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. 

Currently no interpretation matters have been published for Standard 2.

Currently no interpretation matters have been published for Standard 3.

Sections 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 15 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.

The important difference is that 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 should 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.

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 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 divided between Product Groups. Available sustainability credits (from the credit-based system) obtained within 3 months^[2] prior to the transition date may be carried forward into the mass balance account (not exceeding the physical stock).

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 3,000 credits in their ‘legacy’ credit-based system. Of these 3,000 credits, 2,000 were procured between 1 June – 31 August. 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.

[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)

[2] According to the latest REDII clarification if a BP uses both forest feedstock and processing residues feedstock, it needs to use a 3-month period for all mass balance calculations. Only BPs using EXCLUSIVELY forest feedstock may use a 12-month period.