If an installation consumes RFNBOs as an intermediate and uses that volume to support a claim under Article 22a or Article 25 of RED III, the installation must be treated as a certified supply chain element. In ISCC terms, this means the site must be certified under the scope Installation Consuming RFNBOs and requires full traceability of incoming volumes, auditable mass balance and verified transaction data continuity up to the point where the claim is made.
The scope covers installations that consume certified RFNBOs as fuel or feedstock in a further process and then make a renewable claim linked to RED accounting. In practice, this scope includes sites such as refineries and other conversion plants that receive RFNBO hydrogen or methanol and use it in a subsequent production step.
The Installation Consuming RFNBOs scope is about verified intermediate use. It does not confer RFNBO status on the downstream output. The Commission guidance and the Q&A on the implementation of the hydrogen delegated acts make this clear for refinery cases. RFNBOs used in refineries as intermediates for conventional transport fuels or biofuels may count toward Article 25, while the resulting conventional fuels remain conventional fuels. Likewise, RFNBOs used in refineries to produce industrial products consumed in industry may count toward Article 22a. (Commission Guidance on RFNBO Targets, Sections 2.4 and 5; Q&A on the Implementation of the Hydrogen Delegated Acts, Q56)
The scope should therefore be understood as a traceability and accounting scope. It keeps the verified RFNBO intermediate volume within the certified chain until the RED claim is made.
Related FAQ articles:
Why was the ISCC EU scope Installation Consuming RFNBOs introduced?
How is the Installation Consuming RFNBOs scope audited under ISCC EU?
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