Bonsucro RED II transition

We are delighted to confirm that Bonsucro successfully completed the RED II technical assessment process by the European Commission.

Important update on your Bonsucro EU RED certification status

All members currently holding a Bonsucro EU RED certificate are required to sign written statement by 30 June 2021. You can download a template here. Please send it to celine@bonsucro.com and nicolas@bonsucro.com.

Under the recast Renewable Energy Directive (EU) 2018/2001 (commonly referred to as ‘EU-RED2’ or ‘REDII’), the EU sustainability criteria are extended to cover biomass for heating and cooling and power generation.

Bonsucro is one of the voluntary schemes helping to demonstrate that biofuels are sustainably produced by verifying that they comply with the EU sustainability criteria set in EU RED II.

Bonsucro applied for recognition by the Commission in line with article 30 (4) of RED II, and successfully completed the process of technical assessment by the Commission before the transposition date of the RED II (30/06/2021).

As the Commission is still to publish the Implementing Act, the full recognition of any voluntary schemes (not only Bonsucro) cannot yet be finalised.

In order to avoid any disruption to the certification process and to trade, on 8 June, the Commission has agreed to create an interim acceptance status: on the basis of the successful completion of its technical assessment, Bonsucro has officially confirmed to the Commission that Bonsucro (and its EU RED certified members) will apply EU RED II rules as of the transposition date of EU RED II.

We recognise that the notification of requiring the immediate implementation of new EU RED requirements comes at very short notice which is only the consequences of the delay by the EU to publish the required documentation and rules. To facilitate the understanding and implementation of the new EU RED II requirements, Bonsucro has compiled the summary of changes between EU RED I and EU RED II.

For all EU RED certified companies it is required that you sign and return to Bonsucro a written statement by 30 June 2021 using this template to maintain your access to EU RED supply chains.

Applicability:

As of 1 July 2021

Bonsucro Member Assessment required Evidence to be sent to Bonsucro
All economic operators currently holding a Bonsucro EU RED certificate. Must start operating in compliance with the Bonsucro EU RED Standard V1.

 

Signed written statement from the Bonsucro Member by 30 June 2021*
Their next audit (surveillance or recertification must be carried out against the Standard V1 (and other applicable standards) in line with applicable certification requirements.

 

Audit report and Certificate (+ calculator when applicable)
All economic operators currently holding a Bonsucro certificate applying for/ in the process of obtaining a scope extension to include Bonsucro EU RED certification. Must undergo a scope extension audit against the Bonsucro EU RED Standard V1 (and other applicable standards) in line with applicable certification requirements.

 

Audit report and Certificate (+ calculator when applicable)
Economic operator applying for/ in the process of obtaining Bonsucro EU RED certification Must undergo an initial certification audit against the Bonsucro EU RED Standard V1 (and other applicable standards) in line with applicable certification requirements.

 

Audit report and Certificate (+ calculator when applicable)

*  On 1 July 2021, Bonsucro will inform the certification bodies of any members who have not returned the signed written statement, in order for certification bodies to take appropriate action with regards to their certification.

Scheme documents

Bonsucro has updated its scheme documents to meet the new requirements by 30 June 2021:

Bonsucro EU-RED Standard V1

The requirements in the new Bonsucro EU-RED Standard replace requirements under Principle 6 of the Bonsucro Production Standard V4.2 and requirements in the Bonsucro EU-RED Mass Balance Chain of Custody Standard (Version 5.1). The latter two documents previously allowed compliance with requirements in the (previous) EU Renewable Energy Directive (2009/28/EC) and revised Fuel Quality Directive (2009/30/EC)’.

Bonsucro EU RED I – EU RED II summary of changes 

This document summarises the requirements of the new Bonsucro EU-RED Standard V1 for mills and for the supply chain, and specifies which old requirements are replaced (i.e. no longer applicable) and where there are relevant differences between the new and old requirements.

Please do not hesitate to contact Bonsucro should you have any question: celine@bonsucro.com and nicolas@bonsucro.com.

EU RED II transition training

On 13 July 2021, we hosted a training session on the differences between the new and old Bonsucro EU-RED requirements for mills and supply chain operators. The session was delivered by Arjen Brinkmann from Brinkmann Consultancy and included simultaneous translation to Spanish and Portuguese. If you missed it, the recordings are below. The slides from the session are available here.

EU RED II frequently asked questions

EU RED II requirements apply from 1 July 2021. Any certified members who wish to participate in EU RED must implement and comply with EU RED regulation. To minimise the administrative burden linked to additional audits, Bonsucro requests that certified members sign a commitment letter. If members do not wish to sign the letter, the matter will be handled by their certification body who is responsible for their certification. Once they have signed the letter, the certification body will decide what checks need to be done before updating the scope of their clients from EU RED I to EU RED II. The EU has indicated not expecting additional audits, but the final decision rest with the certification body. 

• If you carried out an audit before 1 July 2021 against EU RED I requirements, or started the audit before 1 July (in the case of a two phase-audit) you can finish the process against EU RED I requirements.
• If you start an audit after 1st July 2021, it has to be carried out against EU RED II requirements.

Although the European Commission does not require all economic operators (certificate holders) to undergo an early full recertification audit for the purpose of transitioning to EU RED II, the European Commission expects all economic operators to follow the EU RED II rules from 1 July when producing and trading their volumes. We have asked all Bonsucro EU RED members to return a signed letter to Bonsucro committing to EU RED II implementation from 1 July 2021.

It is the responsibility of the Bonsucro member to read the rules and implement them, especially the new requirements on information / paperwork required to sell volumes under EU RED II.
It is the responsibility of the certification body to liaise with their client and consider what level of evaluation are required against EU RED II to formalise the scope change on the certificate. Certification bodies will need to keep up to date with changes to Bonsucro requirements and for those carrying out Bonsucro EU RED audits, with the EU legislation.

Certification bodies will have to liaise with each client and assess the situation with each of them to determine the best course of action, over the next few weeks, to assess their implementation of EU RED II. It is the CBs’ responsibility to evaluate the risks associated and decide on the best course of action handle conformity assessments.

If an audit is planned for July / August 2021, and a client needs more time to be ready for an audit against EU RED II, the certification body can consider a two phase audit, where the second phase includes the audit against EU RED II requirements, or a follow up audit focussing on EU RED II requirements.

No, therefore if you wish to use the Bonsucro calculator to report your GHG emission savings you must add 4.6 gCO2/MJ to the final result.

You should only use the calculator if you use the default value – with or without land use change emissions:

Take the result display on the tab “BONSUCRO EU RED Output” cell C15
Add 4.6
Note the total – this is the default value plus any land use change emissions
calculate: [94 (new fossil fuel emission value) – total]/94 this is the total saving in %
For example if there is NO land use change:
“BONSUCRO EU RED Output” cell C15 = 24
24+4.6 = 28.6
(94-28.6)/94 = 0.695 – 69.5% saving

The default comparative value for fossil fuel is now 94 g CO2eq/MJ

he greenhouse gas emission savings from the use of biofuels, bioliquids and biomass fuels taken into account for the purposes referred to in paragraph 1 shall be:
(a) at least 50% for biofuels (GHG < 47 g CO2/MJ), biogas consumed in the transport sector, and bioliquids produced in installations in operation on or before 5 October 2015;
(b) at least 60% for biofuels (GHG < 37.6 g CO2/MJ), biogas consumed in the transport sector, and bioliquids produced in installations starting operation from 6 October 2015 until 31 December 2020;
(c) at least 65% for biofuels (GHG < 32.9 g CO2/MJ), biogas consumed in the transport sector, and bioliquids produced in installations starting operation from 1 January 2021;
(d) at least 70% for electricity (54.9 g CO2/MJ or 63.6 g CO2/MJ for the outermost regions), heating and cooling production from biomass fuels used in installations starting operation from 1 January 2021 until 31 December 2025, and 80% for installations starting operation from 1 January 2026 (for electricity production: 36.6 g CO2/MJ or 42.4 g CO2/MJ for the outermost regions).

An installation shall be considered to be in operation once the physical production of biofuels, biogas consumed in the transport sector and bioliquids, and the physical production of heating and cooling and electricity from biomass fuels has started.

For Bonsucro certified ethanol (not EU), the EU RED II calculation is not required.

Bonsucro doesn’t provide a tool to perform actual calculation adapted to EU RED II.

Certified members have to comply with the new calculation requirements from 1 July 2021. Bonsucro does not provide the tool to do the actual calculation of GHG emission savings, each member has to update their own calculation methodology (the Bonsucro calculator can only be used for the use of default value and land use change emissions)

EU RED II requirements do not allow this.

The EU indicator 6.7 refers to the carry over (non-EU can be carried over even if there is no equivalent physical volumes in stock; but EU can only be carried over if there is the equivalent volume in physical stock.

Indicator 6.8 mentions that EU volumes are valid for 1 year; non-EU RED products are valid for 3 years.

Molasses can be added if used to produce ethanol.
You can add syrup, vinasse and filter cake to a Bonsucro EU RED scope if they are used to produce a product covered by the EU RED legislation. Members can proactively request EU RED requirements to cover all their productions. It must be noted though that the EU RED Standard is intended only for the purpose of the scope of the EU RED legislation and therefore might not provide adequate requirements to match alternative use of feedstock or specific clients’ requests.

The database is still under development.
There is currently no information on what data will be required. Bonsucro is a member of the working group supporting the EU to develop the tool.

This is a financial disclosure requirement.
Support refers to financial support given by EU countries (Members States) to producers of renewable energy.
This covers European Member States direct support to the production of renewable energy.
This is mostly relevant for electricity production within the EU.
If you have received direct financial support by an EU member state to produce renewable energy covered by EU RED II certification, you should disclose it here.

‘Support scheme’ means any instrument, scheme or mechanism applied by a Member State, or a group of Member States, that promotes the use of energy from renewable sources by reducing the cost of that energy, increasing the price at which it can be sold, or increasing, by means of a renewable energy obligation or otherwise, the volume of such energy purchased, including but not restricted to, investment aid, tax exemptions or reductions, tax refunds, renewable energy obligation support schemes including those using green certificates, and direct price support schemes including feed-in tariffs and sliding or fixed premium payments.

Indicators EU 3.2 and 3.3 describe the EU RED II requirements with regards to the protection of forest.

Yes, EU RED II now also applies to solid biomass used for the production electricity and heat. Therefore to export bagasse pellet to Europe to be used in electricity and heat production, producers have to comply with the Bonsucro EU RED Standard.

New default value for ethanol is 28.6 g CO2ea/MJ

The Biograce tool has not been updated according to EU RED II, therefore it can’t be used as such. Certified operators are welcome to create their own calculation tool to provide actual calculation. The Bonsucro calculator is only available if operators decide to use the default value.

Yes you do have to.

A new actual calculation is required to maximise emission savings. Members have to develop their own methodology to do the actual calculation which will be verified by the certification body.

Members can continue to use the table provided in the Standard Guidance as they have in the past, the methodology captured in P6Agric is still valid with EU RED II.

For indicator EU 6.3, ART conversion is not allowed as the requirements indicates that the conversion shall be specific for a defined feedstock/product conversion and based on actual data. ART is not a defined feedstock or product.