SBP Response to NGO Briefing Paper, ‘Sustainable Biomass Program: Certifying paperwork without looking at the forest’

The recently published NGO briefing paper, ‘Sustainable Biomass Program: Certifying paperwork without looking at the forest’, alleges that the Dutch authorities’ decision to deem all SBP-certified wood pellets as meeting national sustainability and greenhouse gas standards is unjustified.

SBP welcomes constructive criticism of its certification scheme, which is used to improve its Standards, processes and procedures. SBP is also interested in any feedback regarding its Certification Bodies and Certificate Holders. Allegations of non-compliance are taken seriously and, in the first instance, are drawn to the attention of the relevant Certification Body.

SBP is approved under the Dutch SDE+ subsidy regime, which has specific biomass sustainability requirements and a comprehensive approval mechanism that together should give stakeholders confidence in the decision to deem SBP-certified biomass as SDE+ compliant.

To become SBP-certified, a Biomass Producer (or Trader or End-user) must comply with the SBP Standards. If an SBP-certified Biomass Producer wishes to sell biomass into the Dutch biomass market then it must comply with additional SDE+ requirements specific to the Dutch biomass market. SBP has developed and implemented two additional Instruction Documents to address the specific nature of the SDE+ requirements.

When external bodies compare the SBP Standards with the SDE+ requirements, they too must look at the SDE+ Instruction Documents. The NGO briefing does not appear to have taken those additional documents into consideration.

SBP has evaluated the allegations made in the NGO briefing and finds them to be unjustified. The NGO briefing claims to identify four key problems with SBP, each are addressed below.

  • Lack of external auditing of forest management linked to pellet production

The SBP scheme requires independent, credible auditing of supply chains or verification of claims made by Biomass Producers. SBP Standard 3 establishes a protocol for exactly that. The rules are derived from ISO17065 and ISO19011 – internationally recognised standards for auditing that are applied across many sectors globally. Further, SBP is a community member of ISEAL and SBP Standard 3 is based on the ISEAL Assurance Code of Good Practice.

SBP has clear and proportionate auditing requirements in place. SBP-certified Biomass Producers must undergo an annual audit by an independent Certification Body. SBP operates a risk-based approach, which is a well-known and accepted approach for certification schemes. Independent auditors verify how Biomass Producers manage the specified risks within their supply base, which will entail field visits.

It is important to note that SBP is a sourcing standard, it is not a forest management standard. SBP recognises feedstock accompanied with an FSC, PEFC or PEFC-recognised scheme claim as SBP-compliant.

  • Lack of appropriate scrutiny of claims made by pellet producers and information sources provided by them

The SBP certification scheme requires appropriate scrutiny of claims made by Biomass Producers and information sources provided by them. There are, in fact, four levels of scrutiny:

  1. Independent Certification Bodies – whose auditors must have the requisite skills and training to undertake audits of SBP Certificate Holders. The role of an auditor is to precisely verify the claims made by Biomass Producers and information sources provided by them;
  2. Stakeholder consultation – SBP requires that stakeholders are consulted both by Certificate Holders and Certification Bodies;
  3. Peer review – SBP requires that the findings of the auditors are peer-reviewed by an independent expert; and
  4. Independent accreditation body – whose role is to assess the Certification Bodies through witness assessments of the audits undertaken by the Certification Bodies.
  • Inconsistent interpretation of evidence by certifiers

SBP-endorsed Regional Risk Assessments (RRAs) cover an entire geographic region or country and are a key part of SBP’s focus on identifying and mitigating risks associated with sourcing feedstock. Each country has its own legal framework and resources to support compliance with the SBP requirements, and they naturally vary from country to country. It would be highly unlikely for all countries’ risks to be rated the same and, therefore, it is not unusual to see risk ratings of the same indicators differ across borders. For that reason, the suggestion that RRAs for two different countries contradict each other cannot be attributed to inconsistent interpretation.

  • SBP indicators, i.e., guidelines for interpreting criteria, are not compatible with SDE++ criteria

The Dutch authorities continually monitor SBP’s activities. SBP is obliged to provide the authorities with updates made to any of the scheme’s documentation for their evaluation, whether Standards, SDE+ Instruction Documents, guidance, or interpretations. Maintaining the approval of its certification scheme under SDE+ is important to SBP and its Certificate Holders, and SBP works hard to assure compliance with the SDE+ requirements.

Note: SBP is compliant with SDE+ requirements (renewable energy production). SBP has not sought approval under SDE++, which supports other technologies for reducing greenhouse gas emissions.

In conclusion, SBP is a credible and robust certification scheme for woody biomass. It is recognised by leading regulatory regimes, aligned with best practice for sustainability sourcing standards, and incorporates thorough, independent scrutiny of all practices and decisions.

SBP would welcome the opportunity to engage with the authors to discuss the topics in more detail.

SBP Publishes Response to Public Consultation on Revised SBP Standards

The Sustainable Biomass Program (SBP) has today published its response to the October 2022 public consultation on the revised SBP Standards.

In the response document, each of the comments received during the public consultation is presented along with SBP’s response summarising how the comments have been dealt with in the development final draft of the Standards.

SBP Publishes Final REDII Documents

SBP has published the suite of REDII documents that, in conjunction with our current Standards, have received formal recognition from the European Commission under the recast Renewable Energy Directive (EU) 2018/2011 (REDII).

REDII lays down requirements for, amongst other energy sources, biomass, to ensure that they can be counted towards the targets set in the Directive only if they have been sustainably produced and save significant greenhouse gas emissions compared to fossil fuels.

Our systems have now been updated to allow the SBP certification scheme to be used to demonstrate REDII compliance. Any Certificate Holders wishing to extend the scope of their SBP certificate and make use of the REDII claim must comply with the REDII requirements, whilst maintaining compliance with the core SBP requirements.

All the REDII documents be found on our website at:

Our Assurance Manager, Roman Polyachenko, will be on hand to provide support to all parties, as necessary.

SBP Launches Public Consultation on Final Revision Draft of SBP Standards

The Sustainable Biomass Program (SBP) has today launched the public consultation on the final revision draft of the SBP Standards and the SBP Glossary of Terms and Definitions.

Our Standards Development Process is designed to facilitate an open, inclusive and constructive sharing of views amongst our stakeholder community. At the request of our Standards Committee, we are conducting a third and final round of public consultation to ensure that any remaining critical issues are identified and addressed.

The objective of the public consultation is to inform stakeholders of the near final version of the SBP Standards and to gather stakeholder feedback and comments on critical aspects of the current Standards that would jeopardise the long term strategic interests of our Certificate Holders and SBP itself.

An Explanatory Note gives the background to the consultation and identifies the key changes made to each of the Standards.

The following documents form the scope of the consultation:

SBP Standard 1: Feedstock Compliance

SBP Standard 2: Feedstock Verification

SBP Standard 3: Requirements for Certification Bodies

SBP Standard 4: Chain of Custody

SBP Standard 5: Collection and Communication of Data

SBP Standard 6: Energy and Carbon Balance Calculation

SBP Glossary of Terms and Definitions

All documents are available via the Feedback Platform, please use the platform to provide your feedback and comments. The consultation closes on Sunday, 6 November 2022.

Standards Committee Decides Compliance with EU REDII will Become Mandatory

In November 2021, SBP met with End-users to discuss the treatment of the EU REDII requirements, specifically whether they should be mandatory for all Certificate Holders, that is, included as a core requirement to obtain the SBP certification. That discussion was followed, in December 2021, by a survey sent to all Biomass Producers and Traders seeking their opinion on the matter. The responses from both the discussion and the survey were mixed, with no clear consensus.

As part of the current Standards Development Process, the SBP Standards Committee is responsible for approving the revised Standards. In that role, the Committee is tasked with taking the decision on the treatment of the REDII requirements. Specifically, whether all Certificate Holders, regardless of producer or consumer country, should be required to comply with EU REDII.

After much deliberation, the Standards Committee has decided that the EU REDII requirements will be mandatory for all Certificate Holders certified against the revised Standards, when available. That means all organisations wishing to be SBP-certified, will be required to implement and demonstrate compliance with the EU REDII requirements in order to achieve SBP certification, irrespective of their destination markets. The decision ensures alignment of our Standards with the requirements of EU REDII and, importantly, maintains fungibility in our sector through facilitating international trade.

Guidance on the transition arrangements will be given to all existing and prospective Certificate Holders. In the meantime, for those wishing to understand more about what the EU REDII requirements entail, it is recommended that you refer to the draft Instruction Documents that have been developed to sit alongside the current Standards, namely, Instruction Document REDII: Bridging Requirements for Meeting REDII and Instruction Document 6D: Methodology for the Calculation and Certification of GHG Emissions Savings for REDII. Whereas those documents will need to be updated, they will nevertheless provide a good indication of the requirements.

Please do not hesitate to contact the Secretariat ( should you have any questions in relation to EU REDII compliance and what it means for your organisation.

Termination of Certificates in Russia and Belarus

All SBP certificates in Russia and Belarus were suspended on 8 April 2022. As a result, it has not been possible to source SBP-certified biomass from either country since that date.

In May, SBP announced that it was transitioning to a new assurance service provider, ANSI National Accreditation Board (ANAB). ANAB has confirmed that due to the ongoing geopolitical situation it cannot provide services in Russia and Belarus, which means that approved SBP Certification Bodies will not be able to carry out SBP audits in Russia and Belarus.

Due to the lack of auditing and independent oversight thereof, it is unlikely that the existing suspensions will be lifted in the short to medium term. Under these conditions, SBP certification in Russia and Belarus cannot be maintained and all currently suspended certificates will be terminated by 15 August 2022.

SBP will maintain necessary communications with all affected stakeholders and continue to monitor the situation. SBP also reiterates its commitment to supporting and certifying good biomass from all parts of the globe, where it is in line with our values, and technically and operationally possible to do so.

SBP Launches Public Consultation on Principle 3 of Draft SBP Standard 1

The Sustainable Biomass Program (SBP) has today launched a public consultation on Principle 3 of draft SBP Standard 1: Feedstock Compliance.

Our Standards Development Process is designed to facilitate an open, inclusive and constructive sharing of views amongst our stakeholder community. At the request of our Standards Committee, we are conducting a public consultation focusing on Principle 3, Biomass sourcing contributes to climate change mitigation.

The objective of the public consultation is threefold:

  1. To inform stakeholders of the status of Principle 3;
  2. To gather expert input and suggestions to ensure clarity of the requirements; and
  3. To identify the need for the development of specific guidance for Principle 3, once the Standard has been approved.

The consultation is accessible via the Feedback Platform, please use the platform to provide your feedback and comments. The consultation closes on Thursday, 30 June 2022.

ANSI National Accreditation Board (ANAB) Launches Assurance Program for SBP

Following agreement with its current assurance services provider, Assurance Services International (ASI), SBP is preparing to transition to the ANSI National Accreditation Board (ANAB). SBP has worked with ASI as a valued assurance partner since 2016.

Already well-recognised internationally, ANAB is (amongst other things) a signatory of the International Accreditation Forum (IAF) multilateral recognition arrangements. The IAF is a worldwide association of accreditation bodies and other bodies involved in conformity assessment across a number of fields, providing assurance that certification in the market place is a reliable tool. As SBP prepares for expansion into new geographies, ANAB will help manage the risks associated with the geographic growth strategy.

The transition to ANAB is expected to be completed by mid-July 2022. SBP is providing full support to its Certification Bodies throughout the transition to ensure that there is no loss of service to any of its Certificate Holders.

More on what the transition means for SBP’s Certification Bodies and Certificate Holders is available on the SBP website here.

Extending the Validities of the Regional Risk Assessments for Denmark and Latvia

SBP has today announced that the validities of the Regional Risk Assessments (RRAs) for Denmark and Latvia have been extended to coincide with the end of the transition period for the forthcoming, revised SBP Standards (v2).

SBP-endorsed RRAs remain valid for a period of five (5) years from the approval date. Both the RRA for Denmark and the RRA for Latvia were first published in 2017, consequently both are due to expire this year.

Our Standards Development Process is expected to complete in the second half of this year, culminating in the publication of a set of revised Standards. A transition period will follow allowing time for Certificate Holders to comply with the revised requirements; at the end of the transition period it will be mandatory for all Certificate Holders to comply with the revised requirements.

The RRAs will require updating in line with the revised Standards and that will be undertaken in a timely fashion within the same transition period, such that complying with the requirements of the updated RRAs will also be mandatory from the end of the transition period.

Mindful of the implications of the Standards Development Process on existing SBP-endorsed RRAs, the SBP Secretariat proposed extending the validities of the two RRAs to coincide with the end of the transition period of the revised Standards. In accordance with the SBP RRA Procedure1, a proposal was submitted by the Secretariat to the SBP Technical Committee seeking a recommendation for such an exception. The SBP Technical Committee agreed with the proposal and submitted a recommendation for approval to the SBP Chief Executive Officer. The recommendation was approved on 2 May 2022.

1 SBP RRA Procedure, version 1.2, Section 8.