EN    EN EN 
 
EN    EN  EUROPEAN COMMISSION 
Brussels, 31.1.2011 
SEC(2011) 129 final 
  
COMMISSION STAFF WORKING DOCUMENT 
Report on the operation of the mass balance verification method for the biofuels and 
bioliquids sustainability scheme in acco rdance with Article 18(2) of Directive 
2009/28/EC 
  
Accompanying document to the 
  
COMMUNICATION FROM THE CO MMISSION TO THE EUROPEAN 
PARLIAMENT AND THE COUNCIL 
  
Renewable Energy: Progressing towards the 2020 target 
 
 
{COM(2011) 31 final} 
 
EN 2   EN 1. INTRODUCTION  
The EU has introduced the most comprehensive and advanced binding sustainability scheme 
of its kind anywhere in the worl d. The Renewable Energy Directive1 sets out sustainability 
criteria for biofuels and bioliquids. For biofue ls, corresponding criteria ar e set out in the Fuel 
Quality Directive2. They apply to biofuels and bioliquids  produced in the EU and to imported 
biofuels and bioliquids. The sustainability scheme became operational on 5 December 2010, 
the deadline for Member States to tran spose the Renewable Energy Directive.  
The sustainability criteria rela te to greenhouse gas savings, la nd with high biodiversity value 
and land with high carbon stock. In  relation to the criteria th ere are three elements which 
Member States need to ask fr om economic operators: these are that they submit information 
on the compliance with the criteria3, arrange for an adequate standard of independent 
auditing4, and use a mass balance system5. The mass balance system is a key element of the 
sustainability scheme, providing the method by which a connection is made between 
information or claims concerning raw mate rials or intermediate products and claims 
concerning final products. The Directives re quire the Commission to report by December 
2010 on the operation of this method. This is the report complying w ith that obligation6. 
2. THE MASS BALANCE SYSTEM  
Typically, biofuels/bioliquids have a produc tion chain with many links, from field to 
distribution of the fuel. Feedstoc k is often transformed into an  intermediate product and then 
into a final product. It is in relation to the fi nal product that compliance with the requirements 
of the Directives need to be s hown. To show this, claims will need to be made about the raw 
material and/or intermediate products used. 
The method by which a connection is made betw een information or claims concerning raw 
materials or intermediate produc ts and claims concerning fina l products is known as the chain 
of custody. The chain of custody would normally include all the stages from the feedstock 
production up until the release of the fuels for consumption.  
The method laid down in the Directives for th e chain of custody is the mass balance method. 
This requires a physical link between all stages  (as opposed to 'book and claim' systems where 
after feedstock production the sustainability information7 and the raw material are traded 
separately from each other). However, the ma ss balance system does allow sustainable and 
other8 raw materials to be mixed (as opposed to physical segregation systems, also called 
'track and trace' or 'identity preservation'), as  long as the combination of all consignments 
                                                 
1 Directive 2009/28/EC on the promotion of the use of energy from renewable sources and amending and 
subsequently repealing Directives 2001/77/EC and 2003/30/EC, OJ L 140/16 of 5.6.2009 
2 Directive 98/70/EC as amen ded by Directive 2009/30/EC 
3 Article 18(3) of the Renewable Energy Directive;  Article 7c(3) of the Fuel Quality Directive.  
4 Article 18(3) 
5 Article 18(1) 
6 Article 18(2) 
7 E.g. in the form of a certificate 
8 Not complying with the sustainability criteria or lacking the evidence of compliance.  
 
EN 3   EN taken out of the mixture ha s the same sizes for each of the sets  of sustainability characteristics 
that were in the mixture. 
2.1. The operation of the mass balance system 
Much work has been done by Member States, industry and NGOs in order to implement the 
sustainability scheme. The Commission has give n guidance on the mass balance system in its 
Communication on voluntary schemes and default va lues in the EU biof uels and bioliquids 
sustainability scheme9. However, as the sustainability  scheme became operational on 5 
December 2010, little information is yet av ailable on its operation in the market. 
2.2. Assessment of verification methods 
The Directives require the Commission to report on the operation of the mass balance 
verification method and on the pot ential for allowing for other ve rification methods in relation 
to some or all types of raw material, biofuel or bioliquids. The factors in the assessment 
concern the need to maintain the integrity and ef fectiveness of the verification system (i.e. the 
ability of the regime to deliver greenhouse ga s and biodiversity impacts) while avoiding the 
imposition of an unreasonable burden on industry.10 
The Directives require in particular the c onsideration of verification methods in which 
information about sustainability characterist ics need not remain physically assigned to 
particular consignments or mixtures. Such  systems are also known as 'book and claim' 
systems where, after feedstock production, the su stainability information and the raw material 
are traded separately from each other.  
The Commission assessed the book and claim sy stem and the mass balance system in 2008.11 
It concluded that the book and claim method ha s the disadvantage of lower effectiveness and 
that the mass balance method is effective t hough with somewhat higher costs for economic 
operators than the book and cl aim method. At this point in time there are no essential new 
elements to add to that assessment.  
In terms of integrity and effec tiveness, if sustainability cr iteria using book and claim would 
cover all or most of the production of a particul ar agricultural commod ity – and thus not only 
the relatively small volume used for biofuels an d bioliquids – the inte grity and effectiveness 
would be high. Such voluntary sustainability  criteria applying to agricultural commodities 
more generally, i.e. not only for the part used for biofuels a nd bioliquids, are progressing, in 
part spurred by the Directives. However, they ar e either only just at the point of becoming 
operational12 or their market coverage is gr owing but not yet sufficiently large13 to dispel the 
concerns about the effectivene ss of the book and claim system. 
In terms of administrative burden, little additional information is as yet available from the 
operation of the mass balance system. 
                                                 
9 OJ C 160, 19.6.2010, p. 1. 
10 Article 18(2) 
11 SEC(2008) 85 Vol. II, p. 148. 
12 e.g. the Better Sugarcane Initiative (BSI) a nd the Round Table on Responsible Soy (RTRS). 
13 e.g. the Round Table on Sustainable Palm Oil (RSPO), which covered a little over 3.4 million tons of 
palm oil in November 2010 compared to world production of over 45 million tons. 
 
EN 4   EN 3. CONCLUSIONS  
The mass balance system is a stringent system . It is clear that it requires farmers and 
industries to adapt their pr actices. In terms of integrity and eff ectiveness, there is  at present no 
potential to allow for verification methods for the biofuels and bioli quids sustainability 
scheme that are less stringent than the mass ba lance system laid down in the Directives. In 
line with the Directives the Commission w ill assess again by 2012 whether there is such 
potential.