduction of verico SCE

 globally the only accredited cooperative

 Energy management system (ISO 50001)

 Sustainable biomass certification (SURE)

 Greenhouse gas emissions (ISO 14065)

 Corporate inventories
(EU ETS, carbon footprint, CDP, F-Gas, product carbon footprint, CBAM)

 Emission reduction projects

(voluntary market, VCS/VERRA, GCC, UER)

 Studies, trainings and support for scheme regulators like development

www.verico.eu

banks, ministries and authorities as well as accreditation bodies

11/17
/2022 2
 Certification Scheme(s)

 Driven by RE subsidies / tariffs the certification of biofuels and biogas

is established since long in Germany

 ISCC - International Sustainability and Carbon Certification

 REDcert

Since mid of 2021(with focus on RED-II)

 Sustainable Resources (SURE) Verification Scheme

 All require two levels of accreditation, one by the system owner, one
by the BLE (Federal Office for Agriculture and Food) following
ISO17065
www.verico.eu

Key Market drivers for SURE certification

Gaseous Biofuels

 By RE subsidies / tariffs of CHP plants powered by biogas;

(Biomassestrom-Nachhaltigkeitsverordnung - BioSt-NachV)

 First aspect – agriculture activities, including LU

 Second aspect – biogas produced by digestion, fermentation or

gasification of biomass

 Third aspect – conversion to power (or heat)

 Generation capacity usually well below 20 MW  low relevance at EU

ETS installations (some auxiliary boilers / engines)
www.verico.eu

11/17
/2022 3
 Key Market drivers for SURE certification (2)

Solid Biomass Fuels

 Relevant installations with installed capacity > 20 MW

 Originally some incentive by the same regulation on RE, however, the

high spot market price for electricity completely erased that incentive

 Inclusion of aspect in EU ETS installations, most of them CHP plants

powered by wooden biomass and/or waste with biomass content

 More appropriate regulations when referring to the certification of

solid biomass is currently mainly applied for liquid biofuels
(Biokraftstoff-Nachhaltigkeitsverordnung - Biokraft-NachV)

 Key difference: GHG emissions saving targets also for existing/old

www.verico.eu

installations

Key Market drivers for SURE certification (3)

Liquid Biofuels

 Not included so far in SURE certification system

 No (expected) consumption of liquid biofuels under EU ETS for

stationary installations (other than expected for aviation)

 However, there is demand for some operators (especially waste

collectors) to get certification of both (all) types at the same time
www.verico.eu

11/17
/2022 4
 Specialties of “solid biomass market”

Solid Biomass Fuels

 Creation of market demand in a top-down principle (consumers urge

suppliers to deliver certified ware)

 Consumers (CHP-plant) are frequently also generators of biomass

waste

 Forest biomass – no problematic cases in certification, however risk of

large groups covering many landowners to be included in audit
schedule (sampling approach)

 Collection and “trading” of waste – many processing / collection sites

with consumers inside and outside of ETS  demand only for a share
of available biomass
www.verico.eu

Certification approach (1)

 Closure of certification contract with fixing of scope

 First certification, Focused on (management) system and competences

(mass balance in most cases almost empty)

 Auditing (usually including site inspections) also by means of matrix

sampling e.g. for group managers

 Filling of checklists (designed by SURE) for reporting

 Requirement to close material findings within a timeline

 Issuance of a certificate, entitling the operator to “produce” certified

biomass
www.verico.eu

 Recording of biomass / energy produced in register(s) – certification

scheme and national authority
10

10

11/17
/2022 5
 Certification approach (2)

 Upload of certificate and checklists/report(s) to SURE and BLE

 Surveillance audit after 6 months, with focus on verification of mass

balance

 Registration of “produced” biomass/energy by certified operator /

company

 Annual re-certification, including ex-post verification of mass balance

(in most cases for biomass which has been consumed already), thus
enabling consistency checks with entries in register

 As last link in the (supply) chain, the EU ETS installation has highest
incentive (and risks) regarding data quality and data consistency
www.verico.eu

11

11

Certification approach (3)

Elements of checklists (reports)

www.verico.eu

12

12

11/17
/2022 6
 Certification approach (4)

Elements of checklists (reports)

www.verico.eu

13

13

Example of a certificate
www.verico.eu

14

14

11/17
/2022 7
 Certification approach (5)

Entry of “produced” certified biomass

Agricultural biomass (without agri, waste and residues) – AGRI

Agricultural waste and residues – AGRI WaR
Forest biomass (without forest waste and residues) – FOREST
Forest waste and residues – FOREST WaR
Waste and Residues (not agricultural or forest) WaR
www.verico.eu

15

15

Open issues wrt to use under EU ETS (1)

 Inclusion of industrial waste including biomass in certification scheme

 EU-wide transportation of specific types of waste (e.g. railway

sleepers) using a unified / standardized waste notification system but
missing coverage by certification schemes

 Missing focus on GHG emissions savings when conversion plant is not

a new one

 Need for certification / acquisition of sustainable biomass before

starting with new monitoring plan (e.g. to ensure that storage volume
is already certified)
www.verico.eu

16

16

11/17
/2022 8
 Open issues wrt to use under EU ETS (2)

 High level of uncertainty (NCV, quantity at standard conditions) for

solid biomass

 Missing completion of “infrastructure” (national registries)

 apparent lack of coordination between the authorities involved &

missing guidance on MRV from (all) involved regulators

 Inconsistent usage of mass balances (wet/dry, with and without

contaminations)
www.verico.eu

17

17

Any Questions?

verico SCE
Werner Betzenbichler
Hagenaustraße 7
85416 Langenbach
[email protected]
www.verico.eu
www.verico.eu

Werner Betzenbichler 18

18

11/17
/2022 9
 17/11/2022

EU ETS Monitoring and Reporting – CF Training event

Training Event on Biomass No. 2

[email protected] 27 October 2022

Set-up of the training

• EU ETS Monitoring & reporting aspects of biomass – relation to RED II requirements
• General topics were subject of first training (last week)

• Today focusses on specific topics – biogas, aviation, verification

• Target audience:
• Competent authorities (CAs) and verification bodies

• As the topic is relatively new, all are welcome, from newcomers to experienced staff
• Objectives
• To enable you to check monitoring plans (MPs) and annual emission reports (AERs) of operators
and aircraft operators using biomass

2
 17/11/2022

Mentimeter
• What is your role in the EU ETS?
• Have you participated in the previous training day?

Agenda 27th October2022

# Time Session
1. 10:00 – 10:15 Opening, welcome and introduction (DG CLIMA)
2. 10:15 – 10:30 Biogas in grids - Requirements
10:30 – 11:00 Example of a biogas registry and ERGaR
11:00 – 11:15 Q&A
3. 11:15 – 11:25 Coffee break
4. 11:25 – 11:40 Other Biomass issues: Determining the biomass fraction, CEMS, etc.
11:40 – 11:50 Q&A
5. 11:50 – 12:15 Biofuels for Aviation: Requirements
12:15 – 12:30 Q&A
6. 12:30 – 14:00 Lunch break
7. 14:00 – 14:25 The role of the verifier in assessing biomass requirements - main requirements
14:25 – 14:40 Q&A
8. 14:40 – 15:00 Verifier’s checks on compliance with RED II criteria
15:00 – 15:15 Q&A
9. 15:15 – 15:25 Coffee break
10. 15:25 – 15:40 Verifier’s checks on compliance with RED II criteria
15:40 – 15:50 Q&A
11. 15:50 – 16:00 Wrap-up and close of the meeting (DG CLIMA)
4

4
 17/11/2022

MRR requirements for

biogas
Including requirements for biogas in natural gas grids

Guidance document 3
Guidance document 3 – “Biomass issues in the EU
ETS” has been published:
https://climate.ec.europa.eu/system/files/2022-
10/gd3_biomass_issues_en.pdf

DG CLIMA’s MRVA website:

https://climate.ec.europa.eu/eu-action/eu-emissions-
trading-system-eu-ets/monitoring-reporting-and-
verification-eu-ets-emissions_en

6
 17/11/2022

MRR and RED II

• MRR 2018 (with 2020 and 2022 amendments) contains requirement to apply
RED II criteria for biomass/biofuels
• MRR (Commission Implementing Regulation (EU) 2018/2066 of 19
December 2018 on the monitoring and reporting of greenhouse gas
emissions pursuant to Directive 2003/87/EC of the European Parliament and
of the Council and amending Commission Regulation (EU) No 601/2012):
Consolidated version: EUR-Lex - 02018R2066-20220828 - EN - EUR-Lex
• RED II (Directive (EU) 2018/2001 of the European Parliament and of the
Council of 11 December 2018 on the promotion of the use of energy from
renewable sources): EUR-Lex - 32018L2001 - EN - EUR-Lex

Monitoring Reporting Regulation

• Article 38(5) “Biomass source streams”
• Biomass emissions from combustion can be zero rated if:

• Sustainability criteria are fulfilled  Article 29 (2-7) of Directive (EU) 2018/2001 (RED II)
NEW:
Art. AND
38(5)
MRR • GHG saving criteria are fulfilled  Article 29 (10) of Directive (EU) 2018/2001 (RED II)

• Biofuels produced from waste and residues are required to fulfil only GHG
saving criteria, not the sustainability criteria
• However residues from agricultural, aquaculture, fisheries and forestry have to fulfil both,
sustainability and GHG saving criteria
8

8
 17/11/2022

Recap from last week’s training (1)

• Definitions: Article 3 of the MRR copies the biomass-related definitions from
the RED II, in particular :
• ‘biogas’ means gaseous fuels produced from biomass
• Which parts of RED II apply?
• Art. 29: Sustainability and GHG savings criteria are relevant not only for liquid, but also
for solid and gaseous biomass
• Art. 30: Verification of compliance with the sustainability and greenhouse gas emissions
saving criteria
• Art 31: Calculation of the greenhouse gas impact of biofuels, bioliquids and biomass fuels
• Art. 28(2): Other provisions on renewable energy in the transport sector: Union database:
tracing of liquid and gaseous transport fuels.

Recap from last week’s training (2)

• For which biomass materials do sustainability and/or GHG
savings criteria apply?
• Which sustainability criteria apply?
• How are GHG savings calculated?
• In which Articles of the MRR are the criteria relevant?
• Timeline – MS may delay the application of RED II criteria until
1 January 2023
• How to demonstrate compliance with RED II criteria

Some of these topics will be presented today in the

aviation-specific presentation
10

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Recap from last week’s training (3)

• How do voluntary schemes work?
• Where to find information on schemes recognised by the
Commission:
https://energy.ec.europa.eu/topics/renewable-
energy/bioenergy/voluntary-schemes_en
• Certificate
• Certifies that an economic operator complies with the rules
of the certification scheme
• Proof of Sustainability (PoS):
• Issued by the economic operator for confirming that a
certain consignment of biomass material, biofuel, biogas or
biomass fuel fulfils the sustainability and GHG savings
criteria
EU ETS operators needs the “proof of sustainability” for each of
the consignments (batches) of biomass used so that emissions
from biomass can be zero-rated in the annual emissions report.
11

11

Biogas in natural gas grids

• Situation:
• Biogas is fed into a gas grid, where it is mixed with natural gas. It is hard to predict,
where the biogas is (physically) consumed

• EU ETS operators “somewhere” connected to the grid want to claim the biogas for having
an emission factor of zero

• Solution by the MRR:

• Article 39(3) forbids the use of laboratory analyses for determining the biomass fraction
of natural gas for preventing double counting

• Article 39(4) allows an approach to determine the biomass fraction by purchase records

12

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Biogas in natural gas grids (2)

• Conditions for use of Article 39(4), i.e. the purchase records approach:
• Operator has to provide evidence that there is no double counting of the biomass

• In particular, no Guarantee of Origin (GoO) must be disclosed (i.e. used) by a third party
for the same quantity of biomass

• Gas consumer (EU ETS operator) and the producer of the biogas are connected to the
same gas grid

• Applicable sustainability & GHG savings criteria must be met

• For demonstrating compliance, the operator may use the data recorded in a
database set up by one or more Member States which enables tracing of
transfers of biogas (i.e. a “biogas registry”)  Next presentation
13

13

Purchase records or certificates?

• Does the biogas registry issue certificates that include information on sustainability, or
guarantees of origin, or both?
It must ensure that there is no double counting of biogas

• Does the biogas registry act like a mass balance system under Article 30(1) of the RED II, or
does it issue certificates or GoOs that are traded independently from the physical gas
quantities?

 If the registry fulfils the mass balance requirements, the certificates can be
considered equivalent to purchase records.
However, GoOs are not enough!

• If GoOs are also used in the MS, they must be cancelled either when the certificate is
generated in the registry, or – if closely linked to the certificate – immediately when the
certificate is used.

14

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Transfer of biogas across borders

• MS do not necessarily accept biogas transferred from another MS – Operator
needs to get information on the MS’ approach
• If registries are used, technical compatibility is required – ERGaR! (next
presentation)
• In the future, the Union database (RED II Art. 28(2)) will fulfil the required
tasks (mass balance and tracking of sustainability/GHG savings criteria)
• “Statistical transfer”: How do national inventories take such transferred
biomass into account?
No automatic mechanism in place; Bilateral agreements by MS required

15

15

Thank you for your attention

Consultant core team contacts:

[email protected] (lead on biomass topics)
[email protected] (project lead)
[email protected]
[email protected]

Commission contact:
© European Union 2021 [email protected]

Unless otherwise noted the reuse of this presentation is authorised under the CC BY 4.0 license. For any use or reproduction of elements that are
16owned by the EU, permission may need to be sought directly from the respective right holders.
not

16
 17/11/2022

ISO:
Datum PV Erstellt v. Freigabe Version
29.10.2015 BH BH QMB V01.00

Biomethane Certificates
“Example of a biogas registry and ERGaR”
EU ETS Compliance Forum
27 October 2022
Andreas Wolf

EUROPE Biomethane Certificates

Applications / marketing pathways

Biomethane certificates are the

instrument to provide
trustworthy and transparent
documentation
• For title transfer of the green value
of biomethane
• For biomethane to be applied in
different marketing pathways on
MARKETING national and European markets
PATHWAYS

2
 17/11/2022

AGCS Biomethane Registry Timeline

Launch AGCS Biomethan

2015 Founding of ERGaR in Ghent 2017
Register Austria
2008 Consulting Project
for VSG

Biomethane feed-in tariff

for renewable power

Biosurf Project Cooperations

2012 2015 - 2017 2016 AGCS & DENA 2018
AGCS & UBA

Extension registry system

ERGaR interface, sustainability
2018 2020 attributes 2021
Consulting Project
Workshop
for BFE and BAFU
Renewable gas market in
(Swiss federal authorities)
europe

Now

Webinars Open for new projects

Introduction to new functions for and cooperations
market participants
Social Media
2019 – 2022 2019 implementation 2021 2022
LinkedIn and Youtube

Biomethane in Austria

• Key Facts - Registry • Austrian Biomethane market

• All Austrian market areas covered • 15 biomethane plants
• Monthly creation of biomethane certificates • 12 Biomethane electricty production plants
• Quality through network operator data • 1 subsidy scheme for power generation via biomethane
• Transfer and split option of certificates • 136 GWh produced in 2021
• Handling of Book and Claim (“B&C”) and Mass
Balancing methods Biomethane injection in Austria
• Creation of cancellation documents for final use (incl. January - August 2022)
• Handling of mass balancing and auditing 180 170.98
• 10 Auditors
Biomethane injections in GWh

160 148.66 152.26

• 11 registered Traders 137.69 136.41
140 130.74
• Base of our work: Austrian legal acts on gas and
renewable energy 120
106.22
100 93.67
87.90

• Cooperations and future applications 80

• Interface with Register for sustainable biofuels 60

46.80
52.94 54.52
(elNA) of Austrian environment agency (UBA) 40
• Ownership transfer within Europe via the ERGaR
20
CoO scheme
0
2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022

4
 17/11/2022

Biomethane Certificates
Example Austria: Attributes of biomethane certificates

The attribute list is the centrepiece of the Biomethane Certificate,

providing all relevant information and data on the origin, quantity and
quality of biomethane (renewable gas product).
• Level 1 – plant specific information
o Information about the production plant Auditing
plant Reports qualitative
o The facility at which the biomethane was produced (incl.
commissioning) specific data
o Country, Injection point, plant type, etc. information feedstock-
related
• Level 2 – quantitative data (gas-related)
o quantity / volume (metering/clearing data)
o Specific to the issuing registry
• Level 3 – qualitative data (feedstock-related)
o Externally audited data
o Used/treated substrates incl. details on processing, quality,
volume, emission mitigation, etc.
o Sustainability criteria (REDcert, ISCC, TÜV) quantitative transfer
data information
• Level 4 – transfer information (transfer-related) gas-related
o does NOT contribute information to the renewable gas product
o to enable the (semi-)automated transfer IT-processes

Application Purpose of Biomethane Certificates

Cooperation on European level

Vision of AGCS
one centralised “Decarbonisation Registry”
to cover
Biomethane
Registry • All types of renewable gases
Austria
• All types of marketing pathways
• All types of documentation/proofs
with flexible and comprehensive attribute lists
to provide
• Maximum trust and transparency
*
physical transfer vs certificate transfer • Simplicity for market participants
* incl. mass balancing *

Cooperation & National Registry Registry free

interaction subsidy for GoO for biofuels
ERGaR Hub market
of different registries schemes (labelling) (RED II) Registry for
(Control & Transfer) Hydrogen

Different types of PoS GoO PoS

documentation as proof Proof of Sustainablity Support certificate Guarantees of Origin Proof of Sustainablity Biomethane certificate Hydrogen certificate

6
 17/11/2022

Registry systems to administer movements of renewable products

Purpose of Biomethane Certificates

* Gaseous fuels along the gas grid

* Liquid fuels and off-grid volumes along the respective supply chain
LOCAL GRID
Injection Withdrawal
Metering Point Metering Point
END CONSUMER
* Local grid

RENEWABLE DSOs, TSOs, gas grid managers, balance group coordinators

PRODUCT
Physical Transfer
Gas Flow

Transfer of intrinsic, green value

Certificate Flow

Biogas Plant TSO, DSO

(anaerobic digestion) & BGC
Data Delivery

Producer REGISTRY SYSTEM Consumer

Renewable Renewable
Product • Transparent, secure, reliable documentation Product
• Data security, clear manual and rule book
• Versatile and flexible
Biomethane • Traceability of intrinsic value Biomethane
Certificate (quantitative, qualitative data) Certificate

• Documentation of mass balance

• Documentation of sustainability criteria
Auditor • Application for difference marketing pathways
Data Delivery

Sample Cancellation Statement

8
 17/11/2022

Chain of Custody for Transport Fuels

Closing the mass balance
Chain of Custody: Biomethane in the transport sector
Chains of custody of liquid biofuels
and biomethane in transport
Gas Grid
Part I - congruent in both cases - covers
the mass balance of substrate to the
biorefinery plant, tracked by a recognised
elNA electronic
 reliable sustainability certificate voluntary scheme (e.g.: ISCC, REDcert).
Part I: Mass balance of substrate to by UBA
 transparent
Part I

biorefinery plant Part II covers the chain of custody from

 trustworthy
according to recognised voluntary scheme
(e.g.: ISCC, REDcert, etc) Biomethane
 mass balance Accountable for target compliance, the biomethane plant (biorefinery) to
 sustainability RED II Art 25-30
certificate
the fuelling station, tracked by a
national registry on national level or a
Part II

* Mass balance of renewable gas from biorefinery to fuelling station along the gas grid
 National grid: domestic registry recognised voluntary scheme on EU-level
 European grid: according to recognised voluntary scheme (ERGaR RED MB scheme) (e.g.: ERGaR RED MB scheme).

Biomethane Certificates, created by a

domestic Biomethane Registry are an
Chain of Custody: Liquid Biofuels in the transport sector eligible instrument to track the
movement of the green value of the
renewable gas along the gas grid.
It is important that the biomethane
consumed in the transport sector is
accounted towards national and
* Mass balance Mass balance from substrate elNA electronic international targets, performed by the
to fuelling station sustainability certificate Austrian Environmental Agency in Austria,
according to recognised voluntary scheme by UBA
(e.g.: ISCC, REDcert, etc) which is in active collaboration with the
Accountable for target compliance,
Biomethane Registry Austria.
AT: KVO; EU: FQD, RED II Art 25-30
9

Documentation of withdrawal
Purchase records

• Several options of documenting the physical withdrawal exist in the European gas market:

• Country Level statistic: volume of cancelled renewable gas certificates are accounted if within total
gas consumption of country

• Balance Group level: volume of cancelled renewable gas certificates are accounted if within total gas consumption of
corresponding balance group

• Supplier level: volume of cancelled renewable gas certificates are accounted if within total gas consumption of
corresponding supplier consumption

• Metering point level: volume of cancelled renewable gas certificates are accounted if gas metering reading match
final consumption

10

10
 17/11/2022

Challenges of renewable gas cross-border transfer

Transfer options

• Methods of transfer:
• Book and Claim: pure transfer of certificates between two entities (cancellation at exporting side, creation on
importing side)
• Hubs can simplify transaction between several participants (possible options: ERGaR; AIB)

• Mass Balance: documentation from injection to withdrawal

• Lack of European definition allow for interpretation
• Documentation of injection and withdrawal using “one logistical facility” the interconnected
European gas grid
• Documentation of injection and withdrawal plus cross-border capacity booking
• Documentation of each transaction from injection to withdrawal

• Limitations:
• Accounting Period: The accountability of certificates depend on the application purpose.
• Validity Period: The validity period of certificates vary per application purpose.
• Hybrid Model: Certificates may have no validity period because they can be accounted for a specific period only.

11

11

Challenges of renewable gas cross-border transfer

Transfer platforms

• Three different European platforms exist for transferring renewable gas volumes
• ERGaR: established in 2016 and operational; private initiative
• AIB: established for electricity GoO transfer and extended to renewable gases; private initiative
• Union wide database: to be established for renewable transport fuels; EU initiative

• Each European platform support different application types of renewable gases

• Voluntary markets
• GoO – Guarantees of Origin
• Transport fuels

• Harmonisation of certificates, registries and transfer processes (Scheme) mandatory to accomplish cross-
border transfers
• Different approach/requirements for each application purposes
• Inclusion in national statistics outstanding
• Statistical transfer (REDII Article 8) as major future target

12

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 17/11/2022

Introducing ERGaR
Established in 2016 as non-profit organisation

13

13

Introducing ERGaR
ERGaR Schemes

14

14
 17/11/2022

Functionalities
functioning of ERGaR-Hub

ERGaR-hub as a central, Europe-wide platform solution

• Connection between biomethane registries
• Single and central interface for biomethane registries
• Replaces bi- and trilateral agreements
• Facilitates connection between multiple registers
• Facilitates establishment of new registers

• RED II conformity!
• Function: mass balancing of biomethane distributed along the
European natural gas network with transfer of related
sustainability certification

• Legend: * mass balancing with appropriate documentation

is the optimum solution to track renewable fuel in the natural
gas system:
o Clearing data of clearing agents
o Injection and withdrawal metering data of grid operators
o Auditing
o Other recognised systems

15

15

ERGaR’s Mass Balancing Function

16

16
 17/11/2022

Challenge Austria and abroad

3 registries in Austria
3 European platforms
Different biomethane attributes
Different Mass Balance Requirements

Union wide
database

Recommendation REGATRACE project:

“Establish one central registry per
Member State for all national and
European documentation purposes,
covering all types of renewable gases with
different certificate attributes”

17

17

Statistical Transfer
The ultimate goal

• Market Participants require European rules on how to practically document renewable gas movements between countries
allowing for statistical transfer.

• Otherwise transfers will be mostly for “trading purposes” not including its intrinsic value (CO2 mitigation potential).

• Statistical Transfer according to REDII Art. 8 require standardised processes accepted by Member States,

• European platforms should be considered as integral part for statistical transfers instead of bilateral agreements between
Member States; if they fulfil MRR requirements and are acknowledged by European institutions

• Possibility of platform as recognized Voluntary Scheme such as ISCC or RED Cert!

18

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 17/11/2022

ISO:
Datum PV Erstellt v. Freigabe Version
29.10.2015 BH BH QMB V01.00

Contact
AGCS Gas Clearing & Settlement AG
AGCS Biomethan Register Austria
www.agcs.at www.biomethanregister.at
LinkedIn [email protected]

Project Management
Julian Auderieth, Stefanie Königsberger, Andreas Wolf

Operative Implementation
Sarah Piza, Stefan Thaller

19
 17/11/2022

EU ETS Monitoring and Reporting – CF Training event

Training Event on Biomass No. 2

[email protected] 27 October 2022

The biomass fraction

Activity data (t, m³ or TJ) Oxidation factor

𝐸𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠 = 𝐴𝐷 𝐸𝐹 𝑂𝐹 Biomass
fraction

𝐸𝐹 = 𝐸𝐹 (1 − 𝐵𝐹)
Emission
factor ‘Preliminary’ emission factor
(i.e. fossil + biomass carbon)
• Source stream 100% fossil  BF = 0
• Source stream 100% biomass fulfilling RED II criteria  BF = 1
• BF to be determined for mixed fuels or materials
2

2
 17/11/2022

Biomass fraction: required tiers

Absolute minimum tier
Minimum tier
(technically not feasible or If not at
Installation (tier required technically not
Source stream category Tier required unreasonable costs for least tier 1
category feasible
transitional period to be agreed is possible
or unreasonable costs)
with the CA)

Tier 3 Tier 2 Tier 1

Major
(analyse biomass fraction) (estimation methods) (default values) Fall-back
Tier 3 Tier 1 approach
Cat. B or C Minor n.a.
(analyse biomass fraction) (default values)
de-minimis or
conservative estimates unless tier is achievable without additional effort n.a.
>97% biomass
Tier 1
Major
(default values) Fall-back
n.a.
Cat. A Tier 1 approach
(≤ 50 kt) Minor
(default values)
de-minimis or
conservative estimates unless tier is achievable without additional effort n.a.
>97% biomass

General rules for applicable tiers

• Categorisations in MRR Article 19:
• Installations: “with the exclusion of CO2 stemming from biomass”
• Source streams: “fossil CO2 per year“
Source stream
Price = 20€/t emissions
• Provisions for unreasonable costs
Benefit  P  AEm  IF
• MRR Articles 18(2) and 38(5) apply
Improvement
“provided that the relevant information … is available to the operator” factor = 1%

Thereby, the MRR provides for simplified assumption “RED II criteria complied
with” for categorisation and unreasonable costs (AEm: biomass rated zero)

IMPORTANT! If RED II criteria finally not satisfied for Annual Emissions Report
 risk for operator of non-compliance (required tiers not met)
4

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 17/11/2022

Tier 3: Analysis
• Article 39(2): use relevant standard and the analytical methods, provided
the use of the latter is approved by the CA
• Common standard: EN 15440 (“Solid recovered fuels – Methods for the determination of biomass)
• The selective dissolution method (recommended for routine checks by RED II)
• must not be applied if materials listed in Table 1 of GD3 are contained at above 5% threshold
• The manual sorting method (recommended for routine checks by RED II)
• only applicable for optically and physically distinguishable fractions (particle size >10mm)
• The 14C method: most reliable (reference method), but also most expensive

• Further standard for e.g. liquid fuels: EN 16640

(“Bio-based products – Bio-based carbon content – Determination of the bio-based carbon content using the radiocarbon method”)

Tier 2: Estimation methods

• Operator to propose an estimation method for the approval by the CA:
• Mass balance where the material is originating from a known production process
• e.g. wood-based panel wastes, where the amount of (fossil) resins added is known
• Mass balance as used under Article 30(1) of the RED II will also serve this purpose
• “Balance method”: based on five mass balances and one energy balance. Each
balance describes a certain waste characteristic (e.g. carbon content, heating value)
• Commission may provide guidelines for further applicable estimation methods
 none published at the moment

Recommendation: for not-yet proven methods, confirm validity by applying

corroborative methods (e.g. analyses) at the beginning.

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 17/11/2022

Tier 1: Default values

• Published by the CA
• Published by the Commission  none available yet
• Other default values in accordance with Art. 31(1):

• national inventory values, analyses in the past and still representative, etc.

• i.e. methods which usually correspond to tiers 1 and 2a/2b for e.g. NCV, EF

Recommendations:
• CA to publish default values, where appropriate and useful
(best case: consistent with national inventories, equivalent to “Tier 2a” for e.g. EF)
• Collect published default values and consider publication by the Commission
(EU-wide applicability)
7

CO2

CEMS: General background

CEMS
QAL1 QAL2 QAL3 AST
flue gas
Before
Installation and Starting one year
When? installation of During operation
calibration after QAL2
the CEMS
Typically between
At least every five
Frequency Once once per week and Annually
years
once per month

Instrument Accredited Accredited

Who? Operator
manufacturer laboratory laboratory

EN 14181,
EN ISO 14956, EN 14181, EN 14181,
Relevant standards EN 14181
EN 15267-1, -2 EN 15259 EN 15259
and -3
Determination of Suitable mass balance or  See GD7 for
flue gas flow CEMS (EN 16911-2) further guidance
8

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 17/11/2022

Biomass and CEMS

• MRR Article 43(4) allows to subtract biomass emissions via:
a) Calculation-based approaches:
• Based on source streams (input-based; only method applicable in phase 3)
• “Continuous sampling” from the flue gas (not continuous measurement):
EN ISO 13833 (“Stationary source emissions – Determination of the ratio of biomass (biogenic) and
fossil-derived carbon dioxide – Radiocarbon sampling and determination”)
b) The “balance method”, which is an estimation method in MRR terminology
(based on ISO 18466 “Stationary source emissions – Determination of the biogenic fraction in CO in stack 2

gas using the balance method”)

c) Estimation methods published by the Commission  none published yet

• Article 46 requires corroboration with calculation-based approaches

• RED II criteria apply in order to rate biomass zero and subtract
9

Thank you for your attention

Consultant core team contacts:

[email protected] (lead on biomass topics)
[email protected] (project lead)
[email protected]
[email protected]

Commission contact:
© European Union 2021 [email protected]

Unless otherwise noted the reuse of this presentation is authorised under the CC BY 4.0 license. For any use or reproduction of elements that are
10owned by the EU, permission may need to be sought directly from the respective right holders.
not

10
 17/11/2022

EU ETS Monitoring and Reporting – CF Training event

MRR requirements on biofuels

(Aviation)

[email protected] 27 October 2022

[email protected]

Mentimeter
• Your level of experience with EU ETS?

2
 17/11/2022

Guidance document 3
Guidance document 3 – “Biomass issues in the EU
ETS” has been published:
https://climate.ec.europa.eu/system/files/2022-
10/gd3_biomass_issues_en.pdf

Next step:
• GD2 for aircraft operators will be updated with GD3
content to make it a self-standing document again

Definitions
• ‘biofuels’ means liquid fuels for transport produced from biomass;
• ‘bioliquids’ means liquid fuel for energy purposes other than for transport,
including electricity and heating and cooling, produced from biomass;
• (For other definitions see presentation on biogas) Not relevant
for aviation

Only liquid fuels are currently used for aviation. The focus for this training
event lies on liquid fuels.
GD 3: Liquid biomass is referred to as “biofuel”, as it is relevant for transport
purposes!

4
 17/11/2022

Monitoring Reporting Regulation

• Article 38 “Biomass source streams” Only relevant for biofuels

• Biomass emissions from combustion can be zero rated if:

• Sustainability criteria are fulfilled  Article 29 (2-7) of Directive (EU) 2018/2001 (RED II)
NEW:
Art. AND
38(5)
MRR • GHG saving criteria are fulfilled  Article 29 (10) of Directive (EU) 2018/2001 (RED II)

• Biofuels produced from waste and residues are required to fulfil only GHG
saving criteria, not the sustainability criteria
• However residues from agricultural, aquaculture, fisheries and forestry have to fulfil both,
sustainability and GHG saving criteria
5

RED II Article 29
• Article 29 Paragraph 2 to 7
• (2) Biofuels, etc. shall be taken into account only where operators or national authorities have
monitoring or management plans in place in order to address the impacts on soil quality and soil
carbon

• (3) Biofuels, etc. shall not be made from raw material obtained from land with a high biodiversity
value

• (4) Biofuels, etc. shall not be made from raw material obtained from land with high-carbon stock

• (5) Biofuels, etc. shall not be made from raw material obtained from land that was peatland

• (6) and (7) Biofuels, etc. produced from forest biomass shall meet the specified criteria to minimize
the risk of using forest biomass derived from unsustainable production

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RED II Article 29(10) – GHG savings criteria

• For biofuels, biogas consumed in the transport sector and bioliquids, savings must be
• at least 50% if produced in installations in operation before 5 October 2015,

• at least 60% for installations starting operation until 31 December 2020,

• at least 65% for installations starting operation from 1 January 2021.

• For biomass fuels (i.e. solid and gaseous biomass) consumed in EU ETS installations, GHG
savings must be
• at least 70% in installations starting operation from 1 January 2021 until 31 December 2025,

• 80% for installations starting operation from 1 January 2026.

• Savings relate to life cycle emissions compared vs. a given fossil comparator.

Alignment of EU ETS and RED II

• MRR Article 38(5) has to be applied from 1st January 2022
• New amendment: “… Member States, or competent authorities as
appropriate, may consider as fulfilled the sustainability and greenhouse gas
emissions saving criteria referred to in that paragraph for biofuels, bioliquids
and biomass fuels used for combustion from 1 January 2022 to 31 December
2022

In most Member States, RED II criteria have to be applied by aircraft

operators only from 1 January 2023 (as to be reported in 2024).

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RED II: Source streams-biofuels

• Pure fossil source streams – no RED II criteria apply
• Pure biofuels where sustainability and/or GHG savings criteria apply
• Pure biofuels where RED II criteria do not apply Biofuel mix or fossil / biofuel
mix, where RED II criteria
• Mixed source streams apply and only a part of the
biomass satisfies the
applicable RED II criteria:
Fossil / biofuels mix where either RED
treat it like the first example
II criteria do not apply, or where they Fossil / biofuel mix with the non-sustainable part
apply and are satisfied: EF is the where RED II criteria considered as part of the
preliminary EF multiplied by the fossil apply and are not fossil fraction
fraction satisfied: Treat whole
source stream as fossil
9

CORSIA Eligible Fuels

• CORSIA eligible fuels: https://www.icao.int/environmental-
protection/CORSIA/Pages/CORSIA-Eligible-Fuels.aspx
• Sustainable Aviation Fuel (SAF): “A renewable or waste-derived aviation fuel that meets
SARPS
Annex 16
the CORSIA Sustainability Criteria under this Volume”
Vol. IV
• CORSIA lower carbon aviation fuels: „A fossil-based aviation fuel that meets the CORSIA
Sustainability Criteria under this Volume“

• CORSIA eligible fuels are not known in the EU ETS legislation

• So far not relevant for European aircraft operators
• Full implementation of CORSIA in the EU ETS Directive is currently under
discussion in the “Fit for 55” package
10

10
 17/11/2022

Differences EU ETS - CORSIA

EU ETS CORSIA
Regulated fuels Biofuels (carbon from a biomass source) Sustainable aviation fuel. An aviation
alternative fuel that meets the CORSIA
Sustainability Criteria under the SARPs
Reporting If RED II criteria are met, Emission Life cycle GHG emissions savings are
approach Factor = 0 deducted from emissions

Eligibility criteria Sustainability and GHG savings criteria Document “CORSIA Sustainability
(>50/60/65%) of RED II Criteria for Sustainable Aviation Fuels”
GHG savings >10% and sustainability
criteria (quite different)
Certification (Recognised) RED II certification Document: CORSIA Approved
schemes Sustainability Certification Schemes

Requirements for Implementing act under Art. 30(8) of Document “CORSIA Eligibility
certification RED II Framework and Requirements for
schemes
11
Sustainability Certification Schemes”

11

RED II: Which criteria apply for aviation?

Start for Need to
biomass Mixed determine
Is X a mixed material
source stream or only biomass? biomass
X 1 fraction

Biomass

Is X used for No
energy purpose?
2
Yes

Yes
Is X Solid Municipal
Waste?
3
No

Yes Agricultural or
forestry biomass?
12 4

No

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 17/11/2022

Yes
No

Assess sustainability
criteria
5 Evidence under national or
voluntary scheme available?
If no, make own assessment

Assessed Yes
Criteria complied Liquid (biomass fuel)
6 with? 7

No Liquid

Assess GHG savings

9 Evidence under national or

voluntary scheme available?
If no, make own assessment

Treat as fossil Assume EF = 0

No GHG saving Yes
fuel (use For the
13 criteria met?
preliminary biomass
EF) 10 fraction

13

RED II: Which criteria apply for aviation?

• Step 1: Source stream consists exclusively of biomass, or whether it is mixed
with a fossil fraction? Possibility to apply an emission factor of zero applies
only to the biomass fraction of the source stream.
• Step 2: Source stream is used for energy purposes? If the answer is yes the
following steps are needed. (No: assume EF=0)
• Step 3: If the source stream is municipal solid waste, no further criteria
need to be taken into account. The biomass fraction may be zero-rated.

14

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 17/11/2022

RED II: Which criteria apply for aviation?

• Step 4: Determine if the source stream is any type of forest or agricultural
biomass, or “(produced from) residues from agriculture, aquaculture,
fisheries or forestry”, as for such source streams the “land-related”
sustainability criteria (Article 29(2) to (7) of RED II) apply. For other residues
or waste (including all kinds of industrial wastes, if containing biomass), only
GHG savings criteria need to be complied with. For biomass stemming
from animal wastes and residues from aquaculture and fisheries, Article
29 of the RED II does not list specific land-related sustainability criteria.
Operators will have to determine only GHG savings based in the
calculation methodologies outlined in Annex V and VI of the RED II
(therefore go to step 7)

15

15

RED II: Which criteria apply for aviation?

• Step 5: Depending on step 4, the (land-related) sustainability criteria for
the production of biofuels, bioliquids or biomass fuel are to be
assessed. The operator can rely on the certification of the used material/fuel
under a national system or an (international) voluntary scheme
recognised by the Commission or the installation’s (or aircraft operator’s)
Member State. If no proof of sustainability under a certification scheme is
available to the operator, the operator would have to perform the assessment
of the relevant criteria himself, and get the verifier’s confirmation.
• Step 6: If the previous step shows that relevant sustainability criteria are
not complied with, then the operator has to treat the material as if it were
fossil, (preliminary emission factor becomes the emission factor).

16

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 17/11/2022

RED II: Which criteria apply for aviation?

• Step 7: If the source stream is liquid, the assessment of GHG savings is
mandatory. Go to step 9.
• Step 8: As the additional requirement for “biomass fuels”, i.e. solid or gaseous
biomass, applies only to installations starting operation from 1 January 2021,
older installations (more exactly: installations which used biomass already
before 2021) do not have to carry out further assessment.
• Step 9: According to Article 29(10) of the RED II, required GHG savings
have to be calculated in accordance with Article 31(1) of the RED II.
• If the GHG savings are above the applicable threshold, the biomass can
be zero-rated, otherwise it has to be treated as if it were fossil.
17

17

Beekast – experience with biofuels

• Please follow link given in chat and answer the multiple-choice questions:
• How many of “your” aircraft operator thought about using biofuels?
• How many of “your” aircraft operators actually reported biofuels?

18

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 17/11/2022

RED II: Demonstrate compliance

• Demonstrate compliance with the sustainability and GHG savings criteria for
biofuels, bioliquids and biomass fuels: Biofuels are
relevant for
• National systems aviation

• Voluntary national or international schemes that the MS accepts

• By providing all relevant evidence and GHG calculations themselves, having the
information appropriately audited (if accepted by MS)

For zero-rating biomass under the EU ETS MRV rules, the burden of proof
concerning a biofuel, bioliquid or biomass fuel meeting the requisite
sustainability and/or GHG savings criteria remains with the EU ETS operator
19 or aircraft operator!

19

National systems I
• Currently partly still under development
• No complete overview available of Member States’ national systems on
providing evidence of biomass sustainability and GHG savings available.
Operators and aircraft operators should obtain information on national
systems from the relevant competent authority.
• The RED II does not explicitly require a Member State to publish dedicated
information. However, it is considered best practice to provide transparent
information to operators.

20

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 17/11/2022

National systems II Art. 30 (6) RED II

• Possibility to notify a national scheme to the Commission for recognition. The

relevant information will be published on the Commission website, and all
other Member States are required to accept the resulting certificates. (like it is
the case of voluntary international schemes recognised by the Commission)

However, the use of international voluntary systems may be desirable in

many cases where the biofuel, bioliquid or biomass fuel is not used in the
Member State where it is produced!

21

21

Voluntary schemes I
• Regarding schemes not (yet) recognised by the Commission, Member States
may accept those schemes, if they come to their own conclusion that the
scheme ensures compliance of the biomass with RED II criteria. (same
conditions for schemes approved under RED I)
• Member States specific provisions (e.g. allowing only schemes that have
been recognised by the Commission)
• Operators will always have to check with their competent authority or national
legislation how to provide evidence that the biomass used complies with the
RED II criteria. (exception: using schemes recognised by the Commission)
• Biofuel, bioliquid or biomass fuel certified under a scheme recognized by the
Commission have to be recognised as sustainable in all Member States.
22

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 17/11/2022

Voluntary schemes II
• Proof of sustainability (=declaration of compliance with the scheme) issued by an economic
operator certified under a recognised voluntary scheme means that the emission factor can
be zero-rated in the EU ETS.
• Limitations:
• Voluntary scheme may be approved only for some fuel types, some of the required criteria, or only
regarding some steps of the value chain
• GHG savings criterion depends on transport distance  required for each site where the biomass
is used
• Some sustainability schemes cover a wider scope  use only certificates which explicitly refer to
those “EU RED II compliant versions” of the voluntary schemes
• Some schemes are recognised with limited geographical scope
• The Commission’s recognitions of voluntary schemes are usually valid for five years

23

23

Voluntary schemes III

• Details on all voluntary schemes recognised systems approved by the
Commission can be found here:
https://energy.ec.europa.eu/topics/renewable-energy/bioenergy/voluntary-
schemes_en

24

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 17/11/2022

How do RED II certification schemes

work?

25

25

Biofuel determination by aircraft operators

• Where batches of biofuels are physically delivered directly to the aircraft, the
aircraft operator can determine the biomass fraction by laboratory analyses,
or by using a mass balance Art. 54 (2) MRR

• However, much more likely: biofuel batches are not physically delivered to a
specific aircraft, but to the airport tank system
• To handle this situation, aircraft operators are allowed to determine the
quantity of biofuels used based on purchase records if they can provide
evidence to the competent authority that there is no double counting of
those biofuels. Art. 54 (3) MRR

26

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 17/11/2022

Biofuel determination based on purchase

records
Art. 54 (3) MRR
• How to “…provide evidence to the competent authority that there is no
double counting of the same biofuel quantity, in particular that the
biofuel purchased is not claimed to be used by anyone else”?
• According to RED II, biofuels are tracked by a mass-balance. This is done in
national registries, which also trace the information on proofs of sustainability.
Every consignment of biofuel can be consumed only once.
• Union database: set up by the Commission for tracing liquid and gaseous
transport fuels. Currently under development. Art. 28 (2) RED II

• When the Union database is fully operational, purchasing a “certified biofuel”

will automatically be tracked by the Union database (including trans-border
transactions)  Aircraft operator does not have to worry
27

27

Thank you for your attention

Consultant core team contacts:

[email protected] (lead on biomass topics)
[email protected] (project lead)
[email protected]
[email protected]

Commission contact:
© European Union 2021 [email protected]

Unless otherwise noted the reuse of this presentation is authorised under the CC BY 4.0 license. For any use or reproduction of elements that are
28owned by the EU, permission may need to be sought directly from the respective right holders.
not

28
 17/11/2022

Biomass in EU ETS
VERIFICATION REQUIREMENTS

Training Event on Biomass

Machtelt Oudenes 27 October 2022

Agenda
• Key MRR requirements and impact on verification

• What verifier needs to consider during verification

• What evidence an operator must provide to the verifier related to biomass

• What checks the verifier must carry out as part of process analysis

• Role of the EU ETS verifier and RED II auditor

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 17/11/2022

Impact MRR biomass rules on verification

• New Article 38(5) MRR aligns application of biomass rules with the RED II
 Biomass can only be zero rated in EU ETS if sustainability and GHG savings criteria in
Article 29 (2) to (7) and (10) REDII do not apply or if applicable criteria have been met

• Some biomass related concepts are similar to phase 3 rules:

 How to assess completeness of source streams
 How to check control activities and procedures used in the monitoring of biomass
 The type of checks carried out on data and methodology (e.g. plausibility, cross checks)

• Other concepts are new for phase 4

 Strengthened rules on sustainability criteria and GHG savings (REDII) criteria
 New rules on monitoring and specific issues such as waste and injection of biogas in grid

Elements a verifier needs to consider

• The type of biomass source stream (100%, 97% or higher, less than 97%)
 The methodology is more complex with mixed source streams with less than 97%
biomass  a preliminary EF is applied.

• Applicability of, and compliance with REDII criteria

 Whether or not the operator can zero rate emissions has impact on accuracy of data.
 It is therefore important for the verifier to check whether REDII criteria are applicable
and, if yes, whether REDII criteria have been met.

• Heterogeneity and composition of different batches of biomass

 The verifier needs to be aware that there can be differences between batches: e.g. for
one batch biomass criteria have been met whereas for the other batch these criteria
have not been complied with.

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 17/11/2022

Elements a verifier needs to consider

• Complexity of the biomass chain from harvesting to fuel consumption
 The evidence of sustainability must cover the whole biomass chain and the verifier needs
to be aware of any limitations in scope and quality of evidence the operator provides.

• The approach used to demonstrate compliance with REDII criteria

 The evidence and checks of verifier differ if a voluntary national/ international recognized
scheme is used, a national scheme established by the MS or if the operator provides all
necessary evidence and GHG calculations itself.

• The monitoring methodology applied to determine biomass fraction

• Applicability of waste, injection of biogas in grid and applicable method,
whether fossil and biomass materials are used in the same process

Impact on steps in verification process

• Elements play a role in the allocation of time in pre-contract stage, strategic
analysis and risk analysis which in turn impacts verification planning & checks

• Mixed source streams

More detailed
• Multiple batches with varying checks on high
composition Inherent &
risk areas
control risks
• Sampling/analysis biomass can increase
fraction
• Missing evidence in biomass chain
• Use of waste
• Operator’s own evidence vs Increased risks means more verification effort and
evidence through COM voluntary more time needed for verification
scheme

6
 17/11/2022

Biomass related evidence from operator

• In order to assess the accuracy of biomass related data and compliance with
MP and MRR, the verifier needs information from operator (Art. 10 AVR):
 Monitoring plan and supporting documentation;
 Evidence on compliance with REDII criteria which depends on how operator demonstrates
compliance with REDII criteria.
 Two types of evidence: certification and proof of sustainability;
 Additional evidence applies when national schemes or operator’s own evidence is
used to demonstrate compliance with REDII criteria.

• Verifier needs to determine at various stages what evidence is needed and

whether it is sufficient.
• Verifiers should start early to early identify what evidence is missing and what
follow-up action is needed.

Verifier’s checks on biomass related issues

As part of the process analysis the verifier will perform checks on MP,
application of methods & rules and accuracy of data.
Issue Examples of checks
Source stream The verifier will check completeness and description of source streams:
• are all biomass source streams included in MP?
• what type of biomass is used and does that reflect actual situation?
• are source streams correctly delineated/classified in line with MP & MRR?
• are batches of biomass the same source or different source streams and
is that applied consistently?
Monitoring of biomass The verifier will perform similar checks as for other types of monitoring
methodologies:
• is the monitoring methodology applied in line with MP?
• checks on sampling & analysis activities and evidence of accredited/non –
accredited labs

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 17/11/2022

Verifier’s checks on biomass

Issue Example of checks
Applicability of REDII The verifier checks:
criteria • evidence provided on the nature of biomass source streams to assess
applicability of REDII criteria;
• whether evidence of compliance with REDII criteria is correctly attributed to
different batches of biomass;
• procedures that monitor the batches of biofuels and specify which criteria
are applicable.
Compliance with REDII The REDII auditor will have already performed REDII audit. The approach
criteria via approaches used to demonstrate compliance with criteria determines:
1. voluntary (CION • the extent to which the verifier can rely on scheme’s certificates and
recognised) scheme audited information;
2. national scheme • the checks that the EU ETS verifier carries out on the schemes,
3. operator’s self evidence certificates, declarations and evidence.

Verifier’s checks on biomass

Issue Example of checks
Biomass related The verifier checks whether the procedure
procedures • is established, properly documented and maintained;
described in MP
• contains the information recorded as described in the approved MP and MRR;
• has been correctly implemented and is up to date;
• is applied throughout the reporting year;
• is effective to mitigate the inherent and control risks.
Specific issues The CA will have approved in MP whether fuel/material is waste. The verifier will check
on waste whether the classification is in line with approved MP. However, the verifier can still
comment if it identifies the fuel/material as described in MP is not considered waste.
Specific issues The verifier will check whether
on biogas • the applied monitoring methodology is in line with approved MP;
• there is double counting of the same biogas quantity and the operator and biogas
producers are connected to the same grid;
• RED II criteria are complied with (data in biogas registry or other evidence provided
by operator).

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 17/11/2022

EU ETS verifier’s competence

• To be able to assess biomass related issues in EU ETS verification, the
verifier needs to have a knowledge of biomass requirements:
 Relevant legislation: Art 38, 39, 43, 54 MRR, REDII and Implementing Regulations;
 Applicable national legislation that may impose additional requirements;
 MRR GD 3 on biomass and MRR GD2 on use of biofuels in aviation;
 Updated KGN II.3 which explains in detail what verifiers need to consider and check;
 Updated GD III on verification in EU ETS Aviation which will explain the role of the
verifier in assessing accuracy of data and compliance with rules if biofuels are used.

REDII audit is NOT EU ETS verification and requires

other specific competence requirements.

11

Role of REDII auditor vs EU ETS verifier

RED II auditor EU ETS verifier

Ex ante audit with specific rules Ex post verification based on AVR

Objective /

The auditor assesses: The verifier assesses:

type

• processes of economic operator • compliance with MP/MRR

• ability to manage compliance with criteria • accuracy of emission data

ISO 19011 or equivalent standard

Verification according to AVR & ISO 14065
ISO 14065 (audit GHG Values)
Competence
Standards/

ISO 17065 accreditation

AVR & ISO 14065 accreditation
ISO 14065 (GHG values)

Experience and knowledge REDII audit/

EU ETS knowledge: Article 38 – 40 AVR
REDII Criteria/ technical knowledge

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 17/11/2022

Can EU ETS verifier carry out REDII audit?

• The EU ETS verifier has to meet the required competencies that apply to
REDII audit (requirements from the Implementing Regulation 2022/996);
• There shall be no conflict of interest;
• Accreditation according to ISO 17065 and ISO 14065 or, if a national scheme
is involved, the required qualifications in MS law.

REDII audit is a separate audit requiring a separate risk analysis, verification

activities & reporting.

13

Next steps
• KGN II.3 is being updated to provide guidance on the role of EU ETS verifier
in assessing biomass related issues in EU ETS verification
 Minor changes compared to first draft
 Some additional clarification may be included as a result of the training
 A final version will be available soon
• GD III on verification of EU ETS aviation will be updated to clarify the role of
EU ETS verifier in assessing biofuel requirements in EU ETS verifications
 Close alignment with MRR guidance 2 on MRR aviation
 Update expected End 2022/ January 2023

14
 17/11/2022

Thank you for your attention

Consultant core team contacts:

[email protected]
[email protected] (project lead)
[email protected]
[email protected]

Commission contact:
© European Union 2021
[email protected]

Unless otherwise noted the reuse of this presentation is authorised under the CC BY 4.0 license. For any use or reproduction of elements that are
15owned by the EU, permission may need to be sought directly from the respective right holders.
not

15
 17/11/2022

Verification of biomass issues in ETS

What the verifier should be looking for when presented

with evidence from a national or international voluntary
scheme/ national schemes
Training Event on Biomass
Sven Starckx 27 October 2022

Biomass
Key Requirements

- A key amendment of the MRR is the addition of Article 38(5) which aligns the application of
biomass requirements with the RED II Directive.
Biofuels, bioliquids and biomass fuels used for combustion in EU ETS installations or by aircraft
operators have to meet sustainability and GHG savings criteria laid down in Articles 29 (2) to (7)
and (10) of the RED II Directive in order to apply an emission factor of zero.

Sustainability and/or GHG

The compliance with the criteria laid savings criteria (REDII criteria)
down in paragraphs 2 to 7 and 10 of are not applicable in all
Article 29 of Directive (EU) 2018/2001 situations.
shall be assessed in accordance with
Articles 30 and 31(1) of that Directive.

2
 17/11/2022

Verification of biomass-related
issues
When preparing for verification
in the pre-contract stage, the
strategic analysis and risk
Elements to consider analysis these factors should be
taken into account.

- Several types of biomass source streams: i.e. 100% biomass (which comply with REDII criteria or to which
REDII is not applicable), mixed source streams etc.
- Different monitoring requirements may apply to each of these types of source streams
- Biomass is heterogeneous and different batches may have other composition
- Member States decision (compliance RED II)
- Chain can be complex / evidence may not cover the whole chain
- Approach used by operator to demonstrate compliance REDII criteria
- Which monitoring methodology to determine biomass fraction (if applicable) and the preliminary EF
- Whether waste is used, biogas
- Co-processing (use of fossil and biomass materials in the same process)
- Number of batches
- ….

Impact on time allocation ETS

verification

Terminology:
REDII criteria apply Certification

Verification of compliance with sustainability and GHG savings criteria

Art.30 and 31(1)

- A Voluntary national or International scheme that is accepted by the Member State. If this scheme is
also formally recognised by the Commission, certificates and proofs of sustainability issued to economic
operators by the scheme must be accepted in every Member State
- A National scheme established by the Member State. MS legislation will regulate what evidence is
required for demonstrating compliance with the criteria Art.29 (2) to (7) and (10);
- The operator provides all necessary evidence and GHG calculations and this information is audited (if
accepted by a MS)
- Voluntary Scheme: economic operator has received a valid certification from a certification
body in line with Implementing Regulation 2022/996 (rules to verify sustainability and GHG
savings criteria and low indirect land use change-risk criteria) and is capable of issuing ‘proofs
of sustainability’
- National Scheme: the type of evidence is dependent on the individual national scheme and
national rules. This could be a certificate, statement of sustainability or other documentation
that proves compliance with RED II criteria.

4
 17/11/2022

Verification of biomass-related issues

Economic
Operator
Compliance with REDII criteria
(supplier)
- Annex I of the MRR requires the operator, if
applicable to include in the MP a description
Certificate of
Voluntary or
system’s
of a written procedure to assess whether
national Certification
scheme conformance to biomass sources streams comply with the
audit &
(recognised surveillance scheme requirements of MRR Art.38(5)
for RED II) requirements

- Often the ETS operator or aircraft operator will

‘Proof of rely on data and information provided by third
sustainability’ parties (i.e. supplier or producer of the
per batch biomass)
ETS delivered
verification Be Aware:
Biomass certification schemes under RED II can cover different parts of the supply chain,
and ’economic operators’ are often certified for only part of the supply chain.
For EU ETS the burden of proof is on the user of the biomass (the ETS operator or aircraft
ETS Operator operator).
(consumer)

Verification of biomass-related ETS verifier attention

issues (certificate):
- Scope of certification ?
- Validity of certificate ?
“Certificate” vs “Proof of Sustainability” - Explicit Reference to RED II?
-Suspension EO/CB?

- A certificate certifies that an economic operator complies with the rules of the certification scheme.
- The Proof of Sustainability is issued by the economic operator for confirming that a certain consignment
of biomass material, biofuel, biogas or biomass fuel fulfils the sustainability or GHG savings criteria

National Scheme:
ETS verifier attention PoS: Evidence could be a certificate,
(Voluntary Scheme) statement of sustainability of other
Proof of sustainability for evidence that proves compliance with
each batch available ? sustainability and/or GHG savings
criteria
Full value chain covered ?
In case GHG savings, change
in sourcing plant(s)

6
 17/11/2022

Verification of biomass-related
issues
Example list of certified economic operators

https://energy.ec.europa.eu/topics/rene
wable-energy/bioenergy/voluntary-
schemes_en#approved-voluntary-
schemes-and-national-certification-
schemes

Verification of biomass-related
issues !! A certificate may not cover all types of biomass
or the whole biomass chain of custody (e.g. geographic limitation,..)
Certificates

8
 17/11/2022

Verification of biomass-related PoS

PoS

issues PoS
PoS
PoS
PoS

PoS
Proof of Sustainability
Proof of Sustainability (PoS) for Biofuels, Bioliquids and Biomass fuels V1.1

For Biofuels, Bioliquids and Biomass fuels according to the Renewable Energy Directive (EU) 2018/2001 (RED II)
Use for ETS emissions report
Unique Number of
EU-REDcert-PoS - YYYYMMDD - XXXXXX
Proof of Sustainability:

Place and Date of

city, DD.MM.YYYY
Physical Supply:

Date of Issuance: DD.MM.YYYY

- Source Stream
Supplier Recipient
Name Name
company company

Address Address

- PoS cover full value chain

street street
city city

country country

Certification Scheme: REDcert-EU

- Available each batch Certificate Number

EU-REDcert-XXX-XXXXXXXX

General Information
Contract Number

- Validity certificate/date issuance Type of Product

Type of Raw Material

Additional Information

- Quantities
(optional)
Country of Origin PLEASE SELECT
(of the raw material)

- Applicable sustainability criteria

Mass Balance Option PLEASE SELECT

Quantity m3 mt (metric tons)

Energy content MJ

- In case of GHG savings, transport emissions

Sustainability criteria of the biomass according to Article 29 RED II
1)
The material complies with the sustainability criteria according to Art. 29 (3), (4) and (5) RED II
2)
The sustainability criteria according to Art. 29 (3), (4) and (5) RED II were not taken into account

Greenhouse Gas (GHG) information

Total default value according to RED applied yes no

Eec + El + Ep + Etd + Eu - Esca - Eccs - Eccr = E

+ + + + - - - =

3)
GHG emission saving
for biofuels/biomass fuels (94 gCO2eq/MJ)

In case of electricity and/or heat production

Electrical efficiency (ηel) % Heat efficiency (ηh) %

Fraction of exergy in the electricity (Cel) 100 % Carnot efficiency (Ch) %

3)
GHG emission saving

for bioliquids (for energy installations delivering electricity (183 gCO2eq/MJ))

for bioliquids (for energy installations delivering only heat (80 gCO2eq/MJ))

for bioliquids (for the electricity or mechanical energy coming from energy installations delivering useful heat
together with electricity and/or mechanical energy (183 gCO2eq/MJ))

for bioliquids (for the useful heat coming from energy installations delivering heat
together with electricity and/or mechanical energy (80 gCO2eq/MJ))

The installation where the final biofuels/bioliquids/biomass fuels was produced started physical yes no
production of biofuels/bioliquids/biomass from 6 October 2015 until 31 December 2020
The installation where the final biofuels/bioliquids/biomass fuels was produced started physical yes no
production of biofuels/bioliquids/biomass from 1 January 2021
Note: GHG emission savings shall be at least 50% for biofuels/bioliquids/biomass fuels produced in installations starting operation before 6 October 2015, at least 60% for
biofuels/bioliquids/biomass fuels produced in installations starting operation from 6 October 2015 and at least 65% for biofuels/bioliquids/biomass fuels starting operation
from 1 January 2021.

1)
Applicable for biomass from agricultural, aquaculture, fisheries and forestry including residues from agricultur al, aquaculture, fisheries and forestry residues
2)
Applicable for waste and residues other than agricultur al, aquaculture, fisheries and forestry residues
3)
Saving is calculated automatically based on the fos sil fuel comp arator according to the RED:
(EF – EB)/EF where EB = total emissions from the biofuels/bioliquids/biomass fuels and EF = total emissions from the fossil fuel comparator

© ISCC Sysytem GmbH

Verify
Verify Level of Recognition/validity
Assurance scheme

Check Economic Operator

Verify certification/validity/
Recognition/validity suspension/withdrawel
scheme

Verify Proof of sutainability

Check certification body (PoS) is
/validity/ available/consignment
suspension/withdrawel Deliveries/total delivered
accreditation / scheme Per biomass type

Verify type of biomass full

value chain and REDII Verify data reported
criteria covered or
additional evidence is For GHG savings,
needed transport emissions
included?

10
 17/11/2022

Thank you for your attention

© European Union 2021

Unless otherwise noted the reuse of this presentation is authorised under the CC BY 4.0 license. For any use or reproduction of elements that are
11owned by the EU, permission may need to be sought directly from the respective right holders.
not

11
 17/11/2022

Operator Self-Evidence to
demonstrate RED II criteria compliance
What ETS verifiers should look out for.

Training Event on Biomass

Lucy Candlin 27 October 2022

Focus & assumptions

• Objective – to focus on ETS Verifier’s approach to checking Operator’s ‘self-evidence’ of compliance
(the ‘last resort approach’)
• Presentation assumes that:
• RED II criteria for EU ETS are applicable/have been met
• MS CA allows for ‘self-evidence’ approach & establishes rules for it
• The ETS Operator is providing evidence it has satisfied itself of compliance
• The ETS Operator’s Auditor conforms to national rules on competence, accreditation and audit process
• Presentation looks at:
• What EU ETS Verifiers should look for as evidence from the Operator
• What should be covered by an Operator’s compliance management system and Chain of Custody (CoC)
audit
• The following Regulations are (mostly) relevant:
• Commission implementing Regulation 2022/996 on verification rules
• Commission Regulation (EU) …/... of XXX on establishing operational guidance on the evidence for
demonstrating compliance with the sustainability criteria for forest biomass

2
 17/11/2022

What is Chain of Custody (CoC)?

Adapted from: ISCC EU 203 – Traceability and Chain of Custody Figure 1: Step-by-Step Traceability of Sustainability Characteristics through Sustainability Declarations
Icons from Flatiron (www.flaticon.com/)

Audits required by RED II

Independent auditing to ensure:
• Systems are accurate, reliable and protected against fraud
• Materials are not intentionally modified or discarded so as to become a waste or
residue
• Frequency and methodology for sampling and robustness of data
• Records to support the ‘proofs of sustainability’ issued

Accreditation/approval & competence of Auditors for ‘schemes’ is given in

Regulation 2022/996
National rules apply for audits that are not part of ‘schemes’

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 17/11/2022

Questions for the ETS Verifier to ask itself:

• How has the Operator satisfied itself that each batch of it’s fuels meets RED II criteria?
• Is there evidence of:
• A documented Chain of Custody Management • An Independent audit report on biomass and its CoC, including:
System (is it certified e.g to ISO9001 or
equivalent?) • Auditor competence, qualification & ‘accreditation’

• A CoC Risk Assessment as part of procurement • Scope – full chain back to point of origin & RED II criteria
processes
• Audit protocol/standard applied for:
• A Mass Balance to demonstrate completeness
• The subject matter criteria: RED II
and no double counting
• The audit itself: conduct of the audit
• GHG calculations & supporting evidence (and
these cover ‘life-cycle’ emissions) • Detailed checklist: what will be checked, when and where

• Checking of data entry onto the Union Data • Supporting evidence compiled
Base?
• Report completeness - includes assessment of:
For the ETS Verifier, checks on
Operator’s ‘own evidence’ approach • Criteria applicability, CoC, CoC Management System,
are more like doing a Technical Review GHG calculations, supporting evidence; ‘proofs’….
of the independent audit and the
compliance system to make sure they
meets expectations

Checks on the CoC Management System (1):

• Does it include, for each biomass for example:
• Material types & characteristics, such as:
• Biomass fuel, virgin, waste etc & evidence to support classifications
• What the ‘Point of Origin’ is:
• is the evidence for land use (and LULUCF for forestry) adequate?
• Is there an available risk assessment for the region/location?

• Full chain of custody description/diagram

• Suppliers, customers & sub-contractors (evidence of contracts etc) all included?
• When material was grown/sourced/produced e.g harvesting and pellet production?
• Is there ‘legal ownership certification in the chain (is it unbroken)?
• What type of processing/co-processing is involved?
• Type, number and volume/mass of ‘consignments’
• Adequate ‘materials’ management system, book-keeping & records
e.g Sales/delivery records; opening/closing stocks

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Checks on the CoC Management System (2):

• Does it include, for each biomass for example.:
Has the
• Method description for things like the Mass Balance, including:
independent
• Requirements for suppliers down the chain audit checked
• Input feedstock/output product/ processed material (eligible & non-eligible materials) all this?

• Transfers and shipping etc have been taken into account

• Calculations, formulae, conversion factors & default values are clear
• Demonstrates completeness and no double counting/ omission where fuels are mixed Is it
complete,
• An appropriate time period for balancing*
transparent,
• Links sustainability information to physical batches accurate?
• Capable of generating ‘sustainability proof’ declarations for each fuel batch
• Approach and input data for GHG savings calculations (including preliminary emission factors to support ETS
accounting)
• Information & system security measures to prevent fraud & error
• Internal audits & quality assurance
• Document control & records retention processes
* 3 months for economic operators other than primary producers which have 1 year (over calendar or economic year, as relevant) - see RED II Article 19(2)(l)

Likely routes for evidence to be checked

Notes:
1) Any EC recognised scheme or national schemes
2) i.e audit back to source to confirm sustainability & GHG emissions data –
note: Guarantees of Origin (GoO) are NOT acceptable
3) Waste resulting from product consumption e.g domestic waste (Pre-consumer
waste is material diverted from the process stream during manufacturing and
sent for disposal)
4) GD3 Section 3.4.2 give information on specific criteria applicable
5) Land use criteria N/A for wastes/residues from animals, fisheries &
aquaculture, and microorganisms
6) E.g. National Scheme where Regulator approves sustainability of specific
biomass crops for specific uses

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Example: Biomass Fuels

Type Notes
Chipped fibre  Virgin is generally locally produced/sourced
 Waste is often shipped from overseas
Logs Buy & chip Source of logs and any relevant national scheme?
Pellets Generally large-scale economic operators, usually have a certification (e.g. FSC/ Enplus)
Need to check: manufacturers credentials and scheme credentials for chain of custody
and GHG elements; along with standard shipping documents
Energy crops Need to check any energy crop regulation requirements for relevant country. In addition to timber, plants
include:
 Miscanthus (Elephant) grass  Switchgrass
 Reed canary grass
Waste Need to check country’s waste management licensing/handling requirements and whether material is
materials agricultural (AW), Forestry waste (FW) or processing waste (PW); materials include:
 Woodland brash (FW)  Straw (AW)
 Arboricultural residue (FW)  Bagasse (sugarcane/ sorghum pulp) (PW)
 Construction etc offcuts (PW)  Coffee grounds (PW)
 Sawdust (PW)  Cashew nut shells (PW)
 Cashew nut oil (PW)

Some materials may also be classified as process by-products

Example: Mass Balance Records:

Record type Information it should contain
Input and output records • Invoice reference(s)
of biomass data and • Supplying/receiving company
sustainability • Transaction date
information • Description of physical product biomass data refers to
• Volume of relevant physical input/output
• Related biomass/sustainability information (B&SI)
Conversion factor • The input/output product it refers to.
records • Value and units of the conversion factor.
• Validity of specific conversion factor(s)
• Calculation & supporting evidence determining the conversion factor
Periodic inventory of • Inventory of B&SI at start of the period
biomass data (clearly specifying if this is expressed in input-equivalents (before conversion) or output-equivalents
(after conversion)
• Volumes of inputs/outputs with identical B&SI for the period (volumes must align to stated
input/output records)
• Conversion factor(s) used in the period
• Inventory of B&SI at the end of the period (including carbon intensity of the stock)
(clearly specifying if this is expressed in input-equivalents (before conversion) or output-equivalents
(after conversion)
• Purchase and sales invoices

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Checks to be made on the audit evidence (1):

The EU ETS Verifier needs to check:
• Any independent chain of custody audit carried out has examined evidence back to the primary source
showing compliance at every stage, as well as having:
• independent Auditor appropriately qualified, competent, accredited/approved AND have applied
appropriate audit rules & standards

• Scope and results of audit that are appropriate for ETS and can be relied upon as evidence e.g:

• the report/statement, non-conformities identified, the level of assurance applied, inclusion of full chain of
custody; appropriate evidence is referenced
• Evidence includes e.g.:
For Land For Waste
• satellite image (e.g Google Maps/ Google Earth history) • Permits/certificates issued by regulators
• aerial photos (e,g, waste transfer notes or end-of-waste certificates).
• maps, land register entries, land databases • Process flow diagrams showing how material is created.
• site surveys • Information regarding material uses and its value in the market
• crop records place
• rural payment scheme forms
• current membership of an Energy Crop or equivalent scheme
• applicable sustainable forest management criteria
• current & historical data for specified dates

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Checks to be made on the audit evidence (2):

The EU ETS Verifier needs to check:
• Does compliance evidence for each different batch of fuel covers the full biomass chain; if not:

• need additional audited information for the missing parts in the chain

• Is the Mass Balance complete, consistent and balances over the specified time period*

• For solid biomass is it also on the same weight basis (wet vs dry) – is moisture content being
established along the CoC?

• Does the amounts of fuel stated as biomass delivered/produced match reality at the Installation

• Does the ‘Proof of sustainability’ relate to appropriate batch(es) and is complete (e.g batches
match to batch/delivery numbers) and the mass balance is correct

• Have GHG calculations been checked & confirmed as correct – evidence demonstrates checks on
formulae, conversions, default value, supporting evidence etc

* 3 months for economic operators other than primary producers which have 1 year (over calendar or economic year, as relevant) - see RED II Article 19(2)(l)

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* Note inputs could be different streams (eg waste,

Mass Balance example (1): residue, primary biomass) These must be accounted for
separately)

Outputs from one

Mass Balance will be
inputs in the next MB
up the chain. Each
customer needs to
have its own Mass
Balance in order to
account for its inputs
and outputs up to the
For each accounting period the PU MB balances: point a ‘Proof’ is
• Total input (K) = Σ (total waste + total output + total storage) created for a product
sold to the end user.
• Total output = total amount going out of the site to the different customers

• Appropriate sustainability information goes with each output transaction

(cannot mix ‘information types’ in any output batch)

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Mass Balance example (2):

Also need to account for the proportion of bio vs fossil

material (using separate accounting for each):
Z tonnes of bio output is at a ratio of: K/(K+M)% bio

(also need to account for amounts of each type of material that

leaves as waste out and amounts that go into & out of storage at the
processing site)

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Examples of CoC systems and standards

• CEN/TS 16214-2 : 2020 - Sustainability criteria for the
production of biofuels and bioliquids for energy
applications - Principles, criteria, indicators and verifiers
- Part 2: Conformity assessment including chain of
custody and mass balance
Sources of
reference • International sustainability and carbon certification –
information to help ISCC EU 203 – Traceability and chain of custody
ETS Verifiers
understand RED II • NTA 8080-2 - Sustainably produced biomass for
CoC audits etc. bioenergy and bio-based products – Part 2: Chain-of-
custody requirements

• Roundtable on Sustainable Biomaterials -RSB-PRO-11-

001-20-001 - EU RED Procedure for Traceability

• Roundtable on Responsible Soy Chain of Custody

Standard Version 2.3

https://energy.ec.europa.eu/topics/renewable-energy/bioenergy/voluntary-schemes_en

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Questions?

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Thank you for your attention

Presenter contact:
[email protected]

© European Union 2021

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