The demonstration of ‘sustainability’ thus generally relates to the quality of management of the fuel source (forests and trees) rather than the quality or nature of the product itself but already omits to quantify the carbon debt being created between the moment the biomass is burned and the moment the CO2 generated by the combustion will be re-sequestered, if ever, by future plant growth. [...] Some of the problems which have a material impact on the governability of the REDII sustainability and GHG criteria include: 5.2.1 The 2018 Directive: the role of the Commission in ‘supervising’ and monitoring the schemes Whereas the Directive stipulates that Member States shall supervise the operation of certification bodies.”, it defines very little in terms of ongoing supervisory role for the C. [...] Concerning the outcomes of the schemes, paragraph (g) of the 2022 Regulation requires schemes to provide an: overview of the effectiveness of the implementing system put in place by the governance body of the voluntary scheme in order to track proof of conformity with the sustainability criteria that the scheme gives to its member(s)... [...] The article goes on to state: The frequency of surveillance audits shall be increased on the basis of the level of overall risk related to the profile of the economic operator, the supply chain and the results of previous audits. [...] 5.7 QUALITY OF THE AUDITORS AND THE CONDUCT OF THE AUDITS The 2022 implementing regulation requires that “The audit team shall have the competence, experience and the generic and specific skills necessary for conducting the audit taking into account the scope of the audit.” However, in the absence of consistent and transparent reporting requirements, it is impossible for the Commission or others t.
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Table of Contents
- Why certification of EUs biomass energy supplies under the Renewable Energy Directive is failing to protect forests 1
- Table of Contents 3
- 1. Introduction 5
- NOTES 6
- 2. Background 7
- 3. The current system explained 8
- 3.1 WHY CERTIFY 8
- 3.2 WHO IS DOING THE CERTIFICATION AND FOR WHAT 8
- 3.3 HOW DO THE SCHEMES WORK 10
- Voluntary schemes and national certification schemes approved by the European Commission include 10
- 4. Evidence that the schemes 12
- SUMMARY 12
- 4.1 KNOWN FAILURE OR WEAKNESSES IN OTHER CERTIFICATION 12
- SYSTEMS SINCE AT LEAST 2002 12
- 4.2 CIVIL SOCIETY REPORTS AND ACADEMIC PAPERS 13
- 2010 TO PRESENT 13
- 4.3 EUROPEAN COURT OF AUDITORS REPORT 2016 14
- 4.4 REVIEWS FOR THE COMMISSION OF THE VOLUNTARY SCHEMES 15
- ANNUAL REPORTS 2019 AND 2020 15
- 4.5 EU JOINT RESEARCH CENTRE REPORT 2020 15
- 4.6 RISK OF FRAUD SUCH AS SET OUT IN THE ASSESSMENT OF THE 16
- POTENTIAL FOR NEW BIOFUEL FEEDSTOCKS REPORT 2021 16
- 4.7 STUDY ON CERTIFICATION AND VERIFICATION SCHEMES IN THE 17
- FOREST SECTOR AND FOR WOOD-BASED PRODUCTS 2021 17
- 4.8 CERTIFICATION NOT DEEMED ADEQUATE TO SHOW COMPLIANCE 17
- WITH THE EU DEFORESTATION REGULATION 2023 17
- 5. Where the problems are 18
- SUMMARY 18
- 5.1 INHERENT STRUCTURAL PROBLEMS WITH VOLUNTARY 18
- CERTIFICATION SCHEMES 18
- 5.1.1 Multistakeholderism 18
- 5.1.2 Vestedconflict interest 19
- 5.1.3 Race to the bottom in quality 20
- 5.1.4 Only addresses sustainability at the level of the production unit 20
- 5.1.5 Inherent audit limitations 20
- 5.2 WEAKNESSES IN THE REGULATORY TEXTS 21
- 5.2.1 The 2018 Directive the role of the Commission in supervising 21
- 5.2.2 Extent of self-reporting allowed 21
- Case study 1 The certification of Enviva Pellets Ahoskie North Carolina USA by System Certification Servies under the Sustainable Biomass Program 23
- 5.2.3 The requirements for the contents of public summary audit reports 24
- 5.2.4 The Annex III reporting checklist in the 2022 Regulation 24
- 5.2.5 Weak rules on how voluntary schemes should monitor the certification schemes 25
- 5.2.6 Article 6 of the 2022 Regulation concerning transparency 26
- 5.2.7 Stipulated process of certification audits lack of requirements for on-site audits 27
- 5.3 INADEQUATE TECHNICAL ASSESSMENT OF APPLICANT 27
- VOLUNTARY SCHEMES BY THE COMMISSION 27
- 5.4 FAILURES TO COMPLY WITH THE REGULATORY TEXTS 28
- NOTES ON THE TABLE 29
- 5.5 FAILURE BY THE COMMISSION TO PROPERLY SUPERVISE 30
- THE VOLUNTARY SCHEMES 30
- 5.6 INADEQUATE SUPERVISION OF CERTIFICATION BODIES 30
- BY THE VOLUNTARY SCHEMES 30
- 5.7 QUALITY OF THE AUDITORS AND THE CONDUCT OF THE AUDITS 30
- 5.8 LACK OF TRANSPARENCY 31
- 5.9 INADEQUATE MONITORING OF THE CERTIFICATION BODIES BY 31
- THE MEMBER STATES 31
- 5.10 TOO MANY OPAQUE WAYS TO ACCREDIT CERTIFICATION 32
- BODIES 32
- 5.11 LACK OF ANY LET ALONE PERIODIC INDEPENDENT 32
- EVALUATION OF THE SCHEMES OUTCOME 32
- 6. Examples of the schemes 33
- 6.1 SUSTAINABLE BIOMASS PROGRAMME SBP 33
- Case Study 2 The certification of Graanul Invest Imavere Factory Estonia certified by NepConPreferred by Nature under SBP. 34
- 6.2 INTERNATIONAL SUSTAINABILITY AND CARBON CERTIFICATION 35
- ISCC 35
- 6.3 ROUNDTABLE ON SUSTAINABLE BIOMATERIALS RSB 36
- 6.4 SUSTAINABLE RESOURCES SURE 37
- 7. Conclusions and why a more 38
