The surveillance audit of a high-risk RFNBO supply chain involving CO2 mainly focuses on traceability, in particular the verification of delivery documents and mass balances. Where relevant, this also includes the mass balance of each dependent collecting point and external storage facility. Where CO2 is used in RFNBO production, the auditor should additionally verify the origin and eligibility of the CO2, whether capture, compression and upstream transport emissions have been correctly included in the GHG calculation, and whether any exclusions apply, for example, if credits have already been granted to the CO2 or the fuel was deliberately combusted to produce CO2 for capture.
Related question: What is meant by a high-risk supply chain under ISCC EU RFNBOs, and when is a mandatory surveillance audit required?
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