Interpretation of ISCC Audit Key Points

Interpretation of audit points

1. Remote audit and supplementary on-site audit

The European Commission stipulates that remote audits conducted on a voluntary basis are usually supplemented by on-site audits; if the non-conformities and risks are both low, there is no need for additional on-site audits. Accordingly, if the non-conformities found in the ISCC remote audit do not lead to an increase in non-conformities or risks, there is no need for subsequent on-site audits, especially for situations that are not related to product sustainability or renewable energy directive (legal) requirements and can be rectified immediately, including but not limited to the lack of signature confirmation or internal organizational chart in the documents.

If non-conformities are found during the remote audit, the certification body and auditor need to state the reasons for not conducting a supplementary on-site audit in the audit report. If ISCC further finds other non-conformities or higher risk levels and reaches a different audit conclusion from the certification body and auditor, ISCC reserves the right to conduct a supplementary on-site audit.

In addition, regarding the time limit requirement for supplementary on-site audits, the European Commission’s regulations should be followed: "For countries that first lifted travel restrictions during this period but re-imposed travel restrictions at a later stage due to worsening conditions, the 5-month period for supplementary on-site audits starts at the end of the month when such restrictions were last lifted."

Situations that require additional on-site audits include but are not limited to the following four points.

First, non-conformities have the potential to lead to more serious non-conformities or risks, including but not limited to non-conformities with land-related sustainability requirements, and non-conformities that have a negative impact on downstream supply chain elements (such as conveying wrong information to other system operators).

Second, the risk level determined in the risk assessment is higher than the general risk, that is, medium risk or high risk.

Third, the content required by ISCC cannot be fully verified through remote formal verification (i.e., there is content that cannot be determined as "compliant" during the remote audit).

Fourth, content that does not comply with ISCC requirements is discovered during remote audits.

2. Procedure for withdrawing or correcting a sustainability claim

If an ISCC supplier provides inaccurate information (e.g. wrong GHG values) on a Sustainability Declaration (SD) to a recipient, the supplier may withdraw or correct the SD if the following conditions are met:

(1) The recipient: does not use (i.e. forward) the relevant sustainability information and withdraws and corrects the corresponding information from its mass balance;

(2) Supplier: notify the recipient and the recipient’s certification body (CB) in writing of any erroneous information or documents related to ISCC and the request to cancel or correct the corresponding SD documents;

(3) The recipient’s CB: confirms in writing to the supplier, the supplier’s CB and the ISCC that the request has been received and recorded and that the recipient has removed the erroneous information or SD file from the mass balance;

(4) Supplier’s CB: Non-conformities should be recorded in the audit files of the supplier who provided incorrect information to the recipient.

During the review, the recipient’s CB must verify that incorrect information has been cancelled or corrected in the recipient’s material balance. If the supplier or recipient changes CBs during the review, the newly contracted CB must be informed accordingly to ensure that the relevant transaction information is covered in the next audit.

summary

ISCC system documents and requirements will be adjusted and updated from time to time. During the operation of the system, especially during the review, enterprises and certification bodies need to pay attention to whether the names of the materials involved have changed and focus on verifying the consistency and accuracy of the sustainability documents to ensure that they are implemented in accordance with the latest ISCC requirements.

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