The following provides an update on the status of the recast EU Renewable Energy Directive 2018/2001 (REDII) and sets out the activities underway to secure the recognition of the current SBP Standards under REDII.
To recap, EU Member States had until 1 July 2021 to transpose REDII into national law. Compliance with REDII requirements may be demonstrated via voluntary certification schemes that are approved by the European Commission. Only a few EU Member States implemented REDII on time, and the European Commission has not yet been able to fully complete the approval process for the voluntary certification schemes. The Commission has informed us that approval process will be completed following finalisation of the implementing acts, which is expected by the end of the year.
SBP submitted an application for the approval of our current Standards under REDII back in October 2020. Since then we have engaged with the European Commission (the Commission) and its consultants responsible for evaluating all voluntary schemes.
Following an initial evaluation of our Standards, a number of gaps were identified. Those gaps have been addressed in the form of a new Instruction Document (currently in draft form) that will accompany the current Standards. That draft document was submitted to the Commission for evaluation in June and we await feedback before the document is put through our internal Document Development Procedure and ultimately published and made effective.
Instruction Documents to bridge the gaps between the SBP Standards and the requirements of specific countries/jurisdictions have been used already to good effect, for example, in the Netherlands and Flanders, Belgium. We are adopting a similar approach with REDII, which means that in order for biomass to be REDII-compliant and carry a REDII-compliant claim, it must be compliant with our current Standards and the normative requirements stipulated in the new Instruction Document (Instruction Document REDII).
There are two aspects to Instruction Document REDII. The first covers the REDII-specific sustainability requirements. If a Biomass Producer with a Supply Base Evaluation in its SBP certification scope is sourcing primary feedstock and wishes to produce and sell biomass that is REDII-compliant it must comply with the REDII-specific sustainability requirements. If a Biomass Producer without a Supply Base Evaluation in its SBP certification scope is sourcing primary feedstock and wishes to produce and sell biomass that is REDII-compliant it must comply with the REDII-specific sustainability requirements and implement a Supply Base Evaluation mechanism (as detailed in Standard 2) to do so.
The second aspect covers requirements for demonstrating the origin of the feedstock. If a Biomass Producer is sourcing secondary or tertiary feedstock it must demonstrate the origin of the feedstock in accordance with Instruction Document REDII. Note that secondary/tertiary feedstock does not have to meet any sustainability criteria to be REDII-compliant, therefore, the sustainability requirements of Instruction Document REDII are not applicable.
On the assumption that our current Standards and the new Instruction Document are approved, the following illustrates various scenarios for SBP-certified Biomass Producers regarding REDII compliance:
Sourcing primary feedstock
|Sourcing secondary/ tertiary feedstock||Supply Base Evaluation||Instruction Document REDII||REDII-compliant|
|Biomass Producer A||Yes||Yes||Yes||Yes||Yes|
|Biomass Producer B||Yes||No||Yes||Yes||Yes|
|Biomass Producer C||Yes||No||Yes||No||No|
|Biomass Producer D||Yes||No||No||Yes1||No|
|Biomass Producer E||No||Yes||Yes||Yes||Yes|
|Biomass Producer F||No||Yes||No||Yes2||Yes|
1 Biomass Producer D must extend its scope in accordance with Instruction Document REDII and implement a Supply Base Evaluation mechanism to meet the sustainability criteria of Instruction Document REDII if it wishes to produce and sell REDII-compliant biomass.
2 Biomass Producer F must comply with the requirements of Instruction Document REDII for demonstrating the origin of the feedstock.
As noted above we have submitted our current Standards only for evaluation. We will integrate the specific REDII requirements into the revised Standards that are being developed as part of the ongoing Standards Development Process. Therefore, any claims under the revised Standards will be REDII-compliant by default, that is, without the need to meet any additional requirements.
As soon as we have news of our application, which we understand will not be before the end of August, we will let you know and clarify next steps, which will likely include a webinar for Certificate Holders and additional training for Certification Bodies.