top of page
Search

Key updates on ISCC EU certification under RED III

  • Writer: Cornelia Kunze
    Cornelia Kunze
  • Jun 3
  • 5 min read

Background


The International Sustainability and Carbon Certification (ISCC) scheme is a globally recognized certification system for verifying the sustainability and traceability of biomass, biofuels and circular or waste-based materials. It ensures that feedstocks and products comply with environmental, social and greenhouse gas reduction criteria, particularly under frameworks like the EU Renewable Energy Directive (RED II/III).


ISCC certification is a key tool to demonstrate compliance in regulated markets and to support claims of responsible sourcing. The ISCC plays a central role in the certification process for waste-based biofuels, ensuring they meet sustainability, traceability, and compliance standards.


As of May 2025, the ISCC Association has more than 320 members, with an increase in members and engagement from the maritime sector.[1] Furthermore, as of December 2024, the European Commission (EC) has recognised ISCC EU for certifying Renewable Fuel of Non-Biological Origin (RFNBOs) and Recycled Carbon Fuels (RCFs).[2]


ISCC EU certifications for waste-based biofuels


There has been recent speculation about the status of ISCC EU certification for waste-based biofuels. This speculation was triggered by a meeting of the EC on sustainability of biofuels in March 2025, during which concerns over alleged fraud in biodiesel imports into Europe, particularly from China were discussed. While ISCC was mentioned during the discussions, no formal vote or decision was made regarding its suspension. However, a social media post by an individual (who did not attend the meeting) suggested that ISCC certification will be suspended.


The biofuels market reacted quickly, with:

  • Traders and importers pausing shipments certified under ISCC.

  • Price volatility in waste-based feedstocks like UCO (used cooking oil) and POME (palm oil mill effluent).

  • Increased demand for alternative certifications like RSB and REDcert.


The ISCC responded immediately and held a constructive meeting with the EC on 4 April  2025, to clarify the situation. A key outcome of that meeting was  clarification that the EC is not enacting a suspension of ISCC certification. The EC and ISCC also agreed to strengthen the certification framework, especially for waste-based biofuels.[3] 


As a result, ISCC has implemented an Integrity Programme to investigate potential non-compliance and reaffirmed its support for the Union Database (UDB) to improve traceability and compliance. Over 90% of ISCC system users are now integrated into the UDB, a key tool for improving traceability and preventing fraud.[4]


Can the EC actually suspend the ISCC EU certification?


In short, the answer is yes. Pursuant to EU legislation, the EC is empowered to recognize voluntary national schemes such as the ISCC EU scheme, and to decide whether such schemes comply with the conditions laid down in the relevant legislation.[5] This implies that the EC may suspend or even withdraw the recognition if a scheme (i) no longer meets the sustainability or GHG savings criteria, (ii) fails to ensure proper traceability or auditing, or (iii) is involved in systemic non-compliance or fraud.[6]


Before a decision to suspend or withdraw the recognition is made, the voluntary scheme will be given a chance to respond or correct issues found during a technical assessment . While Member States are consulted and may provide input, they do not have veto power over the EC’s decision. They are, however, responsible for enforcing the consequences of such a decision within their respective national jurisdictions. 


Since 21 May 2025, all ISCC EU audits (certification and surveillance) must follow the updated RED III-aligned requirements. Certificates issued before this date under RED II remain valid until their expiry. An introduction to RED III is included at the end of this article.


What are the alternatives to ISCC EU?


In light of ongoing developments and given the dynamic regulatory landscape, it may be sensible to explore alternative certification schemes to ensure uninterrupted access to the EU market. But are there real alternatives?


For waste-based biofuels, the alternatives are Roundtable on Sustainable Biomaterials (RSB), REDcert and Biomass Biofuels Sustainability voluntary scheme (2BSvs). Each has certain strengths. For example, RSB has a strong focus on traceability, anti-deforestation and social standards. 2BSvs, on the other hand, has a simpler structure which consequentially makes it more cost effective for smaller producers. Each also has varying standards as to audit rigor.


For exporting waste-based biofuels like UCO or POME from Southeast Asia, the best alternative to ISCC is probably REDcert. However, both schemes differ slightly, as is shown in the table below. In summary, ISCC is ideal for companies needing global recognition, especially those exporting to multiple markets or working with diverse feedstocks. REDcert is a strong choice for EU-focused exporters, particularly those prioritizing compliance with RED II and seeking a streamlined certification process.

Aspect

ISCC

REDcert

Scope

Global

Primarily EU, expanding globally

EU RED Compliance

Yes (ISCC EU)

Yes (REDcert-EU)

Feedstock Coverage

Broad: includes agricultural, forestry, and waste-based materials

Agricultural biomass, forestry residues, and waste-based materials

Audit Rigor

High – includes social and environmental safeguards

Moderate to high – focused on RED II compliance

Geographic Relevance

High in South America, EU, and Asia

High in EU, emerging globally

Best Use Cases

Export-oriented biofuels, agricultural feedstocks, waste-based materials

Export-oriented biofuels, compliance with EU RED II

 

Current status and RED III


As of today, ISCC EU remains fully recognized under the EU RED II framework. The EU is working on regulatory amendments to improve oversight, and by working closely with the EC to enhance the system, the ISCC is actively involved in shaping these changes. It seems that market confidence is gradually recovering, though some buyers are adopting a risk adverse/mitigation approach by diversifying certification sources.


The ISCC EU system has also been updated to align with the Renewable Energy Directive III (RED III), which amends the previous RED II directive. The EC has given a positive technical assessment for the updated ISCC EU System Documents under RED III.[7] These updates cover:

  • Biofuels, bioliquids, and biomass fuels

  • Renewable fuels of non-biological origin (RFNBOs)

  • Recycled carbon fuels (RCFs)

  • Co-processed fuels


Overall, ISCC is compliant with RED III (Directive (EU) 2023/2413) which the EU member states were required to fully transpose into their national laws by 21 May 2025. This means that the new targets, permitting rules, and sustainability criteria have become legally enforceable across the EU.


Under RED III, the new EU-wide renewable energy targets are raised from 32% to 42.5% by 2030, with an indicative target of 45% across the electricity, heating and cooling and transport sectors.[8] In the transport sector, it introduces additional binding sub-targets for renewable energy use in transport. It also promotes advanced biofuels and renewable fuels of non-biological origin (RFNBOs) like green hydrogen.


As of today, no EU member has fully transposed RED III into national law. Several countries, including the Netherlands, Spain, France, Italy and Sweden, are behind schedule, prompting the EU to announce legal measures to ensure compliance.[9]


How we add value to your project


The regulatory landscape for sustainable feedstock continues to be fluid and evolving. At DKC, we are uniquely positioned to provide advice and support to make your project a success.


DKC is a consultancy based in Asia that has the technical experience and know-how to provide operational and EU regulatory advice. Our advisory function is complimented and borne out a strong technical legal background and actual project experience of running sustainable fuel projects utilising Asian based feedstock/fuels for export to Europe.


Get in touch if you would like to discuss any of the points raised in this article or any aspect of our offering.

 



[5] The relevant EU legislation is Article 30(4) and (5) of Directive (EU) 2018/2021 (i.e., REDII as amended by REDIII). The EC can decide whether to approve or withdraw schemes such as the ISCC EU scheme by means of implementing acts

 
 
 

Recent Posts

See All

Comments

bottom of page