• If you carried out an audit before 1 July 2021 against EU RED I requirements, or started the audit before 1 July (in the case of a two phase-audit) you can finish the process against EU RED I requirements.
• If you start an audit after 1st July 2021, it has to be carried out against EU RED II requirements.
Although the European Commission does not require all economic operators (certificate holders) to undergo an early full recertification audit for the purpose of transitioning to EU RED II, the European Commission expects all economic operators to follow the EU RED II rules from 1 July when producing and trading their volumes. We have asked all Bonsucro EU RED members to return a signed letter to Bonsucro committing to EU RED II implementation from 1 July 2021.
It is the responsibility of the Bonsucro member to read the rules and implement them, especially the new requirements on information / paperwork required to sell volumes under EU RED II.
It is the responsibility of the certification body to liaise with their client and consider what level of evaluation are required against EU RED II to formalise the scope change on the certificate. Certification bodies will need to keep up to date with changes to Bonsucro requirements and for those carrying out Bonsucro EU RED audits, with the EU legislation.
Certification bodies will have to liaise with each client and assess the situation with each of them to determine the best course of action, over the next few weeks, to assess their implementation of EU RED II. It is the CBs' responsibility to evaluate the risks associated and decide on the best course of action handle conformity assessments.
If an audit is planned for July / August 2021, and a client needs more time to be ready for an audit against EU RED II, the certification body can consider a two phase audit, where the second phase includes the audit against EU RED II requirements, or a follow up audit focussing on EU RED II requirements.