Interpretation Q&As

Users of the SBP Framework are invited to raise matters requiring interpretation or clarification. The matters raised, along with their answers, are grouped according to the Standard they relate to below.

If you have any matters which require interpretation or clarification please email

Standard 1 - Feedstock Compliance Standard

Section 2.3
Q: Section 2.3 states that the BP "may be any organisation in the supply chain that takes legal ownership of feedstock or biomass." However, in the terms and definitions glossary, a BP is defined as an entity that takes physical possession of and, moreover, processes biomass feedstock; which precludes the possibility of those entities in the supply chain which do not process or gather feedstock (as well as organisations which do not take possession of or process non-feedstock biomass). Please resolve this contradiction by specifying which types of entities may and/or may not be considered Biomass Producers.

A: The glossary definition should be read as: Biomass Producer (BP): A legal entity, which ordinarily processes feedstock for conversion into biomass (or gathers biomass, such as wood chips) suitable for power generation.

SBP requires that a legal entity takes on the responsibilities of the BP as specified in the Standards. To comply with the SBP Standards this entity must also hold legal ownership of the biomass.

As per Standard 1, section 2.3, the BP will usually be an organisation that operates a facility, such as a pellet mill.

Where a parent company owns or operates multiple pellet mills each of these mills is a BP.

As per Standard 1, section 2.3, the BP role may be taken on by an entity that does not process or convert biomass, such as a forest owners' cooperative.

Section 2.4: Locally Applicable Verifiers
Clarification: In undertaking an SBE, all BPs must prepare Locally Applicable Verifiers (LAVs). Standard 1 includes examples of Means of Verification, but these may not be appropriate to the Supply Base. LAVs are Means of Verification for each indicator in Standard 1 locally appropriate to the Supply Base of the BP.

BPs are required to consult with stakeholders in determining appropriate LAVs (Means of Verification) to help ensure that appropriate evidence is used to evaluate risk against each indicator.

Although the LAV procedure must be followed for each SBE, modification of indicators is only required in the specific cases detailed in Instruction Note 1A.

Instruction Note 1A, section 3.2
Q: Regarding the risk assessment process, are Certification Bodies permitted to add additional indicators over and above those in Standard 1, or even to create their own risk assessment process for clients to follow?

A: A Certification Body can make additional requirements provided these are in compliance with Standard 1, Instruction Note 1A, 3.2. The SBP indicators cannotbe modified without approval from SBP. Modification of the process would need to ensure that all requirements are met and any additional requirements would need to be carefully managed and explicit to ensure the credibility of the process and avoid a conflict of interest arising between the certification body and its client.

Instruction Note 1A, section 6.1: Instructions for Biomass Producers for the development of Locally Applicable Verifiers

Erratum: The word "Standard" should be replaced with "Supply Base Report".

Standard 2 - Verification of SBP-compliant Feedstock

Section 6
Q: Does a BP sourcing only material with an FSC 100% claim with a declaration in the supplier contract to the effect that the supplied material must only come from a specified country still have to source additional records to prove the origin and place of harvesting? The situation is quite clear for uncertified or controlled material where the origin has to be proved anyway due to the FSC/PEFC requirements. However, for FSC/PEFC-certified material the traceability is assured, therefore is a declaration in the supplier contract sufficient?

A: The CB would need to determine if the FSC/PEFC certification was enough or if additional due diligence was required.

Section 6.2
Q. SBP Standard 2 section 6.2 “The BP shall record the place of harvesting and the identity of the primary wood processor responsible for the supply of inputs classified as SBP-compliant secondary feedstock”. Would it be sufficient if the biomass producer would know the region/country to prove that the material comes from designated SB?

A. The Standard requires that the BP is able to record the place of harvesting such that it can be confirmed if the place of harvesting is within the Supply Base. The place of harvesting may never be larger than a country but may be any smaller geographic area, including a county, region, or state.

Section 8.2
Q: Is material procured under the SFI Fiber Sourcing standard recognised under the SBP rules? If not, is this something that is being revisited given the release of the new SFI Standards, and the FS standard as a stand-alone piece?

A: SFI Fiber Sourcing is not considered to be SBP compliant as regulators in key biomass importing countries do not currently recognise it as demonstrating compliance with their sustainability criteria. Therefore, SBP would only be in a position to review its position if the relevant regulatory authorities revise their interpretations.

Q. Can salvage, sanitation, and fire-prevention cuts be automatically accepted as being "sustainable."?

A. Salvage, sanitation, and fire-prevention cuts are not exempt from the evaluation of sustainability and must comply the SBP requirements for primary feedstock.

Q. How is woody feedstock sourced from plantations established for production of non woody products (e.g. rubber) considered in SBP?

A. Woody feedstock sourced from plantations established for production of non woody products (e.g. rubber) must comply the SBP requirements for primary feedstock.

Q. A BP wishes to producer SBP certified pellets made from lignin. The lignin is a residue from bioethanol production and the trees were harvested 25-30 years ago. How could compliance with SBP sustainability requirements be demonstrated?

A. SBP considers that lignin residue is not woody biomass and therefore not within the scope of SBP certification.

Q. Can Pre-Commercial thinning automatically be considered as being "sustainable"?

A. Pre-commercial and commercial thinnings are not exempt from the evaluation of sustainability and must
comply the SBP requirements for primary feedstock.

Section 9: Clarification of management system, SVP and mitigation measures in risk reduction

Clarification: In evaluating risk against the indicators in Standard 1 the BP is required to evaluate the risks that result from a combination of factors that are related to the woody biomass found in the Supply Base and the management system of the BP. This requires both evaluation of the risks associated with the feedstock and the impact of the BP management system.

In some instances the risk may be low as a result of factors outside the influence of the BP, such as the nature of the forest type or a strong regulatory framework combined with effective enforcement.

Risk may also be altered by action taken by the BP such as sourcing policies, mapping of high risk areas or undertaking supplier audits. It may not always be clear if these interventions are part of the BP management system, Supplier Verification Program or mitigation measures. An example of this would be a BP’s decision not to purchase from particular suppliers that are associated with particular risks. Activities that may be part of the SVP for one BP may be considered part of the management system of another BP, for example, because the BP has been implementing field audits for a long time.

Where the action of the BP reduces the risk (as a result of the management system, SVP or mitigation measure) then the effectiveness of this action needs to be monitored by the BP either as part of operating an effective management system, as part of monitoring the SVP, or as part of monitoring mitigation measures. The justification for low risk, either as a result of external factors or as a result of actions taken by the BP, must be documented.

In evaluating compliance of the BP the CB is required to evaluate the actions of the BP in reducing risk whether as part of the management system, SVP or mitigation measure.

Where a BP’s SBE concludes low risk, a neighbouring BP with an identical Supply Base may not necessarily conclude low risk because of differences between the BPs, for example in their management system.

Section 10.1
Erratum: "Where a Supply Base covers more than one country (or regions where different legislative jurisdictions apply) then each must be considered a separate subscope.” should be replaced with "Where a
Supply Base covers more than one country (or regions where different legislative jurisdictions apply) then each may be considered a separate sub-scope."

Section 13: Relationship between the BP and CB consultation processes

Clarification: BPs are required to complete a stakeholder consultation as part of the SBE with the intention that stakeholders have an opportunity to help identify risks in the Supply Base. The consultation may be combined with the LAV consultation process. The requirement that “Stakeholders shall be provided with adequate information as a basis for informed comment” includes the requirement to provide a copy of or access to (for example, via a web-link) SBP Standard 1. Findings from the stakeholder consultation are used to inform the SBE.

The CB stakeholder consultation process should take place once the BP stakeholder consultation is complete and it should be completed by the time of the CB onsite audit. In that way the process informs the CB audit, including evaluation of whether stakeholders’ comments were adequately addressed by the BP. Additional stakeholder engagement during or after the audit may be appropriate to follow up on issues identified.

Instruction Note 2A, Section 1.5
Q: Section 1.5 states: “Suppliers selected by the BP for monitoring purposes should be different to those who have been selected for evaluation by the CB, except in situations where actions to address complaints or evaluate risk factors require verification.” How does the CB select the sample of suppliers to be evaluated, since this is not covered in Standard 3? What qualifications are needed for auditors conducting on-site monitoring of suppliers who are forest owners?

A: CBs need to justify the sampling techniques and the competence requirements of personnel. It is expected that both these would be based on processes included in the CBs’ sampling procedures for accredited SBP-approved Forest Management Schemes and that auditors can demonstrate relevant forest auditing competencies.

CBs are required to audit the BP management system and mitigation measures. Where the BP management system or mitigation measures extend to activities such as monitoring forest operations then CBs are required to audit these aspects of the BPs operation to evaluate compliance.

Instruction Note 2A, Section 8.4

Q: Can feedstock sourced from within a SB where a SBE is completed and found to be compliant with SBP requirements (including low-risk against all indicators in SBP Standard 1. Feedstock Compliance Standard) be classified as SBP-compliant feedstock if the feedstock is harvested on property owned or managed by the BP?

A: Yes.

Instruction Note 2C

Q: Regarding the Supply Base Report Template for Biomass Producers and Supply Base Report Template for Biomass Producers Annex 1, does the Annex 1 document need to be made publicly available as well the report? If, so why are they separate documents?

A: Annex 1 needs to be made publicly available where a Supply Base Evaluation is completed. A Supply Base Report needs to be completed by all Biomass Producers.

Standard 3 - Requirements for Certification Bodies

Q. The SBP Standards don’t specifically address multi-site auditing techniques, but other standards do allow the application of multi-site methodologies. Can such an approach be used under the SBP Standards, provided International Auditing Guidance is followed?

A. SBP only allows one BP site per certificate. SBP considers each pellet mill to be a BP. Multi-site approaches only extend to multiple operational locations within the scope of one BP, e.g. a pellet mill operating two port facilities where the operational locations are subject to the conditions specified in IAF MD1. Each BP requires an on-site audit annually.

Section 2
Q. Section 2 states: "Lead auditors and personnel in the review and certification decision-making process shall have completed an SBP-approved training course." What is the process for getting a training course approved by SBP?

A. Training courses are currently provided directly by SBP. There are currently no plans to approve third party training courses.

Q. How do CBs achieve accreditation to Standard 6?

A. For those countries that have specified requirements, for example, the Netherlands and the UK, it is possible to implement Standard 6. However, for Belgium, SBP is currently working with the national regulators to define the requirements. CBs may apply to SBP for approval to certify against Standard 6 for specific countries.

Section 5
Q. Can CBs operate SBP certification beyond the scope of the relevant FSC/PEFC or SFI accreditation?

A. During the approval process, prior to accreditation, CBs may operate SBP certification from an office other than the legal entity holding FSC®, PEFC or SFI accreditation provided that the CB can demonstrate that the accredited systems and procedures are effectively implemented in providing SBP certification.

Q. SBP has stated that during the approval process, prior to accreditation, CBs with multiple offices may hold SBP-approval at an office other than the legal entity holding FSC®, PEFC or SFI accreditation provided
that the CB can demonstrate that the accredited systems and procedures are effectively implemented in providing SBP certification by the approved office. Does 'multiple offices' include contractors?

A. A CB may not hold SBP-approval at an office of a contractor.

Section 5.2
Q. The technical scopes of the accreditation must match as specified in Standard #3, section 5.2 which states "For CoC certification, CBs shall hold valid FSC®, PEFC, or SFI CoC accreditation. The scope of the accreditation (supply chain or forest management) shall be equivalent to the applicable scope for SBP certification (supply chain or BP’s management systems evaluation)."

A. Where a CB wishes to extend the geographic scope for SBP certification beyond that held for FSC®, PEFC, or SFI then the CB must demonstrate adequate evidence of competence to offer SBP certification.

Section 6
Q. If an applicant for SBP certification is operating an approved CoC system is the CB required to check that the CoCsystem is operating or can the fact that the applicant holds a valid certificate sufficient evidence?

A. Standard 3 sets out requirements for CBs conducting main assessments (including sections 6 and 7) and for
surveillance audits (including Instruction Notes). These requirements are additional to confirming that the applicant holds a valid CoC certificate. The requirements include that the CB confirms that the organisation’s management system is capable of ensuring that all requirements of the standards are implemented across the entire scope of the evaluation. This includes analysis and description of the:

  • Structure, operation, inputs and outputs
  • CoC system
  • Critical control points
    Note also that Standard 3, section 6.4 requires the CB to implement the requirements as specified in the table.

Section 8
Q. Do lead auditors need to be qualified Lead Auditors for forest management or chain of custody in relevant SBP-approved schemes?

A. Standard 3 section 8.2 requires that CB “personnel shall be competent for the functions they perform, including making required technical judgments, defining policies and implementing them.” It is unlikely that this requirement can be met for Lead Auditors or Technical reviewers unless they are qualified Lead Auditors for forest management or chain of custody in relevant SBP-approved schemes.

Section 9
Q. Is the definition of stakeholders the same as that used in the FSC system?

A. FSC-STD-20-006 is referred to as good practice and stakeholder is defined there as "Any individual or group whose interests are affected by the way in which a forest is managed". Use of another definition would need to be justified.

Q. Does the Certification Body stakeholder consultation process only apply in situations where a Supply Base Evaluation has been done and will the Certification Body be working on the list of stakeholders provided by the Biomass Producer? Is it correct to assume that if the Biomass Producer does not need to do a Supply Base Evaluation there is no need for stakeholder consultation at all?

A. A stakeholder consultation by the Certification Body is required irrespective of the Supply Base Evaluation process.

Standard 3, Section 9.3 states: "The Certification Body (CB) shall consult with stakeholders included in the Biomass Producer's (BP's) Supply Base Evaluation (SBE) consultation and the Locally Applicable Verifiers (LAVs) process. As a part of the CB consultation the CB shall determine if stakeholders' comments were adequately addressed by the BP.” This requires that where an SBE is completed the stakeholders engaged with by the Biomass Producer are also engaged with by the Certification Body.

Section 9.4
Q. Must the CB allow one month to elapse between receiving the comments from the BP on the SBE and undertaking the CB stakeholder and conducting the audit?

A. In theory the process could be completed in 1 month with both the BP and CB stakeholders processes happening in parallel. There are credibility risks associated with that approach, including stakeholders not having opportunity to comment on the outcomes of the SBE, which the CB would need to consider in its evaluation.

Section 10
Q. Section 10 requires that the CB prepare a public summary report for each BP to which a certificate is issued. Is a public summary report required for non-BP certificate holders (e.g. biomass brokers and distributors)? If so, will SBP create a public summary report template for non-BPs?

A. A public summary report is only required for the BP.

Section 13.4
Q. Does the BP have to sign the Trade Mark Licence Agreement even if it is not willing to use the SBP trademark? (The FSC scheme requires it as the agreement contains other points not directly connected with trademark use.) Further, is use of the SBR template considered to be use of the SBP trade mark? There may be cases where the organisation doesn't want to use the SBP trade mark, but still must use the official template for the SBR.

A. Use of the trade mark includes using the term "SBP". Any company making an SBP claim needs to sign the agreement.

Instruction Note 3D, section 1.9.1
Q. The minor non-conformity close-out timeframe is up to one year but other accreditation requirements require shorter close-out.

A. Standard 3, section 1.9.1 states "Minor non-compliances shall be corrected within one year (under exceptional circumstances, within two years)." This is a maximum timeframe. CBs may elect to reduce the timeframe.

Standard 4 - Chain of Custody

Section 5.1.1
Q. Is it correct that a Biomass Producer cannot have SBP certification on its own, that is, it also needs to have FSC and/or PEFC and/or SFI certification as well, even if the Biomass Producer has no FSC- or PEFC-certified feedstock?

A. Correct. There is no bespoke SBP Chain of Custody control system. Implementing an SBP-approved Chain of Custody (CoC) system and a valid certificate is required in order to be able to make an SBP claim.

Section 5.1.2
Q. Where a legal owner is operating an FSC transfer system, can biomass with different SBP claims (SBP-compliant and SBP-controlled) be physically mixed (for example, in a ship) and the biomass still retain the SBP-compliant and SBP-controlled claims? 

A. A legal owner operating an FSC transfer system may physically mix batches of biomass with different SBP claims and the output batches of biomass may retain their original input claims. 

Although SBP requires that legal owners operate an SBP-approved CoC system (FSC, PEFC or SFI) to determine output claims, it differs from FSC in that material with different claims may be mixed as long as the material is sold in proper proportions to the original claims. Within FSC, implementation of the transfer system requires that if there is physical mixing of inputs with different claims then only the lowest claim may be used for outputs.

SBP differs from FSC in two important respects in relation to CoC claims. Firstly, SBP does not have an equivalent of the FSC 100% claim, which indicates that all ‘atoms’ in a product carrying that claim originated from an FSC certified forest. Instead, the SBP standards state that SBP-compliant biomass “may physically contain SBP-compliant feedstock, Controlled Feedstock or EUTR-compliant biomass”.

Secondly, SBP requires implementation of a Production Batch system which ensures that SBP claims are retained and cannot be transferred between batches, even if batches are physically mixed. This principle is supported by the implementation of the SBP Data Transfer System (DTS). Additionally, SBP does not permit claims to be transferred between physical batches using ‘book and claim’ techniques as SBP states (in Instruction Document 5A v1.1) that the Permitted Use of a Transaction Claim is that it “must remain consistent with the physical biomass to which it relates. If the biomass is destroyed, or is sold to a customer who is not an SBP Certificate Holder, the claim must also be destroyed. A Transaction Claim may only be 'detached' from the physical biomass to which it relates when the biomass is burned by an End-User for the purpose of generating electricity or heat.” Put simply, batches may be physically combined as long as their Transaction Claim follows the same proportional weight of material as outputs that entered the system as inputs.

As such, SBP does not consider that the physical mixing of biomass with different SBP claims under an FSC transfer system necessarily requires that the lowest claim be allocated to all outputs.

SBP Standard 4, section 5.1.2 states that “The legal owner shall implement all aspects of the SBP-approved CoC system requirements for the SBP feedstock and biomass. Where there is a conflict between the requirements in the SBP-approved CoC system requirements and those specified in the SBP standards, the SBP standards shall have precedence.”

With reference to SBP Standard 4, section 5.1.2 and the absence of a 100% claim, the implementation of both the Production Batch system and the DTS and the definition of a Permitted Use of a Transaction Claim, SBP concludes the following: A legal owner operating an FSC transfer system may physically mix batches of biomass with different SBP claims and the output batches of biomass may retain their original input claims.

Section 5.1.2
Q. Can a BP that is operating an FSC percentage system use that system for SBP as there is no SBP percentage claim?

A. A BP that is operating a percentage based control system for purposes other than SBP certification may adopt it to control SBP claims. As there is no SBP percentage claim, a proportion of biomass up to the equivalent of the percentage claim may carry the 'SBP-compliant biomass' claim.

Section 5.2.2
Q. Standard 4, section 5.2.2 states "Only the following feedstock inputs shall be considered to be SBP-compliant feedstock [3rd bullet]

  • Feedstock sourced within the scope of the BP’s own SBP-approved Chain of Custody (CoC) System Certification, for example, non-certified reclaimed feedstock sourced in compliance with FSC-STD-40-007: FSC Standard for Sourcing Reclaimed Material for Use in FSC."

A. Notice is drawn to FSC-STD-40-007: FSC Standard for Sourcing Reclaimed Material for Use in FSC Annex I: Examples of reclaimed wood material which states that the following products are not considered to be reclaimed "Co-products from virgin parent materials (example: Offcuts, shavings, sawdust, and the like, generated during primary manufacture of logs)."

Section 5.5.4
Q. Standard 4, section 5.5.4 states "5.5.4 'SBP-compliant biomass' is biomass which is produced in compliance with all relevant SBP standards using the rules of an SBP approved Chain of Custody (CoC) System and is derived from SBP compliant primary feedstock. It may physically contain SBP compliant feedstock, Controlled Feedstock or EUTR-compliant biomass."

A. Standard 4, section 5.5.4 would more correctly read "'SBP-compliant biomass' is biomass which is produced in compliance with all relevant SBP standards using the rules of an SBP-approved Chain of Custody (CoC) system and is derived from SBP compliant feedstock. It may physically contain SBP-compliant feedstock, Controlled Feedstock or EUTR-compliant biomass."

Standard 5 - Collection and Communication of Data

Q. If a Biomass Producer had FSC certification and was using exclusively FSC feedstock, could it use the energy and carbon balance data gathering standard on its own and supply the biomass as FSC-certified along with the carbon data without being SBP-certified?

A. The energy and carbon balance data could be certified, but it is not clear how this could be linked to biomass carrying an FSC claim without SBP certification of the biomass. SBP is currently exploring the data transfer component and how it might facilitate trade more widely (e.g. quality aspects as well as sustainability characteristics).

Q. What is to stop FSC and PEFC setting up their own energy and carbon balance systems as optional modules and supplying the feedstock as FSC- or PEFC-certified, thus cutting SBP out of the equation. Would the power generators accept this?

A. SBP is actively working with PEFC to develop a greenhouse gas (GHG) module that would mean a legal owner could just be PEFC-certified with the GHG module, thereby not requiring SBP certification. It is SBP’s stated intention to promote FSC and PEFC certification.

Q. Is certification against standard 5 compulsory or optional? Can the BP be certified against standards 1 to 4 first, and against standard 5 afterwards?

A. Certification against Standard 5 is optional and may be added later. If an organisation is not certified against Standard 5 no claim may be made about any carbon or energy data supplied until it is certified against Standard 5.

Section 7.2
Erratum. "Each legal owner is required to pass information relevant to each batch of pellets to the next legal owner and enduser, including sustainability and carbon and energy data." The word "pellets" should be replaced with "biomass".

Instruction Document 5A
Q. Regarding the energy and carbon balance data gathering process, if the Biomass Producer is the unit of certification, how is the data that applies to the forest (and is presumably provided by the forest owner or harvester) verified as being accurate and correct? Instruction Document 5A, Section 3 “Feedstock Inputs” carries a lot of data applying to the feedstock source, how would these data be validated? Would there be a need for the Certification Body to carry out site level assessments at forest source?

A. Developing the data specifications in Instruction Note 5A is an ongoing task, which informed by the regulatory requirements as the regulators themselves define what they require. Guidance will be forthcoming.

Instruction Document 5A, Section 2.2
Q. Is it possible to assess a BP that has not commenced commercial production, only test production? In such a case the reporting period would include only a few batches of production, would that be allowed? And if so, is there a minimum length of reporting period?

A. Yes, it is possible to audit and certify a BP during commissioning. There is no minimum reporting period, and it may be appropriate to use engineering values for a start-up operation. Note, however, that an additional audit may be required if there is a significant change in the operation and associated GHG values, such as reaching full productivity.

Instruction Document 5A, Section 6.1
Q. SBP Instruction Note 5A, section 6.1 states "For roundwood from final fellings from forest types typically grown in rotation times of more than 40 years, the average% of the volume of harvested wood from
these final fellings that was delivered to the biomass producer.

Note: The average % of the volume of harvested wood going to the BP may be based on a representative sample of plots.

Note: Data does not need to be collected for roundwood from thinnings or roundwood from final fellings from forest types with a typical rotation time of less than 40 years."

A. For clarification, the 2 Notes relate only to the last bullet point.

Instruction Document 5A, Section 7
Q. SBP product groups – is it correct that if secondary feedstock is delivered with an FSC/PEFC 100% claim then it shall be considered as product group No. 6: SBP-compliant secondary feedstock, rather than product group 4 or 5 which are controlled only?

A. Yes, product group No. 6 is the correct definition of secondary feedstock with an FSC/PEFC 100% claim. Secondary feedstock received with a ‘Controlled’ claim would be categorised as product group No.4 or No 5.

Standard 6 - Energy and Carbon Balance Calculation

Currently no interpretation matters have been published for this Standard.

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