Robustness of GHG emission verification and certification of biofuels – a case study of selected (SAF) supply chains and policies

Feb 2025
Publications

The SAF market is growing rapidly and, due to its inherent international character, it is subject to various (inter)national policy frameworks related to sustainability claims, in particular the reduction of greenhouse gases (GHG).

Biofuels policy frameworks exhibit a diversity of underlying rules and methodologies for calculating and accounting for GHG emissions and differ in the degree of stringency and robustness. Policies use verification/certification for the implementation of these rules. This study, performed within the framework of IEA Bioenergy Task 39 (Biofuels to decarbonize transport) aims to identify opportunities for policy makers to increase the robustness of GHG related verification/certification aspects in international biofuel supply chains, especially for SAF.

The SAF related policy frameworks within scope (with underlying verifications /certification activities) are: California Low Carbon Fuel Standard (LCFS), EU Renewable Energy Directive (RED), Brazilian RenovaBio, US Inflation Reductino Act (IRA) and ICAO Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA). The focus is on the currently operational SAF supply chains of HEFA and Alcohol-to-Jet (from feedstock sourcing up to aircraft refueling).

Report (in slide deck form): Improvement opportunities for policies and certification schemes promoting sustainable biofuels with low GHG emissions

Annex: Factsheets on sustainability policy frameworks

Six main sensitivities regarding the robustness of GHG emission verification and certification of SAF have been identified.

  1. Differences in data quality and transparency of supply chain data reduce visibility and traceability of GHG emissions and complicate data verification.
  2. Differences in GHG targets and calculation methodologies increase complexity for the exchange of SAF between policy frameworks.
  3. Labelling and classification of feedstock materials diverge in policies and could pose a risk since feedstock categorization is linked to GHG performance.
  4. Different implementation of policies into verification/certification usage and requirements hinders mutual exchange.
  5. Requirements for auditor competence vary, which can impact the quality of the auditing on certification/verification.
  6. Potential misuse and double counting could occur with SAF trade.

These sensitivities mostly affect actors who are working on the intersect of the different policies, such as certification/verification schemes and their auditors, supervising bodies and SAF producers.

Conclusions and recommendations:

  • Policy differences create a challenge for international SAF supply chains as feedstocks and SAF batches need to fulfill all the sustainability requirements set out in any policy where they may be used. Flexibility between policy frameworks is not possible and double certification is costly.
  • The policy differences, lack of transparency and traceability between countries, different certification/verification schemes and registries might create a risk regarding double counting of GHG savings. This could lead to higher reported total GHG savings than actually achieved in practice.
  • An opportunity to increase the robustness of SAF policy frameworks is to ensure a level playing field and harmonized implementation rules to the greatest extent possible. Cover hard to harmonize discrepancies between frameworks in the short term by means of mutual agreements. For the long term, by means of complementary (regional) regulations.

 

Different policy frameworks target different parts of the SAF supply chain.