Feedback on the Possible Review of the Renewable Energy Directive and its Secondary Legislation

In recent months, reports of alleged fraud involving certified imported fuels to the EU have raised serious concerns about the credibility of voluntary certification schemes under the Renewable Energy Directive (RED). Such incidents risk undermining the integrity of the system and jeopardising progress towards the EU’s renewable energy goals.

To strengthen the system’s resilience against fraud, improvements are needed across the entire value chain, from scheme owners and EU institutions to national authorities, traders, system users, and Certification Bodies. Fraud often results from failures involving multiple actors, making a holistic approach essential.

Drawing on its long-standing experience and role within the certification ecosystem, TIC Council shares its recommendations to reinforce the work of auditors and Certification Bodies to verify and certify the sustainability of imported biofuels. The proposals outlined below aim to enhance the robustness, transparency, and credibility of all RED-recognised voluntary schemes: 

Strengthening Certification Oversight

• Reinforce mandatory codes of conduct across all entities in the certification chain, including auditors.
• Require Certification Bodies to maintain a physical presence in the EU to facilitate accountability and regulatory oversight.

Improving Auditor Quality & Transparency

• Introduce compulsory training and auditor rotation to reduce fraud risk.
• Mandate public disclosure of auditor qualifications, assignments, and audit outcomes.

Enhancing Traceability & Mass-Balance Systems

• Implement robust mass-balance protocols to ensure complete traceability of certified fuels.
• Require origin verification through documentary evidence, traceability systems, and physical sampling.

Harmonising Standards and Definitions

• Standardise definitions of feedstock types, including waste vs. residue, to ensure coherent application.
• Support the introduction of regional quotas to manage feedstock sourcing and market sustainability.

Ensuring Independence of Voluntary Schemes

• Establish strong governance, with independent oversight boards and stakeholder representation.
• Call for increased Commission supervision of scheme operators’ performance and processes.

Read the full document here.

The integrity of RED-accepted voluntary schemes and its market acceptability depend on the trust that each operator lays on the system. The robustness of the system will only be the trustworthiness of each stakeholder involved. As a representative of the Certification Bodies, we are at the disposal of the European Commission and any other interested party to discuss these and other proposals.