Normative interpretations for SBP Standards v2.0

Low grade stemwood
Original text: N/A

Correction: Wood from the stem of a tree (i.e., excludes branches, stumps and roots) that is not merchantable as sawtimber in local markets. This excludes salvage trees, end-of-life trees and trees removed for nature conservation.

Rationale: To support the implementation and auditing of the requirement, a definition has been added.

Material status
Original text: N/A

Correction: The characteristic of feedstock or biomass is defined by the combination of the Product Group of the feedstock/biomass and its certification status (SBP-compliant, SBP-controlled or non-certified). 

Rationale: A definition is needed to facilitate the implementation and auditing of the indicators where material status is used.

Product Group
Original text: N/A

Correction: Categories used by SBP to identify the origin of the feedstock used for the production of biomass. 

Rationale: A definition is needed to facilitate the implementation and auditing of the indicators where material status is used.

Short Rotation Coppice
Original text: Trees originating from plantations on agricultural land with short harvest rotations less than eight (8) years, including agroforestry (where trees are grown in short rotation around or among crops or pastureland to optimise use of the land).

Correction: Plantation which has been or will be regenerated from shoots formed at the stumps of the previous crop trees, root suckers, or both, i.e., by vegetative means with short harvest rotations, generally less than eight (8) years. Trees originating from plantations on agricultural land with short harvest rotations, including agroforestry (where trees are grown in short rotation around or among crops or pastureland to optimise use of the land). 

Rationale: The additional definition references the FAO definition of coppice. The original definition is also maintained with the addition of “generally” to acknowledge that local SRC management practices and definition might defer.

Thinning
Original text: Wood originating from the trees felled during the implementation of a thinning performed prior to trees reaching merchantable size, in any case not significantly larger than 11cm (4.5 inches) measured as diameter at breast height measured at 137cm (4.5 ft) above the ground. 

Correction: Silvicultural operation intended to increase tree growth and maintain forest health by regulating stand density.

Rationale: The original definition was that for pre-commercial thinning. As pre-commercial thinning is not used in the Standards, but thinning is, a definition is added.

Rationale: The table presented a series of typos. As the main header is “N/A”, the sub-criteria should be “N/A’.

Guidance Document, Indicator 4.1.8 
Original text: Training shall be provided for all workers to allow them to implement the conditions set out in all elements of the SBP Standards relevant to their responsibilities.

Additional guidance: The intent is that operators equip their workers with adequate and relevant knowledge (e.g., first aid training, forestry training for forest workers, social training for community liaison, etc.) so that they perform their work in accordance with the SBP Standards. It does not necessarily mean the workers must have knowledge of SBP or its Standards, but that they are adequately trained to perform their work and ensure overall compliance of the operations with the SBP Standards. 

Clause 3.11

3.11 The Organisation shall consider feedstock as SBP-compliant if:

1. the results of the Risk Assessment(s) conclude low risk for all Indicators, or
2. the results of the Risk Assessment(s) conclude specified risk however the RMMs have effectively reduced all specified risks to low risk, or
3. the Organisation can provide evidence that the feedstock can be categorised as processing residues and that the feedstock is certified against an SBP-recognised certification scheme, or
4. the Organisation can provide evidence that the feedstock can be categorised as post-consumer

Q: Can feedstock be considered SBP-compliant if the Biomass Producer knows that Standard 1 requirements are not met (e.g., forest conversion without plans for regeneration), but the RRA for the specific region/country defines Low Risk for this requirement?

A: No. If a Biomass Producer or Certification Body has evidence that feedstock originates from a source where Standard 1 requirements are not met, it cannot be accepted as SBP-compliant. If a published RRA for the country/region defines Low Risk for the requirement, the Certification Body must report such cases to SBP to inform a potential review of the RRA risk rating. If a Company Risk Assessment (CRA) has been developed by a Biomass Producer, the Certification Body must evaluate whether the Biomass Producer shall revise the CRA risk conclusion.

Clauses 5.3 and 6.1

Normative Interpretation: If a Biomass Producer exclusively sources FSC or PEFC certified feedstock (e.g., from a certified forest plantation under its ownership), then it shall only develop SBVs and conduct a Risk Assessment for those indicators that are marked as partially met or not met in a corresponding SBP evaluation report for (i.e., evaluation reports developed per the Framework for benchmarking and recognition of certification schemes relevant to the scope of SBP certification, https://sbp-cert.org/documents/process-documents/framework-for-benchmarking-and-recognition-of-certification-schemes-relevant-to-the-scope-of-sbp-certification/).

Clause 7.1

7.1 The Organisation shall develop a Risk Management Plan (RMP) which includes Risk Management Measures (RMMs) for each Indicator rated as specified risk within its SBE per the Organisation’s Risk Assessment or an SBP-endorsed RRA with the objective to mitigate the risk and reduce the risk rating to low risk.

Q: Are there any differences in requirements between non-certified (neither FSC- nor PEFC-certified) primary feedstock and processing residues feedstock regarding RMMs? Does processing residues feedstock have any exceptions or flexibility?

A: No. The obligation to develop Risk Mitigation Measures is the same for both types of feedstock. The only difference lies in the implementation of RMMs, as mitigating risk may require more effort when sourcing through longer and more complex supply chains (e.g., residues from sawmills versus primary feedstock directly from forests).

Q: Can supplier audits using sampling (e.g., auditing a portion of suppliers annually, typically applying a square root or percentage formula) be considered sufficient RMM?

A: No. It is essential to distinguish between RMM implementation (i.e., reducing risk to low) and monitoring the implementation and effectiveness of RMMs. When implementing RMMs, Biomass Producers must work with all suppliers and sub-suppliers, ensuring all feedstock sources included in the RMP implement the identified mitigation measure(s). Biomass Producers may delegate the implementation of RMMs to their direct suppliers. For instance, a sawmill supplying processing residues may be tasked with implementing RMMs for its own suppliers, such as logging companies or forest owners. However, the overall responsibility for risk management always remains with the Biomass Producer.

Monitoring the effectiveness of RMMs may indeed involve supplier audit sampling, but it is likely not to be an effective mitigation measure in itself. Audit of suppliers is one of various means of verifying the effective implementation of mitigation measures at supplier level. If sampling is used, sampling must be statistically representative to provide sufficient confidence that measures have been effectively implemented.

Clauses 7.1 and 7.2
Original text:
7.1 The Organisation shall develop a Risk Management Plan (RMP) which includes Risk Management Measures (RMMs) for each Indicator rated as specified risk within its SBE per the Organisation’s Risk Assessment or an SBP-endorsed RRA with the objective to mitigate the risk and reduce the risk rating to low risk
7.2 The Organisation shall implement any RMMs proposed by SBP (i.e., in Instruction Documents) or by SBP-endorsed RRAs.

Clarification: The term ‘SBP-endorsed RRA’ in clauses 7.1 and 7.2 also includes ‘SBP Interim RRA’. An SBP Interim RRA for a region might be published by SBP to enable Certificate Holders to develop and implement mitigation measures and for Certification Bodies to certify the Certificate Holders until an SBP-endorsed RRA for the said region is published.

If any of the risk ratings in the final SBP-endorsed RRA have changed from low to specified compared to the SBP Interim RRA, the Biomass Producer will need to update its Supply Base Evaluation accordingly. There will be a 6-month transition period for the Organisation to implement the SBP-endorsed RRA, and will be subject to verification during the Certification Body’s surveillance audit. If the transition to the SBP-endorsed RRA is not completed, the CB shall raise a major non-conformance.

Clause 1.1.7

Clarification: With regards to clause 1.1.7 the geographical scope of accreditation for SBP shall match the geographical scope of FSC® and/or PEFC Chain of Custody accreditations.

Clause 4.1

Clarification: There are several exceptions to clause 4.1a, the:

• BP only sells SBP-controlled biomass;
• REDII Level A risk assessment for the BP’s Supply Base has rated all indicators as low risk;
• SBP Regional Risk Assessment for the BP’s Supply Base rated all indicators as low risk;
• BP only sources Processing Residues feedstock with a claim from an SBP-recognised certification scheme (i.e., FSC or PEFC).

In situations listed above, an auditor qualification in FSC or PEFC CoC is sufficient (i.e., 4.1b applies).

Clause 4.12 (and Instruction Document 5E, clause 2.1)

Clarification: When assigning a Product Group ID, the BP may use three digits once A=9 has been reached, e.g., 101, 102, 103 etc.

Clause 6.22

Clarification: X = number of Forest Management Units or suppliers, i.e., the term ‘sourcing area’ shall be interpreted as ‘Forest Management Unit’ (FMU). Nonetheless, the CB audit samples shall include both suppliers and FMU.

Where a BP’s RMMs have to be implemented on an FMU or supplier level, only those FMUs or suppliers shall be included in an CB audit sample.

Example: Two sawmills supply a pellet mill (BP) and each of the two sawmills buy from 500 different FMUs. Out of 1,000 FMUs, RMMs had to be implemented at the FMU level for only 200 FMUs.  The sample shall be calculated with X = 200, not X = 1,000. In this case, Y = 0.8 SQRT (200) = 0.8 x 14.1=11.3. The sample shall include 12 FMUs (always round up).

If RMMs must also be implemented at a supplier level, then the CB shall consider it as a separate sample set. In the example above, the X for the supplier sample would be 2. In this case, 0.8 x SQRT(2) = 0.8 x 1.4 = 1.13. The sample shall include the 2 suppliers (always round up).

Section 8 Non-conformances

Normative interpretation: Where a non-conformance (NCR) is identified when auditing a Biomass Producer’s Supply Base Evaluation process (Standard 2), that NCR shall be categorised as a major NCR under the following circumstances:

1. Failure to develop and implement a Supply Base Evaluation process;
2. Absence of credible and verifiable information that demonstrates the origin of feedstock;
3. Failure of the organisation to demonstrate that its risk assessment has been conducted in accordance with the applicable SBP requirements;
4. Failure to use an SBP-endorsed Regional Risk Assessment, if such exists;
5. Use of feedstock originating from unevaluated sourcing areas, in other words, without the Certification Body’s approval of a revised SBE scope for the organisation (new sourcing areas may only be added through a scope change audit);
6. Failure to establish and implement control or mitigation measures; or
7. Failure to provide information required to be made publicly available in the Supply Base Report (e.g., description of supply base, risk assessment or risk mitigation measures that do not adequately inform stakeholders about how risks are identified and mitigated and, on the verification, and risk mitigation measures implemented).

For any of the circumstances above, CB auditors shall issue a MAJOR NCR. The CB may only issue or re-issue a certificate if all identified NCRs (i.e., both major and minor non-conformances) are closed (SBP Standard 3, 8.11).

Clause 8.9

Original: Timelines for corrective action requests shall commence from the day of the certification decision.

Correction: Timelines for corrective action requests shall commence from the day of the certification decision, except for major corrective action requests, which shall commence from the date when the major corrective action request was formally communicated in writing to the Certificate Holder, which shall be no later than 30 days from the day of the audit closing meeting. 

Clause 11.6 

Original: CBs shall take certification decisions no later than one month after the date of the closing meeting of the evaluation.

Correction: CBs shall take certification decisions no later than three months after the date of the closing meeting of the evaluation audit.

Annex 1, Clause 1.10 

1.10 The period of validity of an SBP certificate shall not exceed five (5) years.

Normative interpretation: The specified period of validity of certification may be extended for a single exceptional extension of up to six (6) months to permit re-evaluation to be completed, when justified by circumstances beyond the control of the Certification Body and its client. Once the Certification Body has satisfied itself that its client will maintain its conformity with the applicable SBP requirements until the new expiry date, the Certification Body shall take the following steps:   

a. record such circumstances;
b. inform SBP Secretariat and provide:

• • the rationale for requesting an extension to the validity date, and
    
  • a new validity date (not more than 6 months beyond the original expiry date).

c. SBP will review the request and if approved shall update the entry on the SBP Audit Portal. 

SBP will consider each extension on a case-by-case basis, and none shall be taken as forming any precedent.  

Clause 4.10

Clarification: The BP shall create separate mass balance accounts for SBP-compliant and SBP-controlled biomass product groups.

Clauses 4.22 and 4.23

“4.22 The claim ‘SBP-compliant’ may be used on sales transactions related to biomass, only where it refers to products which are included in the Organisation’s certificate scope and that meet the eligibility requirements for SBP-complaint claims.

“4.23 The claim ‘SBP-controlled’ may be used on sales transactions related to biomass produced from the feedstock category conforming with SBP-controlled or SBP-compliant definitions.”

Clarification: In line with the decision by the SBP Standards Committee, EU REDII compliance has been made mandatory when making SBP-compliant or SBP-controlled claims under SBP Standards v2.0. Thus, SBP-compliant or SBP-controlled claims shall always be accompanied by an SBP REDII-compliant claim. EU REDII requirements are provided in a separate normative document ‘Instruction Document REDII: Bridging Requirements for Meeting REDII’ (or the REDII Bridging Instruction Document).

Document Development Procedure, Section 8.2.1

Revised SBP Standards: key dates

This interpretation summarises rules for the transition of Certificate Holders from the current SBP Standards (v1.0) to the revised Standards (v2.0). Defined dates and the timeframes associated with the implementation of a normative document in order of the events are as follows:

• Approval date: the date on which an SBP normative document is approved by the decision-making body.
• Publication date: the date on which an approved SBP normative document is announced and published on the SBP website (within 60 days of the approval date).
• Effective date: the date on which a published SBP normative document becomes applicable for use (within 90 days of the publication date).
• Transition period: the period of time commencing on the effective date and continuing for 27 months. During the transition period, the new version of an SBP normative document is phased-in and the old version (where one exists) is phased-out, therefore, both versions are valid during that time and may be used by existing and new certificate holders. At the end of the transition period, only the new version is valid and any certificates issued against the old version are considered invalid.  This means that even though both versions may be used during the transition period, it is highly recommended to switch to the new version at soonest opportunity and choose the new version of the Standards for new assessments.

Document Development Procedure, sections 8.5.1 and 8.5.2

“8.5.1 Where an urgent substantive change (either revision or new documents) to a Category 1 or 2 document is determined to be needed the Secretariat shall draft the document.

“8.5.2 Urgent substantive changes to Category 3 and Category 4 documents may be implemented by the Secretariat.”

Definition: The term substantive change is defined under section 8.5. A change is an urgent substantive change when an immediate need for change is identified that is consistent with international best practice for standards development.

The conditions under which these changes may be triggered are as per 8.5.1.2. A change that is likely to generate significant divergent stakeholder views is not suitable for development as an urgent substantive change under section 8.5. The procedure set out in section 8.5 shall only be used infrequently where a specific urgent need is identified.

Transition from credit-based system in SBP Standards v1.0 to the REDII-type mass balance system in revised SBP Standards v2.0 (following Instruction Document REDII: Bridging Requirements for Meeting REDII)

Background: SBP Standard 4 v1.0 relies on Chain of Custody (CoC) methods in SBP-approved CoC systems, such as FSC or PEFC. Both schemes use the concept of a so-called credit-based system, which follows the basic ‘units in = units out’ principle but has an important difference to the 12-month mass balance period required in SBP Standard 4 v2.0 (which follows the REDII requirements^[1]). Under the FSC and PEFC credit-based systems, sustainability information (‘credits’) enters a credit account until the operator decides to sell physical material with some of those credits. If a customer does not require sustainability information, physical material can be sold, and the credits can stay in the credit account (e.g., in a virtual spreadsheet record). The transfer of sustainability credits is always with a physical flow of material and operators are never allowed to have a deficit in sustainability credits. But the amount of credits in an operator’s credit account does not have to match the physical quantity of material on a site.

The use of this system has the potential to create a situation where Biomass Producers (BPs) may accumulate virtual stock of sustainability credits significantly exceeding their physical stock.

SBP Standard 4 v2.0 requires that to carry sustainability information over to the next mass balance period, a BP must have at least the same quantity of physical stock. The balance shall be achieved over either a 3 or 12-month period, depending on the type of feedstock used (as required by SBP Instruction Document REDII: Bridging Requirements for Meeting REDII (or the REDII Bridging Instruction Document)). While BPs will be allowed to have a negative balance during a mass balance period under the SBP Standard 4 v2.0, BPs will no longer be able to carry forward more balance than they have physical stock. Note that EU REDII compliance is compulsory for all Certificate Holders transitioning to v2.0.

This interpretation is intended to guide BPs on how to transition between these two systems.

Interpretation: A BP shall document a plan for the transition from the credit-based system to the mass balance system, including the start date of the mass balance period. The BP may use available credits in its mass balance system up to the amount equivalent to the physical stock on the day preceding the first day of the established mass balance period. Note that, to make SBP-certified and EU RED claims on any physical stock after the transition date, those volumes must have been produced from feedstock procured in compliance with the SBP Standards v2.0 and the REDII Bridging Instruction Document. The physical stock at the beginning of the first mass balance period shall be allocated to its respective Product Group according to the rule in Standard 4 (v2.0), clause 4.12. Available sustainability credits (from the credit-based system) obtained prior to the transition date may be carried forward into the mass balance account (not exceeding the physical stock). In other words, in order to use physical inventory material in the new mass balance system, it shall be ‘virtually’ SBP-compliant (enough SBP credits) or SBP-controlled (not enough credits but can prove that all input was either FSC or PEFC controlled), and all physical inventory material shall also be SBP REDII-compliant.

Example: A BP transitions to the SBP Standards v2.0 on 1 September. The BP began procuring feedstock in compliance with the SBP Standards v2.0 and the REDII Bridging Instruction Document on 1 June. On 31 August, the BP had 1,000 tonnes in physical stock inventory, and a balance of 2,000 credits in their ‘legacy’ credit-based system. Of those 2,000 credits, 1,000 were from forest feedstock, and 1,000 were from processing residues feedstock. Therefore, the BP may either choose to carry over all 1,000 tonnes of forest feedstock, or all 1,000 tonnes of processing residues feedstock, or some combination of the two (e.g., 500/500) so long as the total sustainability credits carried over do not exceed the physical stock of 1,000 tonnes. To claim this stock as EU RED-compliant, the BP shall demonstrate that the physical stock of 1000 tonnes complies with the REDII Bridging Document.

[1] Please note that SBP requires SBP-compliant or SBP-controlled biomass to also conform to SBP REDII-compliant biomass requirements (i.e., follow REDII mass balance rules from the SBP REDII Bridging Instruction Document).