On December 21, 2018, Directive (EU) 2018/2001 (REDII) came into force, in which operators of plants for the generation of electricity or heat from biomass are obliged to provide evidence of the sustainable generation and use of biomass.
In a transitional period, the member states had time until 1 July 2021 to transpose the directive into national law. The economic operators concerned can provide proof of sustainability via voluntary certification schemes that are approved by the European Commission for this purpose.
Since then, only a few EU member states have managed to create the legal requirements for implementing the REDII on time, and the European Commission has not yet been able to fully complete the recognition procedures for the voluntary schemes. One reason for this is that the European Commission has greatly delayed the process of publishing the delegated legal acts, which serve as the basis for both the national implementation and the recognition process of the voluntary certification schemes.
On the other hand, quite a few economic operators are faced with the challenge of concluding supply contracts for sustainable biomass fuels for the coming year or ensuring that this year's harvests are REDII-compliant. For example, biomass fuels that are used in the European emissions trading scheme must provide proof of sustainability by January 2022 at the latest in order to continue to be counted as CO2-neutral. This in turn requires a timely REDII certification of the entire supply chain and the early recording of sustainable biomass long before the deadline.
Even if the recognition process for the voluntary schemes has not yet been completed, the European Commission has reacted, particularly with a view to the continuity in the biofuel sector. In a communication to the voluntary schemes EC proposed a transitional regulation, according to which those voluntary schemes, which were able to successfully complete the technical assessment of the relevant scheme requirements by 30 June 2021, are allowed to carry out audits according to the specifications of the REDII under certain conditions. This also includes SURE (see https://ec.europa.eu/energy/topics/renewable-energy/biofuels/voluntary-schemes_en?redir=1#recognition-criteria).
The SURE-EU-System has successfully completed this technical assessment for the entire scope of electricity or heat generation from agricultural or forestry biomass as well as biogenic waste and residues and received confirmation to start, based on the assessed scheme documentation, certification according to the rules of the REDII already in the transition period until SURE is officially recognized. The scheme documentation of the SURE-EU-System was therefore updated as of 30 June 2021 and has been the basis for the audits (initial and recertification as well as surveillance audits) since 1 July 2021.
SURE expressly points out that further scheme adjustments will be necessary in the light of the expected implementing acts. These must be implemented and checked accordingly both by the schemes themselves and by the already certified economic operators. For this purpose, SURE follows all processes related to the REDII and carefully implements all the requirements of the European Commission and the competent national authorities.
The scheme documentation published on the SURE website always reflects the current status and is constantly updated. The different versions can be identified by the version number of the documents and their publication date. SURE will point out the essential changes to the previous versions; all changes in the documentation can also be found in the revision history in the documents.
Even if this approach does not represent an ideal from the point of view of SURE and involves additional effort and a certain "residual risk" for all those involved with regard to possible process adjustments, a number of challenges of a timely proof of sustainability can already be met by this and the certification process in the company can now be initiated without further delay.