Is a contract, invoices and address sufficient if residues are being purchased from an industrial operator that have been processed them by its stationary shredder, i.e. wood chips, shredded bark, etc.? Does this operator still have to log in to the RED BP system and declare the data himself?

If the industrial operator is the primary owner of the raw material, it will not need to log in to the RED BP system. You, as the seller of the biomass, will be able to declare the data for him. Regardless of whether biomass is supplied or raw materials used in the production of biomass, for control purposes it is necessary to indicate the form in which the supply takes place: raw materials or biomass.

For information on the documents and information to be collected, please see here: RED BP information to be declared

If the original primary raw material owner states that the raw material is his, confirms this in the contract, in the declaration, and gives the coordinates of the plot, how do we verify that he is the primary owner of the raw material? Or even more so, that his field meets the CO2 requirements? Who bears this responsibility? What if the seller of the raw material owns a plot of land which is leased from the State?

In this case, the responsibility to make sure that the seller is the real owner of the raw material, as has always been the case before the RED BP scheme, lies with the buyer, i.e. the national biofuel sustainability scheme does not remove the buyer’s obligation to make sure that the person selling is the legal owner of the thing sold (owner, manager or user of the land). The manner in which this will be done is left to the discretion of the Exchange Participant.

Will I need to attach or upload documents related to the purchase of the feedstock with each separate declaration of sustainable biomass and transfer to the buyer?

There are 2 ways for participants to ensure data reliability:

• Attach the related accounting document to each feedstock purchase declaration;

• Accounting documents may be omitted if it is opted to have a year-end audit performed and certified to the Operator by a financial auditor that the accounting documents and feedstock quantities in the declarations are consistent with the accounting records of the particular biomass seller.

In the case of deliveries of products certified under other schemes, the accounting document shall be attached in all cases as proof that the feedstock delivered is certified.

Will there be any tolerance, transition time? Initially, it will be difficult to reconcile all contracts, invoices, declarations of ownership, intermediaries, etc.

From the point of view of the biomass seller, an important deadline will be the quarterly closure, i.e. the second quarter will have to be “closed” within 30 days, with an inventory of the stock balances (the inventory obligation is set on a quarterly basis). Once the inventory data has been entered, it will no longer be possible to enter raw materials for the inventory period. The “informal” learning period will therefore be until the end of July.