Questions on the SBP Standards v2.0 submitted by stakeholders are collated below along with our answers.
We encourage you to continue to submit any questions you may have, please email firstname.lastname@example.org.
Q: What does SBP certification achieve that cannot be achieved through existing certification schemes, such as, FSC and PEFC?
A: SBP does not intend to compete with or replicate existing certification schemes, such as, FSC and PEFC. Those schemes do not cover all the key requirements necessary to demonstrate the legality and sustainability aspects and attributes of feedstock used in biomass production and use. SBP will publish its procedure for benchmarking and recognition of other certification schemes, which will allow FSC and PEFC to be evaluated against the SBP certification scheme.
Q: How will FSC-certified material be treated under the SBP Standards v2.0?
A: The SBP procedure for benchmarking and recognition of other certification schemes will set out how other certification schemes may be benchmarked or recognised with respect to the SBP certification scheme. For example, in the case of FSC, the procedure will allow identification of any gaps between FSC and SBP requirements. Where there is a gap, and where a specified risk has been identified in the supply base, operators are required to develop and implement mitigation measures.
Q: When will the SBP procedure for benchmarking and recognition of other certification schemes be available?
A: The SBP Benchmarking and Recognition Procedure, and the evaluation of FSC and PEFC will be published in October 2023.
Q: Will there still be an SBP-controlled biomass claim?
A: The SBP-controlled biomass claim continues to exist. It is available to feedstock that is certified against a recognised controlled claim, for example, FSC Controlled Wood.
Q: Is biomass certified against SBP Standards v1.0 only entitled to carry the SBP claim until the end of the transition period?
A: No. Biomass certified against SBP Standards v1.0 before the end of the transition period is entitled to carry the SBP claim beyond the end of the transition period.
Q: Can a Certificate Holder continue to use the FSC or PEFC Chain of Custody schemes, or must it be certified against the SBP Chain of Custody scheme?
A: Certificate Holders must be certified against the SBP Chain of Custody scheme (SBP Standard 4). It is no longer required to hold a valid FSC or PEFC Chain of Custody certificate.
Q: SBP Standard 4 (v2.0), section 4.14 refers to a mass balance period of no more than 12 months. However, the Instruction Document REDII (v1.0), section 8.3.8 refers to a three-month mass balance period. Why are they not the same?
A: The EU REDII has stricter mass balance requirements for processing residues and post consumer feedstocks. For those feedstocks, the mass balance period shall not be more than three months. Only when an operator handles solely primary feedstock can the mass balance period be no more than 12 months.
Q: When will the credit system be withdrawn in favour of the mass balance system?
A: For any Certificate Holder, the credit system will be withdrawn when the SBP Standards v1.0 are retired at the end of the transition period (10 November 2024) or when the Certificate Holder is certified against the SBP Standards v2.0, whichever is the sooner.
Q: Could a mobile chipper use the mass balance system and mix different feedstock groups if accumulated in storage yards?
A: One condition for the mass balance system is to have a fixed site. If mixing occurs at a fixed storage site (e.g.,a storage yard), it is possible to mix different feedstocks and apply the mass balance system following the requirements set out in Standard 4.
Q: In SBP Standard 4, section 4.8 what is the definition of ‘material status’? What type of material needs to be kept separate?
A: Material status refers to the certification status of the material. Compliant/controlled material or material with no claim need to be segregated.
Q: If a Certificate Holder wants to create more than nine Product Group IDs, can the system support a three-digit Product Group?
A: Yes, you can use a three-digit Product Group ID (for example, 111, 112).
Q: How should bark removed from trees at a sawmill be categorised?
A: Bark should be categorised as processing residues if the processing takes place at the sawmill.
Q: In situations where there is an official SBP RRA or REDII Level A risk assessment and ALL Indicators are designated Low Risk, is a Biomass Producer required to consult
A: No. The purpose of stakeholder consultation is to collect feedback on Supply Base Verifiers, Risk Ratings and the Risk Management Plan developed by the Biomass Producer (Standard 2 v2.0, Indicator 8.1). Where there is an SBP RRA or REDII Level A risk assessment, and Low Risk designations for ALL Indicators, there is no need for further stakeholder consultation. Stakeholders may contact SBP directly if they have any comments regarding the contents or risk designations of SBP RRAs or REDII Level A risk assessments.
Q: Which of the SBP Standards should End-users be certified against if they wish to be REDII-compliant?
A: End-users seeking compliance with REDII shall be certified against Standard 4, Standard 5 and Instruction Document REDII: Bridging Requirements for Meeting REDII. Certification against Standard 6 remains optional.
Q: Does a Trader that is certified against v1.0 have to be certified against v2.0 before it can trade biomass carrying the SBP REDII claim?
A: Traders with EU REDII in their scope will be able to trade SBP REDII-compliant biomass irrespective of the version of the Standards against which they have been certified, provided that their suppliers have REDII in their scope.
Q: Is it possible for a Trader certified to SBP Standards v1.0 to extend its scope to include EU REDII and trade REDII-compliant biomass certified to SBP Standards v2.0?
A: Extending the scope to include EU RED II is not sufficient to fully transition to v2.0. Operators must fully transition to v2.0 by implementing the Standards v2.0 applicable to their operations.
Q: Is compliance with EU REDII required across all SBP-certified biomass or just for biomass that is destined for a REDII market?
A: EU REDII compliance is mandatory for all Certificate Holders irrespective of the market destination of the biomass they produce.
Q: Is compliance with EU REDII obligatory at all times?
A: Yes, compliance with the EU REDII requirements is mandatory for all Certificate Holders.
Q: Is the EU REDII mass balance reporting period still under discussion?
A: No, the European Commission has clarified the rule for the mass balance period. Only Biomass Producers that use EXCLUSIVELY primary feedstock can use a mass balance period of up to a maximum of 12 months, others have to use up to a maximum of three months.
Q: Do all the RRAs include the EU REDII requirements?
A: All revised and new RRAs will include the EU REDII requirements.
Q: Can the SBP REDII claim be passed on to organisations that are not SBP Certificate Holders?
A: There is currently no mechanism to pass on SBP claims or information to organisations that are not SBP Certificate Holders.
Q: Is it possible to have a REDII-compliant SBP-controlled claim?
A: Yes, the two are not mutually exclusive.
Q: Do the SBP Standards v2.0 incorporate the REDII requirements, effectively doing away with the Instruction Dcument REDII: Bridging Requirements for Meeting REDII?
A: No, the revised SBP Standards v2.0 do not replace Instruction Document REDII. Certificate Holders must comply with the requirements of the SBP Standards v2.0 and Instruction Document REDII.
Q: Will trees outside forest (TOF) be included in the EU REDII requirements?
A: Yes. Trees outside forests (TOF) will be included in Instruction Document REDII that accompanies the SBP Standards v2.0. That document is currently with the European Commission for approval.
Q: EU REDII requires that certification schemes must accept claims from other approved certification schemes. How does SBP address this?
A: SBP is required to accept EU REDII claims from peer certification schemes. In order to transit through the SBP system, such claims must upgrade to an SBP (controlled or certified) claim by implementing and demonstrating compliance with the relevant additional elements of the SBP scheme.
Q: If a share of the feedstock used by a Biomass Producer is not REDII-compliant, does that mean the Biomass Producer cannot be SBP-certified?
A: The Biomass Producer can be certified, however, the biomass produced from non-REDII compliant feedstock cannot carry an SBP claim.
Q: If segregation of feedstock and/or biomass is ensured as per the Standards, can a Biomass Producer be SBP-certified and sell SBP/REDII compliant biomass and non-certified biomass?
Q: Is the Instruction Document REDII: Bridging Requirements for Meeting REDII only applicable to the SBP Standards v1.0?
A: Instruction Document REDII: Bridging Requirements for Meeting REDII is applicable to the SBP Standards v1.0 and SBP Standards v2.0?
Q: Is it possible to use the National Risk Assessments developed for EU REDII when conducting a Supply Base Evaluation?
Q: Which other countries/regions are Regional Risk Assessments being developed for?
A: In addition to the current six RRAs, for Denmark, Estonia, Latvia, Lithuania, Quebec and British Columbia, new RRAs are being prepared for Portugal, Alberta, Nova Scotia and New Brunswick. We anticipate that, over time, RRAs will be developed for Vietnam, and south-east USA, although as yet there is no confirmed timeline, budget or Working Body established.
Q: Harvest operations in a single area can often include different types of trees outside forests. Does SBP require classification according to the main type or each type?
A: It is required to subdivide for each type as per the Feedstock Group classification, especially as this has implications for mass balance reporting.
Q: Could woody feedstock resulting from peat extraction be considered as trees outside forests?
A: This type of feedstock is not in the scope of the Instruction Document for Trees Outside Forests and is not eligible for SBP certification.
Q: Should applicant Certificate Holders be certified against the revised SBP Standards v2.0?
A: From the effective date of the SBP Standards v2.0 (10 August 2023), applicant Certificate Holders can choose to become certified against them. The choice is dependent on the applicant’s own circumstances. Note that from 10 November 2024, all Certificate Holders must be compliant with the SBP Standards v2.0.
Q: If the audit cycle for a Biomass Producer falls in January, does it mean that the transition to SBP Standards v 2.0 must be completed in the January 2024 audit?
A: It is possible to bring forward or delay the transition to SBP Standards v2.0, however, this should be decided after consultation with your Certification Body. Note that from 10 November 2024, all Certificate Holders must be compliant with the SBP Standards v2.0.
Q: When will the SBP Standards v2.0 be ready for use by Certification Bodies?
A: The SBP Standards v2.0 will be ready for use from the effective date of 10 August 2023. Certification Bodies will need to have updated their internal systems and have their updated internal systems approved by the Accreditation Body. It is recommended that Certificate Holders liaise with their Certification Body to confirm timelines.
Q: Will the SBP Audit Portal and Data Transfer System (DTS) be affected by the switch to the revised SBP Standards v2.0?
A: The Audit Portal and DTS will be updated to meet the requirements of the revised SBP Standards v2.0. During the transition period all SBP systems will cater for both v1.0 and v2.0 of the Standards.
Q: Will all Certificate Holders need to be certified against the EU REDII requirements by the end of the transition period?
A: Yes, by the end of the transition period all SBP Certificate Holders will have to be EU REDII-compliant (in addition to being compliant with the revised SBP Standards v2.0).
Q: Is it possible for Organisations to have major and minor non-conformities when audited against the SBP Standards v2.0, but still be considered to have transitioned to v2.0?
A: All major non-conformities must be closed for a cetificate to be issued and this must happen before the end of the transition period. Rules for the management of non-conformities are given in SBP Standard 3 and Instruction Document REDII.
Q: Will the EUDR requirements be considered by SBP?
A: SBP is currently evaluating the possibility of developing support to demonstrate compliance with the EUDR.
Q: Is the Peer Review process limited to audits of the Supply Base Evaluation?
A: Yes, the Peer Review process continues to be limited to the Supply Base Evaluation (when in scope).