RED: ISCC publishes update on Nabisy

On 13 November 2018, ISCC Published its regular update, which included updates to its Proof of Sustainability (PoS) format and clarifications on GHG calculations. It also confirmed that a new version of the web application Nabisy (for use in the German market), will be released at the end of January 2019. The update can be accessed here 

REACH: UK Government published "no deal" guidance

On 24 September 2018 the UK government published its REACH guidance in the event there is a "no deal" Brexit. EBOTA has circulated a memo on this guidance to REACH Working Group Members. The guidance can be accessed here 

RED: draft of the RED 2 text published

Once the updated RED II text has been finalized it will be submitted in the next few months for official approval to the European Parliament and Council, which is expected to be a formality. The Directive shall enter into force on 1 January 2021 and Member States are required to transpose it into national law by latest 30 June 2021. EBOTA has provided a summary of the RED 2 provisions to its RED Working Group Members.

Draft Regulation of government of Energy Union agreed

On 20 June 2018, the Commission, the European Parliament and the Council agreed the text of a Regulation on the governance of the Energy Union.  The agreed text of the draft Regulation has not yet been published. However, the Commission's press release states that, among other things, the Regulation will put in place "a robust mechanism to ensure the collective attainment of the EU renewable and energy efficiency targets" and will also address progress made by Member States in achieving exisitng renewables targets. 

The Commission's press release can be found here 

Amendments to the RFTO come into force on 15 April 2018 

On 15 April 2018 the Renewable Transport Fuels and Greenhouse Gas Emissions Regulations 2018 come into force.  These regulations amend various aspects of the RFTO, including raising the targets for renewable fuels and introducing sub-targets for the use of certain advanced biofuels classified as "development fuels". 

The text of the new regulations can be found here

LEAP Forms European Barge Electronic Movement Document Working Group (20 February 2018)

Further information can be found here

ECHA publishes updated guidance documents

ECHA has published the following updates to its guidance documents: 

November 2016 update of "Guidance on Registration" document can be found here

April 2017 update of "Guidance in a Nutshell for identification and naming of substances under REACH and CLP" can be found here

May 2017 update of "Guidance for identification and naming of substances under REACH and CLP" can be found here

July 2017 update of  "Guidance in a Nutshell – Registration" document can be found here


The Royal Academy of Engineers Publishes its report "The Sustainability of Liquid Biofuels" 

On July 14, 2017, the Royal Academy of Engineering published its report "The Sustainability of Liquid Biofuels" on the sustainability pros and cons of biofuels, which was commissioned by the Department of Transport and the Department for Business, Energy and Industrial Strategy. The report aims to provide advice on the future strategy for the development of biofuels in the United Kingdom (UK).  

The report calls on government to incentivize the development of second generation biofuels in the UK, specifically those derived from wastes and agricultural, forest, and sawmill residues, and to incentivize the use of marginal land, such as land unsuitable for food production or housing, for the production of biofuels. The Academy also recommended that the government properly regulate the biofuels sector with clear and consistent categorization of wastes and residues to help avoid unintended market distortions within the UK and internationally, and that other sustainability issues, such as competitiveness of biofuels with fossil fuels; food, energy and water security; employment provision; rural development; and human health impacts, be evaluated.

The full report can be found here 


EU’s biofuels U-turn is final nail in coffin of Irish sugar 

The Renewable Energy Directive — which provided that by 2020 at least 10% of EU transport sector energy must come from renewable sources — opened the prospect of repeating in Europe the ‘quiet revolution’ in rural investment and jobs that that the US witnessed from its ethanol policy.

However, the EU's proposal in 2012 to reduce the targets from 10% to 5% had led to a loss of investment from Biofuels industry.  It has been suggested that if the EU follows through on its proposal, half the jobs in the biofuels industry could be lost.  One of the major losers will be those seeking to revive the Irish sugar industry for the purpose of producing sugar for the bioethanol industry.

The full article on this issue can be found here


ECJ rules that where a party breaches the REACH Regulation by importing a registrable substance into the EU without registered it with ECHA,  the REACH Regulation does not prevent that party re-exporting the substance to a country outside the EU.  

A German citizen had imported a quantity of nicotine sulphate into Germany from China.  He had failed to register the substance in accordance with the REACH Regulation and consequently had been prosecuted by the authorities in Germany.  He then requested authorisation to export the nicotine sulphate to Russia.  The German authorities sought to prevent him doing so on the basis that the substance was in Germany unlawfully.

The ECJ held that "the export of a substance to a third country cannot be considered as the ‘placing on the market’ of that substance within the meaning of Article 3(12) and Article 5 of the REACH Regulation."  Consequently the fact that the party.

The full judgment is available here 


Implementation of the Updated GHG Emission Calculation Methodology

The EU Commission (EC) has now informed all recognised voluntary schemes that “all voluntary schemes that have been recognised by the EC since August 2016 are required to implement an improved GHG emission certification methodology...”.  In the letter the EC requests that the requirements are fully implemented at the latest by end of August 2017. The implementation deadline of end of August 2017 applies to all schemes whose recognition by the EC will have been extended by end of August 2017

This means, that by that date System Users have to implement all new requirements according to ISCC System Document 205 “GHG Emissions” (v3.0).

The main adjustments cover:

  • GHG information transfer for all individual elements of the GHG calculation formula along the supply chain

  • Calculation and forwarding of all GHG values per dry-ton matter

  • Application of feedstock factor based on mass (for feedstocks and intermediates) and based on energy content of input and main output for final biofuels

Further information on this subject and access the ISCC System Update for 11 May 2017 is available here


11 April ISCC System Update is available here

Topics covered include:

  • ISCC clarifies that the scope “Trader” has to be applied for all trades that are not specific for the main scope of the audit. 

  • ISCC clarifies its position regarding its approach to materials from other certification schemes.

  • ISCC clarifies various points regarding Waste and Residues and the ISCC's List of Materials.


Chemtrac launches new "Professional Plus" edition software

Further information on Chemtrac's new Professional Plus software can be found here 


Implementation of the ISCC Public Summary Audit Report – 4 April 2017

The ISCC has announced that it is introducing summary audit reports for all ISCC certified system users that will be made publicly available on the ISCC website.  Currently, system users can agree on a voluntary basis if the audit reports that are completed by the certification body during the audit will be uploaded on the ISCC website. Since these reports often contain sensitive company information, many system users have opted against a publication.   The summary audit report shall provide an overview on relevant aspects and results of the audit of a certified ISCC system user, but the report shall not contain confidential or business sensitive information or data.

Further information can be found here


The ISCC has been registered as a Certification System Administrator by the ARR in Poland 

On 29 November 2016 the ISCC was registered as a Certification System Administrator by the Polish Agricultural Market Agency (ARR).  By obtaining this registration the ISCC has satisfied the legal requirements necessary to continue its certification scheme in Poland into 2017 and beyond.

The ISCC EU scheme is already recognised by the European Commission to demonstrate compliance with the legal requirements for the Renewable Energy Directive (RED) and Fuel Quality Directive (FQD) for all Member States of the European Union.  

Further information about the ISCC is available on the ISCC website.

The most recent ISCC Newletter (23 March 2017 edition) can be found here


ECHA updates its list of substances that might be chosen for compliance checks 

ECHA has updated the list of substances that might be chosen for compliance checks. The list includes 130 new substances. ECHA is advising registrants to check this list and, if needed, update their related registration dossiers and registration tonnage bands by 22 May 2017

The new list can be found here

Further information on ECHA's compliance checks may be found here


ECHA publishes the results of its first enhanced completeness checks

Since the enhanced completeness check was introduced in June 2016, 1653 REACH registration dossiers have been manually verified by ECHA's staff. This corresponds to 33 % of the incoming dossiers.

For 20 % (329) of the verified dossiers, companies were asked to improve the submitted information. More information was asked mainly on the following (one dossier may need to be improved in many areas):

  • Justifications for waiving data – 136 dossiers

  • Substance identification – 180 dossiers

  • Testing proposals – 33 dossiers

  • Chemical safety report – 11 dossiers

Almost all registrants (95 % of dossiers) updated their information as requested and passed the completeness check at their second attempt. For the remaining 5 % of cases, the submission was rejected. This was either because no update was submitted within the given deadline or the second submission failed the completeness check. For initial submissions, the rejection meant that a registration number was not issued.

Further information about the results of the enhanced completeness checks may be found here 


ECHA has shortlisted 162 substances for possible regulatory action 

ECHA has selected 162 substances from REACH registrations for further scrutiny by the Member State competent authorities in its annual IT screening exercise. The competent authorities will carry out a manual examination of the dossiers they prioritise to decide whether regulatory action is needed.

The selection is based on an automated IT screening focusing on substances with potential carcinogenic, mutagenic or toxic to reproduction (CMR), persistent, bioaccumulative and toxic (PBT), endocrine-disrupting, sensitising or specific target organ toxicity following repeated exposure (STOT RE) properties.

Potential substances with these hazardous properties were then further prioritised based on uses that are likely to lead to exposure to humans or release to the environment. The Member State competent authorities will select substances from the shortlist for their manual examination.

A company that has registered one of substances now shortlisted will receive a letter from ECHA informing it of the potential examination of its registration(s).  ECHA is encouraging such companies to update their dossiers to address any shortcomings as soon as possible. Up-to-date information will help the Member State authorities better assess whether the concern indicated by the screening is confirmed, and whether regulatory action is still needed.

Further information is available here


Introduction to Chemicals Regulation in Asia Pacific

The REACH Centre is offering the above course at LEC, Lancaster University on Tuesday 12 April 2016. 

As Asian countries implement REACH-like chemicals management legislation, this one-day course will cover the major markets including China, Taiwan and Korea. 

New case on REACH

The European Court of Justice has recently made a decision on REACH.  Further details can be found here (see second article in the bulletin).

Free REACH centre webinar on 10 September 2015: Sameness Checking for Joint Registrants

You can sign up to attend the webinar here.  It will provide an overview of the sameness checking process; key considerations relating to substance characterisation; and several case examples.

New version of IUCLID launched in beta

ECHA has released version 6 of IUCLID, the system used for, among other things, the preparation of REACH dossiers.  Click here for further information on ECHA's news page.

ECHA's annual evaluation report published

On 26 February 2015, ECHA published its annual evaluation report.  The REACH Evaluation Report 2014 shows that a considerable share of the examined registration dossiers still require improvement. At the same time, more registrants comply with ECHA's dossier evaluation decisions.  For further information, click here.

Updates from the REACH Centre

The REACH Centre has recently provided updates on Chemtrac 4, and a regulatory newsletter.  Please click here Chemtrac and here regulatory news to view in your browser.

Belgian law on inland barge freight rates takes effect

(C-2014/14358 Loi Relative à l'Affrètement et la Formation des Prix dans la Navigation

The above law came into force in Belgium on 22 August 2014. The law follows from Council Directive 96/75/EC of 19 November 1996 (the "Directive") (FN1).  Currently the law is available only in Dutch and French, but EBOTA will link to an English version if it becomes available.

The law makes it a criminal offence for a barge to be  chartered at below cost, to reduce the likelihood
of market participants being forced out by predatory pricing, i.e., to prevent unfair competition in the market.  The law is ambiguous in various respects, including how the 'cost' price is to be determined and applied.

Members should take note that the consequences of breach are serious.  Breach is  punishable by a fine and/or imprisonment for up to three years.  The authorities may also detain the vessel concerned or impose a temporary prohibition on its use. 

FN1: The Directive was aimed at maintaining freedom of contract in the barge market, while seeking to tackle over-capacity.  The Directive allowed Member States to maintain a system of minimum compulsory tariffs and 'chartering by rotation' (effectively a cab-rank style rule applied to barges and cargoes) for a certain period, and to apply for the ability to maintain or apply certain measures in case of potential market disturbance.   

New EBOTA ADN training scheduled for 23 June (Geneva) and 30 June (London) and now open to non-member delegates

The ADN WORKING GROUP has put together a one-day training session focussing on the transport of dangerous goods by barge in inland waterways, in association with Transafe. The course will be provided both in London and Geneva.  If you wish to book places on the course or would like any further information, please click contact the EBOTA secretariat.  The course fee is £1,000, inclusive of refreshments during the day.  A 50% discount will be given to EBOTA members.

New EBOTA/REACH 1-day operator training course:  first course to take place 27 May 2014 in London

Following on from the success of EBOTA's previous REACH 2-day training course, we are now pleased to offer a new 1-day operator specific course.  The course has been developed with the REACH Centre specifically with EBOTA members in mind, and will address practical and documentary issues, as well as working through example trading scenarios.

This course will also be open to non-members.

If you or your company would like further information on the course outline and costs, please contact the EBOTA secretariat.

EBOTA training sessions now open to non-members

EBOTA is pleased to announce that it will now be opening up its tailored training courses to non-members.  If you would like to be informed about future courses please contact the EBOTA secretariat.

24 March 2014 - ECHA publishes guidance on the Prior Informed Consent Regulation

The Prior Informed Consent Regulation (PIC, Regulation (EU) 649/2012) administers the import and export of certain hazardous chemicals and places obligations on companies who wish to export these chemicals to non-EU countries. It aims to promote shared responsibility and cooperation in the international trade of hazardous chemicals, and to protect human health and the environment by providing developing countries with information on how to store, transport, use and dispose of hazardous chemicals safely.

More information can be found here on the ECHA website.

12 December 2013 - EBOTA / ISCC RED Sustainability Workshop, Geneva

On 12 December 2013 EBOTA held a RED Sustainability Workshop in Geneva.  It was organised with the ISCC (Andreas Feige and Jan Henke) and attended by the BLE (Karl-Heinz Schnau).  The Workshop was tailored specifically to the needs of EBOTA oil trading members, over twenty of whom attended as delegates.  It considered a wide range of issues arising out of the Renewable Energy Directive affecting the trading community.  Topics included the roles of the ISCC, other voluntary schemes and the BLE, proofs of sustainability, Nabisy, mass balance, GHG calculations, waste, double counting, auditing, certification bodies and Trace Your Claim. Participants already had daily experience with most of these topics, so it was a good opportunity to resolve some of the questions and difficulties they faced.  Feedback on the Workshop has been very positive from both EBOTA members and the ISCC and BLE representatives.  Delegates commented that it was useful to have an opportunity for open discussion and Q&A rather than just a lecture.  They found it particularly helpful to have a representative from BLE present.  Both the ISCC and the BLE demonstrated a willingness to adapt, be open to suggestions and to clarify issues.  It was also a good opportunity for the ISCC and BLE to receive feedback and discuss such topics with those involved in using the schemes.  Workshop materials and BLE Q&As are available to those who attended the Workshop on the Members only section of the website.

9 December 2013

The European Commission has published an update on anti-dumping duties on biodiesel from Argentina and Indonesia, which may be of interest, the full article can be found here and the full regulation can be found here.

12 September 2013 - Publication of new REACH handbook

The REACH Regulation (EC No 1907/2006) has been described as the “most
complex” piece of legislation in EU history, which entered into force on 1st
June 2007. REACH constitutes the basic law for any business concerning chemical
substances in the European Union. In order to compile the experience made so
far during the implementation phase, this Best Practice Guide was
launched. The editors (Dieter Drohmann/Chemservice and Matt Townsend/Allen
& Overy) are recognized practitioners experienced in the various fields of
REACH and have been able to recruit high level REACH experts as authors from
industry, law firms and authorities to address this complex field of chemical
control legislation. This handbook covers all relevant issues from initial
registration of chemical substances to the final enforcement of the obligations
under the Regulation.

12 September 2013 - AGM

EBOTA will be holding its AGM to report on progress in the last 12 months.  Speakers from each of the working groups, the Executive Committee and the Secretariat will provide updates to members.  

April 2013 - Energy Institute

Adam Panni will be attending the Energy Institute Oil Transportation Measurement Committee meetings in Stavanger on 14 - 16 May 2013 on behalf of EBOTA. 

The agenda for the meetings can be found here.


April 2013 - REACH presentation

Andries Eeltink will be giving a presentation entitled "EBOTA REACH update" at the LEAP European Barge Workshop in London on 8 May 2013.

Further information on the Workshop can be found here.


April 2013 - REACH and CLP Helpdesk in conjunction with the REACH Centre

EBOTA has teamed up with The REACH Centre to provide a REACH and CLP helpdesk service for the benefit of our members. Full EBOTA member companies will have access to advice and guidance on REACH and CLP provided by experts from The REACH Centre, with each member having access to 3 hours per quarter of free consultancy advice via the helpdesk.

Further details and contact information for the helpdesk can be accessed via the helpdesk tab.


March 2013: ISCC presentation

The EBOTA RED/Sustainability Working Group met on 21 March 2013. Dr Jan Henke of the ISCC gave a very useful presentation to the RED Working Group members on sustainability certification, the ISCC and Trace Your Claim.


January 2013

The European Commission has published an indicative roadmap proposing to make an inventory of the existing measures for internalising external costs in all modes of transport.  It aims to ensure that correct and consistent monetary signals are given to users, operators and investors, and to encourage internalisation of external costs in order to establish a level playing field between different modes of transport.  A public presentation is foreseen in 2013 following the adoption of the communication.


January 2013

Following the success of EBOTA's first REACH training session at the end of last year, a further session is set to take place on 13-14 February in Geneva.  In order to allow as many members as possible to benefit from the training (and to open up the sessions to non-members), EBOTA is currently considering further dates for an additional London session.  For further information, or if you would like to register your interest, please contact the Secretariat.

December 2012

Public Consultation on the protection of business and research know-how

The European Commission has launched a public consultation on the protection of business and research know-how.  Concerns have been voiced over the effectiveness of the legal protection against the misappropriation of trade secrets in the Internal Market.  The Commission has decided to analyse the current situation in the Union in more detail and to collect views with regard to the protection of business and research know-how within the Union.  Contributions can be made until 8 March 2013 via the online questionnaire, which can be found here.


December 2012

Energy Technologies in a future European Energy Policy

The European Commmission has published an updated roadmap on the development of energy technologies within a more cohesive and cooperative EU-wide energy policy.  It discusses the need to avoid fragmentation and duplication of research, and to avoid the European low carbon industry being sidelined by global competitors in the longer term.  It outlines potential strategy options and aims to develop a new approach to complement the ambitious decarbonisation goals of the energy 2050 roadmap.

No particular legislation is being considered as yet.  Further research and consultation is planned. 


15 November 2012

Annual Report on the operations of the Transparency Register

The European Parliament on 15 November 2012 released its first Annual Report on the operations Transparency Register.  There will be a lengthier review of the Transparency Register in June 2013.  The Annual Report explains the need for the Transparency Register and describes the role of the Joint Transparency Register Secretariat.  It summarises the results of the public consultation from 8 June to 31 August 2012, and gives statistics of the entities and organisations registered so far.  It analyses the operations of the Transparency Register generally, discusses other issues to be examined and identifies next steps to be taken.

The Annual Report and an Information Note regarding the Transparency Register can be found here and Transparency Register updates can be found on the dedicated Transparency news section of the EBOTA site.


20 November 2012

EBOTA / REACH Centre Training launches

The first EBOTA REACH Centre Training Workshop took place in London on November 14-15 2012.  The seminar was attended by representatives from BP, Chevtex, HETCO, JP Morgan, Morgan Stanley and Holman Fenwick Willan LLP.  Feedback has been positive. The Workshop will be repeated in early 2013 for those in Geneva. Details will follow shortly.

Arrangements have also been made with the REACH Centre to set up an EBOTA Help Desk function.  This is expected to go live shortly and further details will follow.

20 November 2012

EU Transparency

Please note that from today, EBOTA's EU Transparency updates will appear on their own dedicated page of this site, please use the link to the right of this page to access the updates.

19 October 2012

European Commission proposes wide-ranging changes to Renewable Energy Directive

The European Commission has proposed amendments to the Renewable Energy Directive (RED) that have potentially far-reaching consequences for biomass and biofuel production. The changes include greenhouse gas reduction thresholds and incentives for using feedstocks with 'Low Indirect Land Use Change' emissions. These have in part been prompted by concerns over the balance in European agriculture between food and first generation biofuels. 

18 October 2012

REACH Centre

EBOTA has been working with the Reach Centre in recent months with a view to seeking and promoting solutions to members' concerns about the implementation of Reach compliance measures.

EBOTA is pleased to announce that it has also entered into negotiations with the Reach Centre to provide services including dedicated EBOTA training sessions relating to Reach implementation for oil trading entities.  EBOTA plans to offer both overview and in-depth sessions and EBOTA members will be able to take advantage of a significant subsidy on the cost of these courses when they become available.  EBOTA is also considering the provision of a dedicated Reach telephone helpdesk for members to provide confidential advice on specific transactions. 

Further updates will be provided soon, but please contact the secretariat with any questions or suggestions in the meantime. 

17 August 2012

New ADN Working Group

EBOTA has set up a new working group to consider the impact and implementation of the International Carriage of Dangerous Goods by Inland Waterways ("ADN") within the bulk oil trading market.  

The aims of the ADN are broadly to:

·    ensure a high level of safety;

·    prevent pollution and other environmental damage; and

·    facilitate transport operations and international trade.

The ADN includes detailed regulations concerning the carriage of dangerous goods during inland navigation.  The regulations also set out a number of requirements and procedures for inspections, the issue of certificates of approval, recognition of classification societies, monitoring, and training and examination of experts.

Further information concerning the new working group can be found here.

2 July 2012

ECHA Factsheet

The European Chemicals Agency has released a factsheet targeted at recipients of REACH-exempt products. Whilst directed primarily at downstream users, it provides a helpful summary of the Safety Data Sheet obligations on suppliers. The factsheet can be accessed here.

8 June 2012

Renewable Energy Strategy

The European Commission has published an updated roadmap on its Renewable Energy Strategy (RES). The roadmap considers renewable energy policy in Europe beyond current 2020 targets and with a view to the 2050 decarbonisation agenda. Whilst stakeholder consultation is ongoing, immediate legislative action is not being considered yet.

May 2012

Energy Institute and EBOTA

Earlier this month, Adam Panni of Morgan Stanley gave a presentation introducing EBOTA to the Energy Institute in Paris.  The presentation covered topics including the work of EBOTA's REACH and RED working groups.  It is hoped that the presentation will kick start the process of EBOTA forging links with other organisations in similar fields and also raise awareness of the current issues in bulk oil trading.  

Following the presentation, members of the HMC-4 Committee voted formally to invite EBOTA to their meetings as a permanent invitee.