Better than Before: SBP Launches Revised Standards

SBP has today launched its revised sourcing Standards for woody biomass. The revised Standards underpin the SBP promise of good biomass. They require that SBP-certified biomass is deforestation-free, that biodiversity is maintained or enhanced through protecting key species, habitats and ecosystems, that water quality and soil quality are maintained or enhanced, that carbon stocks are stable or increasing, and that workers and their rights, local communities, and the rights of Indigenous Peoples are protected.

In addition, the EU REDII requirements will be mandatory for all Certificate Holders certified against the revised Standards.

Carsten Huljus, Chief Executive Officer, commented: “Reviewing and revising our Standards has been another milestone in the development of SBP.

“At the outset our goal was to achieve multi-stakeholder consensus on how to improve and advance our certification scheme, whilst maintaining relevance and effectiveness, and importantly, ensuring future fitness.

“We have achieved that with a set of Standards that are better than before, and we are now focused on their successful roll-out.

“My sincere thanks to all who contributed along the way”.

The Standards Development Process

The launch of the revised Standards marks the culmination of the Standards Development Process that we and our stakeholders formally embarked upon in 2020, five years since our Standards were first published.

Continuous improvement and relevance are central to our thinking and a key aspect of the review and revision process was to fully consider, amongst other things, changes in market regulations, advances in best practice, and increased knowledge of key issues, including forest carbon, biodiversity and social impact.

The Process encouraged full stakeholder participation, with comprehensive Working Group arrangements to delve into the detail and make recommendations to improve and advance the requirements for legal and sustainable sourcing of feedstock for biomass production.

The full suite of six Standards was subject to three public consultations, and pilot testing in key producer regions across a representative sample of small and large producers of pellets and chips.

Our Technical Committee and Standards Committee conscientiously oversaw the Process, scrutinising the recommendations throughout. Ultimately, in March 2023, following approval by the Standards Committee our Board endorsed the revisions.

Key improvements

Our revised Standards have been improved and advanced in a number of areas, including:

  • Structural, streamlining our requirements to aid implementation and clarity, with a focus on outputs.
  • Beyond regulatory compliance, through indicators in the areas of biodiversity, land conversion, forest carbon stock, cascading use, training, grievance handling and free, prior and informed consent (FPIC).
  • Environmental, strengthened requirements to identify threats to ecosystems, and to maintain or enhance key species, habitats, ecosystems and areas of high conservation value; clarifying those no-go areas of land that cannot be changed or converted; regeneration of forested land; and banning of harmful agrochemicals.
  • Forest carbon, a new principle, including land use, land-use change and forestry (LULUCF) emissions requirements; driving positive impact through the requirement for forest carbon to be stable or increasing; no harvesting in low productivity or difficult to regenerate areas, nor in areas combining high conservation values and high carbon stocks; and the introduction of the cascading use principle.
  • Social, new and enhanced social requirements fighting discrimination through strengthening the protection of workers and their rights; and requirements to identify and avoid negative impacts in local communities, protect cultural heritage sites and the rights of Indigenous Peoples.
  • Identifying and managing sourcing risks, a major overhaul delivering greater clarity in how to develop, implement and manage risk assessments, and the introduction of more objective requirements for auditors when evaluating compliance; a new concept of benchmarked and recognised schemes to manage risks in the Supply Base; and the need for requirement for stakeholder consultation.
  • SBP-specific, increased relevance of the requirements for Certification Bodies and the introduction of our own Chain of Custody system; strengthened requirements around auditor competence; minor and major non-conformity definitions aligned with best practice; and clear rules on, amongst other things, annual surveillance audits, audit timelines, management systems and internal audits, record keeping, stakeholder consultations, health and safety, and anti-corruption.
  • Data focused, significant improvements to the requirements around identifying volumes of biomass and communication of data; and enabling the calculation of greenhouse gas emissions along the supply chain.

A fuller description of the improvements and advancements is available here.

Roll-out of SBP Standards v2.0

All documents come into effect on 10 August 2023, and  existing Certificate Holders have a period of 15 months from the effective date during which to transition to the revised Standards. The transition period will end on 9 November 2024, at which time SBP Standards v1.0 will be retired.

The normative documents, comprising the six SBP Standards, Glossary of Terms and Definitions, and Instruction Documents are available on our website here. For the first time we have published Guidance Documents to accompany Standards 1, 2 and 4, and they are available on our website here.

SBP-endorsed Regional Risk Assessments (RRAs) are currently being revised, and new RRAs developed, to align with the revised Standards. Keep up-to-date with the status of the revisions and developments here (scroll down).

SBP Directorate Change

Will Gardiner, CEO of Drax Group, has with effect from 16 March 2023 stepped down from his role as a board member of the Sustainable Biomass Program. Mr. Gardiner has served in this position in a personal capacity since January 2019 and we thank him for his valuable contribution to our organisation. We will look to filling his seat over the coming months and will provide an update in due course.

SBP Receives Formal Recognition as a Voluntary Scheme under REDII

The Sustainable Biomass Program (SBP) is pleased to announce that on 26 September, the European Commission published the legal text of SBP’s recognition under the 2018 Renewable Energy Directive (REDII). The Decision entered into force on the day following that of its publication in the Official Journal of the European Union (OJEU), and so became effective as of 27 September.

REDII lays down requirements for, amongst other energy sources, biomass, to ensure that it can be counted towards the targets set in the Directive only if it has been sustainably produced and save significant greenhouse gas emissions compared to fossil fuels. SBP welcomes the Commission’s endorsement of our Standards’ reliability, transparency and independent auditing as being in line with the requirements of the Directive.

As Europe’s largest independent certification scheme for woody biomass in large-scale industrial heat and power production, steps will now be taken to activate SBP’s systems to allow the scheme to be used to demonstrate compliance with REDII.

It should be noted that Certificate Holders must take action to comply with SBP’s specific REDII requirements in order to be REDII-compliant; recognition of our scheme does not mean biomass carrying an SBP claim is automatically REDII-compliant. SBP will host a webinar on 25 October 2022 for Certificate Holders and Certification Bodies to outline the REDII requirements and the actions to be taken to ensure compliance with REDII. Certificate Holders and Certification Bodies are invited to register for the webinar here.

The link to the Commission’s publication of the Implementing Decision can be found here, while the publication of the Decision on the OJEU can be found here.

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: https://sbp-cert.org/documents/standards-documents/redii-documents/.

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 (info@sbp-cert.org) 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.