The Installation Consuming RFNBOs scope closes a traceability gap that arises when RFNBOs are consumed as intermediates rather than sold as final fuels, for example, in refinery hydrotreating, HVO production, or other industrial processes.
When fuels under RED III are counted toward the industry target under Article 22a or the transport target under Article 25, Member States must require relevant economic operators to record accurate transaction and sustainability data in the Union Database from the point of production to the point at which the fuels are placed on the market in the European Union. RED III also requires that data be verified and links that verification to Implementing Regulation (EU) 2022/996. (RED III, Directive (EU) 2023/2413, Article 31a(2) and 31a(5); Implementing Regulation (EU) 2022/996, Article 10)
As a result, an installation that consumes RFNBOs as intermediates for a RED claim cannot sit outside the certified supply chain. It must be included as a certified supply chain element so that sustainability characteristics, quantities, and transaction data remain verifiable and auditable throughout.
Related FAQ articles:
What is the use case for the Installation Consuming RFNBOs scope under ISCC EU?
How is the Installation Consuming RFNBOs scope audited under ISCC EU?
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