Biomass Feedstock Accounting

Criterion ID and Type

Requirement

Documentation Requirements

FC1: All feedstock submissions must provide all feedstock supplier details, the feedstock sourcing region, the chain or chains of custody, the demand for the feedstock at scale and the feedstock characteristics.

FC1.1 Validation and Verification Requirement

The feedstock supplier(s) are defined. For more details on how to handle feedstock aggregators/intermediaries, handling diverse feedstock portfolios and more, see Section 1.1.

The Project Proponent must provide all of the following for each feedstock supplier:

• Organization name

• Company registration number

• Address

• Contact person

• Contact details

• A description of the organization's role in the Project and declaration of payments exchanged

FC1.2 Validation Requirement

The feedstock sourcing region is defined.

The Project Proponent must provide one of the following:

• Mapped sourcing region boundary, such as a shape file
• Sourcing radius from project site
• Demonstration of the feedstock suppliers’ legal operating area

Where a Project cannot define a sourcing region from supplier records, it must define the region as the area within the maximum economic transport distance for the feedstock and transport mode, stating the distance, the mode, the cost basis and the source. The resulting boundary must be the larger of that area and the administrative unit(s) it intersects, so that all land potentially supplying the feedstock is captured by the criteria assessed at sourcing-region level.

FC1.3 Validation and Verification Requirement

The feedstock chain-of-custody is defined so that the flow of feedstock from the supplier to the Project is transparent.

The Project Proponent must define the model of chain-of-custody and detail the flow and organizations involved in the chain-of-custody from the procurement of feedstock to the acceptance by the Project. Acceptable chain-of-custody models include:

• Identity preservation

• Link the feedstock back to an applicable point (producer, producer group, aggregator) and preserve the linkage via transaction & volume reconciliation.

• Segregation

• Prevent commingling across origins or sourcing classifications that preserves the origin geolocation and reconcile volumes at each transport/processing node.

• Mass balance

• Record transactions, reconcile volumes at each supply node, retain origin geolocation to the point of origin and define balancing periods for each feedstock type and sourcing classification. Dedicated feedstocks must use segregation. Once a chain-of-custody is established, this remains valid until there is a change in the flow, model or organisations involved at which point the Project must update the submission prior to Verification. A book-and-claim chain-of-custody cannot be used for biomass feedstocks.

FC1.4 Validation Requirement

The Project demand for the feedstock is defined.

The Project Proponent must provide a quantification of annual feedstock demand at scale in bone-dry tonnes/year.

Where bone-dry tonnes is not a valid measurement, the feedstock may be reported as received with the appropriate justification, ensuring all other measurements/calculations are suitably adjusted.

Where a Project is an Eligible Retrofit or Integration Project demonstrating compliance with the requirements in Appendix E.1, and the underlying facility has a highly variable feedstock consumption rate, the marginal biomass that is sourced specifically for the Project (such as feedstock sourced to increase Certificate volume or compensate for a parasitic energy demand introduced by the Project), if any, must be represented here.

FC1.5 Validation Requirement

The feedstock is accurately and completely characterised.

The Project Proponent must provide a detailed description of the feedstock to be used, including the feedstock characteristics (species, pre-processing etc.), feedstock origin, potential contaminants and any potential fossil carbon content.

Criterion ID and Type

Requirement

Documentation Requirements

FS1: The feedstock storage conditions do not result in increased methane emissions through anaerobic decay. For feedstock submissions that demonstrate compliance with FS1.1, $CO_2e_{BioStorage}$ = 0.

FS1.1 Verification Requirement

The feedstock storage conditions prior to utilization do not cause an increase in methanogenesis compared to the counterfactual.

Project Proponents must provide one of the following:

• Evidence that the feedstock consists of coarse woody material (>10cm in diameter) that naturally remains well aerated.
• Evidence that the feedstock was stored for no more than four weeks prior to utilization.
• Evidence that the feedstock was stored with a maximum of 30% residual moisture (e.g., drying, torrefaction etc.).
• The feedstock is pelleted for storage.
• Evidence that the storage conditions do not materially change from the counterfactual (e.g., similar sized piles, similar climatic conditions and similar environmental interaction such as ground contact and covering). This includes cases where a Project is an Eligible Retrofit or Integration that neither changes the feedstock type/volume or the storage conditions.
• Evidence that methanogenesis is otherwise avoided given the nature of the feedstock and storage conditions.

FS2.1 Verification Requirement

Emissions associated with feedstock storage conditions are accurately quantified.

The Project Proponent must provide a calculation of CH₄ emissions, adjusted to GWP₁₀₀, to be subtracted from gross removals. Calculation requirements can be found in Section 1.6.1.

Criterion ID and Type

Requirement

Documentation Requirements

CU1: The feedstock is woody, such as forestry residue, a sawmill residue or post-consumer wood waste. All woody feedstocks must comply with CU1.1.

CU1.1 Validation Requirement

The feedstock must not have been used in a wood-based product in the absence of the Project. This includes use in a wood-based product, extending the service life of a wood-based product, re-use as a wood-based product, and recycling into a wood-based product. Saw logs, veneer logs, and industrial-grade roundwood are ineligible. This does not apply to material that has already fulfilled its use as a wood-based product and cannot be re-used or recycled into one.

The Project Proponent must demonstrate their feedstock complies with this requirement by submitting one of the following pieces of evidence:

• End-use/disposal data for the feedstock covering the preceding five years demonstrating a lack of use in wood-based products.
• A legally binding affidavit from the feedstock supplier or an appropriate member of the chain-of-custody, detailing the final fate of the feedstock over the previous five years, corroborated by delivery, disposal or sales records.
• Third-party log-grading data, accompanied by an auditable monitoring plan, demonstrating the wood's unsuitability for long-lived wood or pulpwood mills (e.g., characteristics like diameters or lengths falling outside mill tolerances).
• A legally binding affidavit from the feedstock supplier or an appropriate member of the chain-of-custody confirming the wood is unmarketable due to damage (e.g., insect damage, decay, fire-damage), accompanied by dated photographic evidence or a third-party inspection report.
• Contamination data (e.g., chemicals or embedded materials) indicating levels that exceed mill tolerances.
• Letters of rejection or detailed tender/auctions confirming the feedstock is unsuitable for pulpwood or long-lived wood products dated within the preceding 12 months.
• A report demonstrating the absence of an available market for the material within the defined supply base. This report must reference specific mills and include defensible evidence of supply/demand data and the constraints of the defined supply base, which must be appropriate for the material being sourced.
• Evidence that the feedstock is covered by a certificate issued under an EC-recognised voluntary scheme (Article 30(4) of Directive (EU) 2018/2001) or a Member State national scheme (Article 30(6)) whose recognised scope covers forest biomass – such as PEFC RED, SBP, ISCC EU, SURE or KZR INiG – together with documentary evidence that the sourcing jurisdiction applies the cascading use of biomass under Article 3(3) to the feedstock in question and that no Article 3(3a) derogation has been invoked for it.
• A purchase agreement demonstrating that the total contribution paid to the feedstock supplier, inclusive of revenue sharing and in-kind benefits, does not exceed the supplier's documented cost of recovering and transporting the feedstock at the point of transfer. This includes cases where the feedstock is received free of charge or the Project Proponent is paid a tipping fee. Where the feedstock supplier is a related party of the Project Proponent, this evidence option is not available.
• Evidence that feedstock is already in use, and the Project is an Eligible Retrofit or Integration Project demonstrating compliance with the requirements in Appendix E.1 (e.g., a sawmill or bioenergy facility) where the sourcing practice and volumes will remain unchanged by the Project.
• Evidence that the feedstock is sourced from Eligible Wildfire Mitigation activities as defined in Appendix E.2.

CU2: The feedstock is non-woody, such as a crop residue or food processing residue. All non-woody feedstocks must comply with CU2.1.

CU2.1 Validation Requirement

The feedstock must not have been used for food or feed in the absence of the Project.

The Project Proponent must demonstrate their feedstock complies with this requirement by submitting one of the following pieces of evidence:

• End-use/disposal data for the feedstock covering the preceding 3 years demonstrating a lack of use in food or feed.
• Waste classification, such as waste codes or labels that demonstrate the use of the feedstock is restricted to non-food and non-feed end-fates.
• Evidence of diversion of the feedstock from a waste stream.
• Evidence of regulatory restrictions covering the feedstock that block the feedstock use as food or feed.
• Evidence of feedstock constituents that demonstrate the feedstock's clear absence from the food/feed market (such as inedible food residues, post-consumer residues and sanitation residues).
• Condemnation by authorities, such as destruction orders, evidence of spoilage, quality assurance failure or contamination exceeding thresholds.
• Evidence of unrecoverable mixing with inedible materials.
• The feedstock is already in use, and the Project is an Eligible Retrofit or Integration Project demonstrating compliance with the requirements in Appendix E.1 (e.g., a waste processing facility or bioenergy facility) where the sourcing practice and volumes will remain unchanged by the Project.
• A purchase agreement demonstrating that the total contribution paid to the feedstock supplier, inclusive of revenue sharing and in-kind benefits, does not exceed the supplier's documented cost of recovering and transporting the feedstock at the point of transfer. This includes cases where the feedstock is received free of charge or the Project Proponent is paid a tipping fee. Where the feedstock supplier is a related party of the Project Proponent, this evidence option is not available.

Criterion ID and Type

Requirement

Documentation Requirements

SC1.1 Validation and Verification Requirement

The feedstock must be sourced from management practices audited against high standards of social and environmental sustainability. Key sustainability principles include:

1. Harvesting is legal
2. Harvested areas are regenerated in a timely manner
3. Protected areas remain protected
4. Harvesting maintains or enhances soils and biodiversity

a. Stumps & roots remain in the ground b. Forests are not converted into plantations c. Vulnerable soils are not logged d. Clear-cuts stay within size limits set by the country of harvest e. Deadwood and other residues are retained at levels appropriate to the local ecology f. Logging systems & equipment are chosen to prevent harm to the soil quality and to maintain biodiversity and habitats

5. The forest’s long-term capacity to produce is maintained or enhanced.
6. Resource provision to local communities and indigenous people is maintained or enhanced.
7. All management activities comply with international labour laws.

The Project Proponent must provide one of the following:

• Evidence that the feedstock is certified by an approved Tier 1 or Tier 2 third-party forestry management or sustainability assurance framework listed in Table C.1, together with any additional documentation Table C.1 specifies for that framework. A framework not listed in Table C.1 may be accepted case-by-case where the Project Proponent demonstrates principles and criteria equivalent to those listed.

• Where the framework's certificate does not itself cover the residue (e.g. FSC Forest Management), chain-of-custody documentation tracing the feedstock to the certified forest management unit. A chain-of-custody certificate alone (e.g. FSC CoC) does not satisfy this criterion. - A Tier 3 framework may only be used where the Project Proponent demonstrates both: (a) the Project is an Eligible Retrofit or Integration Project demonstrating compliance with the requirements in Appendix E.1; and (b) the feedstock volume relying on the Tier 3 framework would have been consumed by the underlying facility in the absence of the Project.

• Evidence that the feedstock is sourced from an area managed under a statutory forest management framework administered or mandated by an approved governing authority, as listed in Table C.1. Equivalent frameworks may be considered on a case-by-case basis pending a demonstration of equivalent principles & criteria to those listed in Table C.1 by the Project Proponent.

• Completion of the Tier 2 regional risk assessment listed in Table C.1, audited by a suitable forestry professional (as defined below), demonstrating a low residual risk of non-compliance with each criterion – either directly, or following the application of mitigation measures for criteria carrying an elevated risk. A framework not listed in Table C.1 may be accepted case-by-case where the Project Proponent demonstrates principles and criteria equivalent to those listed.

• A suitable forestry professional is an individual who: (a) has been agreed with Isometric in writing before the assessment is carried out; (b) holds risk assessment training and experience consistent with ISO 19011 or equivalent or holds a recognised auditor certification for ISO 9001, ISO 14001, or equivalent; and (c) holds relevant forestry sector experience.

• Evidence that the feedstock was obtained as a forestry residue from an Isometric Improved Forestry Management, Reforestation or Mangroves Restoration Project (not Agroforestry). The Biosphere Project and the Project utilizing the feedstock must demonstrate independent economic feasibility.

SC1.2 Validation and Verification Requirement

Projects must demonstrate that forest carbon stocks in the sourcing region* have not decreased or have decreased only due to widespread ecological disturbance (e.g., wildfire, windfall, insect or disease outbreak) and not due to increased harvesting. Where the most recent years are unrepresented by datasets, the Project Proponent must use the most recently available data with sufficient justification for why more recent data were not available. This assessment must be completed at Validation and refreshed annually.

The Project Proponent must provide one of the following:

• Evidence demonstrating, using published forest inventory data, that carbon stocks in the sourcing region are either stable or increasing when comparing the most recent five years to the preceding five-year period. Publicly available datasets that enable carbon stock trend analysis at the jurisdictional level include:

• jmrv.ctrees.org

• Reference an applicable third-party assurance framework that demonstrates that carbon stocks are stable/increasing within the sourcing region.

• Evidence demonstrating compliance with regionally defined maximum allowable cuts relative to growth when comparing the most recent five years to the preceding five-year period.

• A detailed assessment demonstrating carbon stock trends in the absence of natural disturbance would be stable/increasing. This is done by subtracting the extent of decline attributable to natural disturbances from the carbon stock trend, resulting in a stable/increasing trend in the absence of the natural disturbances.

• Completion of the Isometric Forestry Biomass Risk Assessment, demonstrating a low-risk of non-compliance with all criteria, or a specified risk with appropriate mitigation measures depending on the criteria, producing a low residual risk of non-compliance. Equivalent frameworks may be considered on a case-by-case basis pending a demonstration of equivalent principles & criteria to those listed in Table C.1 by the Project Proponent.

• Evidence that the feedstock was obtained as a forestry residue from an Isometric Improved Forestry Management, Reforestation or Mangroves Restoration Project (not Agroforestry). The Biosphere Project and the Project utilizing the feedstock must demonstrate independent economic feasibility.

• Independent satellite derived aboveground biomass change products such as ESA CCI biomass or GEDI-derived datasets, accompanied with a justification for why none of the above options was achievable by the Project.

SC1.3 Validation Requirement

The feedstock must not originate from land that held the following status in or after January 2008, whether or not the land continues to hold that status: Primary forest and other wooded land, namely forest and other wooded land of native species, where there is no clearly visible indication of human activity and the ecological processes are not significantly disturbed.

The Project Proponent must provide one of the following:

• Evidence that the region is covered by a current, valid regional risk assessment published by an approved third-party sustainability assurance framework as listed in Table C.1, confirming compliance with this criterion.

• A geospatial exclusion assessment demonstrating the sourcing region of the feedstock does not overlap with primary forests. Public third-party tools include:

• https://peatfires-153915.projects.earthengine.app/view/ifl2025

• Evidence that feedstock is certified by a valid certification program under an EC-recognised voluntary scheme with the RED forest biomass scope (SBP EU RED, PEFC RED, ISCC EU), or a non-EU equivalent. Equivalent frameworks may be considered on a case-by-case basis pending a demonstration of equivalent assessment scope to those listed above by the Project Proponent.

• Evidence that the feedstock was obtained as a forestry residue from an Isometric Biosphere Project through one of the following Protocols: Improved Forestry Management, Reforestation or Mangroves Restoration (not Agroforestry). The Biosphere Project and the Project utilizing the feedstock must demonstrate independent economic feasibility.

Criterion ID and Type

Requirement

Documentation Requirements

SC2.1 Validation Requirement

The feedstock must not originate from land that held any of the following statuses in or after January 2008, whether or not the land continues to hold that status:

1. Primary forest and other wooded land, namely forest and other wooded land of native species, where there is no clearly visible indication of human activity and the ecological processes are not significantly disturbed.
2. Old-growth forest as defined by the country of harvest.
3. Highly biodiverse forest or other wooded land that is species-rich and not degraded, and formally identified as highly biodiverse by the relevant competent authority.
4. Designated protection areas, including habitats of IUCN-listed threatened species.
5. Highly biodiverse grassland spanning more than one hectare that is:

a. Natural – grassland that would remain grassland in the absence of human intervention and that maintains its natural species composition and ecological characteristics and processes. b. Non-natural – grassland that would cease to be grassland in the absence of human intervention, that is species-rich and not degraded, and that has been identified as highly biodiverse by the relevant competent authority.

6. Heathland, namely vegetation with low and closed cover, dominated by bushes, shrubs, dwarf shrubs (heather, briars, broom, gorse, laburnum etc.) and herbaceous plants, forming a climax stage of development.
7. Peatland unless evidence is provided that feedstock cultivation/harvesting did not contribute to drainage.

The Project Proponent must provide one of the following:

• Evidence that the region is covered by a current, valid regional risk assessment published by an approved third-party sustainability assurance framework as listed in Table C.1, confirming compliance with this criterion.

• A geospatial exclusion assessment demonstrating the sourcing region of the feedstock does not overlap with any category listed. Suitable geospatial tools include:

• Intact Forest Landscapes 2025 viewer for primary and old-growth forests (free) - IBAT for designated protection areas and IUCN-listed species habitat (subscription) - Global Peatland Database for peatland (free)

• Remote sensing evidence demonstrating the sourcing acreage has been in continuous agricultural use since January 2008. In accordance with Section 1.1.1 sourcing acreages may be grouped and assessed using a sub-sampling approach, subject to up-front engagement and written approval from Isometric.

• Evidence that feedstock is certified by a valid certification program under an EC-recognised voluntary scheme with the RED agricultural biomass scope (SURE, REDcert, ISCC EU), or a non-EU equivalent. Equivalent frameworks may be considered on a case-by-case basis pending a demonstration of equivalent assessment scope to those listed above by the Project Proponent.

SC2.2 Validation Requirement

The feedstock must not originate from land that held any of the following statuses in January 2008, and no longer holds that status:

1. Wetland, defined as land that is covered with or saturated by water permanently or for a significant part of the year.
2. Continuously forested land over one hectare, with trees over five metres and canopy cover above 30%, or trees able to reach those thresholds where they stand.
3. Land with 10–30% canopy cover over one hectare, trees over five metres, or able to reach those thresholds.

The Project Proponent must provide one of the following:

• Evidence that the region is covered by a current, valid regional risk assessment published by an approved third-party sustainability assurance framework as listed in Table C.1, confirming compliance with this criterion.
• A geospatial exclusion assessment demonstrating the sourcing region of the feedstock does not overlap with any category listed. Suitable geospatial tools include:

https://global-surface-water.appspot.com/map

• Remote sensing evidence demonstrating the sourcing acreage has been in continuous agricultural use since January 2008. In accordance with Section 1.1.1 sourcing acreages may be grouped and assessed using a sub-sampling approach, subject to up-front engagement and written approval from Isometric.
• Evidence that feedstock is certified by a valid certification program under an EC-recognised voluntary scheme with the RED agricultural biomass scope (SURE, REDcert, ISCC EU), or a non-EU equivalent. Equivalent frameworks may be considered on a case-by-case basis pending a demonstration of equivalent assessment scope to those listed above by the Project Proponent.

SC2.3 Verification Requirement

Where residues would otherwise have been retained on agricultural land to maintain or enhance soil health, the effects on soil quality and soil carbon must be addressed through monitoring or management, and how they are monitored and managed must be reported. In accordance with Section 1.1.1 sourcing acreages may be grouped and assessed using a sub-sampling approach, subject to up-front engagement and written approval from Isometric.

The Project Proponent must provide one of the following:

• Evidence that the counterfactual fate of the feedstock is not retained on the field in the counterfactual, consistent with the evidence requirements in CF1.
• A documented assessment of the effects of the take-rate on soil quality and soil carbon, drawing on existing datasets, literature or models for the specific agricultural system – including soil type, crop rotation, climate and erosion regime, and slope.
• A crop and soil monitoring plan, ensuring effects on soil health and soil carbon are monitored, that all yield impacts and compensatory mechanisms (such as increased fertilizer use) are tracked and accurately accounted for as market leakage emissions and all sustained decreases in soil carbon stocks are deducted as counterfactual storage.
• A documented method for taking a conservative deduction from net removals based on the take-rate and its consequences, applied for the duration of the sourcing, in agreement with Isometric and the VVB. Examples include Carbon Direct’s Agricultural Biomass Sourcing Guide for CDR that enforces a 13-29% default deduction for a 30% take-rate as conservative but widely applicable deduction for dry agricultural systems. Note that in some cases, depending on the take-rate and consequences, the conservative deduction may be 0.

Criterion ID and Type

Requirement

Documentation Requirements

SC3.1 Validation Requirement

The sourcing of the feedstock must not incentivise the establishment or expansion of unsustainable intensive livestock operations.

The Project Proponent must provide one of the following:

• Evidence that the feedstock carries an appropriate sustainability assurance certification such as RSPCA Assured, AWA, USDA Organic, or a demonstrable equivalent.
• A demonstration of regulatory compliance confirming the operation falls below an applicable, officially recognised regulatory threshold for an intensive livestock operation in its jurisdiction, such as the U.S. EPA's Large Concentrated Animal Feeding Operation (CAFO) threshold under 40 CFR §122.23, or the intensive-rearing thresholds for pig and poultry installations under the EU Industrial Emissions Directive (Directive (EU) 2024/1785), corroborated by the relevant permit, registration or compliance documentation.
• A purchase agreement demonstrating that the total contribution paid to the feedstock supplier, inclusive of revenue sharing and in-kind benefits, does not exceed the supplier's documented cost of recovering and transporting the feedstock at the point of transfer. This includes cases where the feedstock is received free of charge or the Project Proponent is paid a tipping fee. Where the feedstock supplier is a related party of the Project Proponent, this evidence option is not available.
• Where no officially recognised regulatory threshold for an intensive operation exists in the sourcing jurisdiction, a legally binding affidavit from the feedstock supplier (or a vet/agricultural inspector), corroborated by herd size records or stocking density documentation, demonstrating that the operation does not exceed a stocking rate of 10 livestock units per hectare and that at least 10% of the dry matter fed to the animals is produced on the farm, consistent with the FAO's definition of a non-landless livestock system.
• Evidence that the supplier's herd size and stocking density have not increased since the Project’s date of first procurement compared to the preceding 2 year average, corroborated by herd or stocking records.

Criterion ID and Type

Requirement

Documentation Requirements

SC4.1 Validation Requirement

The feedstock is designated as a controlled waste feedstock. These include feedstocks such as:

• MSW, pharmaceutical waste and contaminated/spoiled food/feed
• Sewage sludge, biosolids and DAF sludge
• Construction/demolition waste
• Post-industrial, post-consumer or municipal wood waste such as railway ties, telephone poles, fencing panels etc.

Other feedstocks may be eligible under this criteria subject to a case-by-case review by Isometric and the VVB.

The Project Proponent must provide one of the following:

• Feedstock waste classification evidence, such as an official EWC designation.
• Evidence that the feedstock was obtained, produced or diverted from a waste processing facility, such as an EPA facility registration.
• Evidence that the Project is an Eligible Retrofit or Integration to a waste facility, demonstrating compliance with the requirements in Appendix E.1, such as a biogas or landfill.
• Evidence of a waste management contract with a local/regional authority.
• Waste transfer/consignment notes, EPA waste manifests or equivalent demonstrating the waste status.
• Gate/tipping fee documentation demonstrating the waste status.
• Regulatory condemnation or destruction orders.
• Waste carrier or broker registration and transfer documentation demonstrating the waste status.
• Import/export waste movement declaration, such as EU Waste Shipment Regulation documentation or equivalent.

SC4.2 Validation Requirement

The feedstock has been sorted or segregated from higher-value or recoverable fractions of the waste stream, in accordance with applicable waste sorting and processing requirements.

The Project Proponent must provide one of the following:

• Evidence that the feedstock is generated in a physically homogeneous form, such as biosolids or waste water effluent, for which no established sorting or processing step separates higher-value fractions, corroborated by a description of the generating process or industry/regulatory guidance characterising the waste stream as homogeneous.
• Evidence of waste hierarchy compliance for the feedstock type under applicable waste management regulations, such as the EU Waste Framework Directive.
• End-of-waste determination confirming applicable recovery criteria have been met.
• Waste processing facility permit or licence covering the feedstock.
• Industry specification compliance demonstrating the material has been processed to a defined output standard.
• Process flow documentation detailing the steps through which the feedstock was generated, demonstrating its residue status.
• Source segregation documentation where the feedstock never entered a mixed waste stream.
• A technical assessment by a qualified waste or process specialist confirming no viable recovery pathway exists or that sorting/processing would not constitute an environmental/economic benefit.
• A legally binding affidavit from the feedstock supplier demonstrating that processing/sorting would have no environmental or economic benefit, corroborated by market pricing data or processor quotes showing the material has no net recoverable value, or a citation to a specific named industry or regulatory guidance document establishing the same conclusion for that waste stream.

SC4.3 Verification Requirement

Where the feedstock is sourced from a mixed waste stream or a process where fossil-derived materials may be present, the biogenic fraction must be accurately determined and conservatively applied in all carbon accounting calculations.

The Project Proponent must provide one of the following:

• If the Project is a BioCCS Project, the Project must provide demonstrable compliance with the fossil characterisation methodology in the Isometric BioCCS methodology.
• A description of the feedstock generating process demonstrating that the feedstock originates entirely from biological inputs, with no fossil-derived inputs present in the generating process.
• Determination of biomass content in accordance with EN ISO 21644:2021 (radiocarbon method) or ASTM D6866-24. Where the EN ISO 21644 selective dissolution or manual sorting methods are used instead of the radiocarbon method, the Project Proponent must justify the selection and demonstrate its suitability for the feedstock composition.
• Component-based mass balance from documented input composition, demonstrating the biogenic fraction with conservative assumptions.
• Third-party, representative compositional analysis by an acCertificateed laboratory. Frequency and volume will depend on feedstock composition, biogenic fraction and variability and must be agreed with Isometric in writing.
• Data from existing monitoring obligations, such as the EU ETS MRR.

Criterion ID and Type

Requirement

Documentation Requirements

SC5.1 Validation Requirement

The feedstock is residue from an industrial/commercial process. Eligible feedstocks include but are not limited to:

• Food processing residues such as oat hulls, nut shells and rice husks.
• Textile and fibre processing residues.
• Beverage processing residues such as spent grains or wine pomace.
• Commercial landscaping residues such as park maintenance residues, road & rail corridor vegetation.
• Pallet recycling residues.
• Arboricultural residues.
• Compost overs and other green waste.
• Herbaceous/aquatic residues from waste water treatment.

Feedstocks not listed above may be eligible subject to a case-by-case review by Isometric and the VVB. Feedstocks with high risks of market leakage, namely plant oils and used cooking oil, will be subject to a case-by-case review by Isometric and the VVB due to the high risk of market leakage. Palm oil, feedstock derived from palm oil or palm fatty acid distillate are categorically ineligible. This does not restrict the eligibility of residues such as oil palm fronds, press fibre, palm kernel shells/cake, empty fruit bunches, declinant palm stems or palm mill effluent.

The Project Proponent must demonstrate that the description of the feedstock matches one of the feedstocks listed in the adjacent column.

SC5.2 Verification Requirement

Where the feedstock is sourced from a process where fossil-derived materials may be present, the biogenic fraction must be accurately determined and conservatively applied in all carbon accounting calculations.

The Project Proponent must provide one of the following:

• If the Project is a BioCCS Project, the Project must provide demonstrable compliance with the fossil characterisation methodology in the Isometric BioCCS methodology.
• A description of the feedstock generating process demonstrating that the feedstock originates entirely from biological inputs, with no fossil-derived inputs present in the generating process.
• Determination of biomass content in accordance with EN ISO 21644:2021 (radiocarbon method) or ASTM D6866-24. Where the EN ISO 21644 selective dissolution or manual sorting methods are used instead of the radiocarbon method, the Project Proponent must justify the selection and demonstrate its suitability for the feedstock composition.
• Component-based mass balance from documented input composition, demonstrating the biogenic fraction with conservative assumptions.
• Conservative default biogenic fraction values from an authority such as the IPCC, including a demonstration of how the feedstock matches these categories. Where ambiguity exists, the most conservative selection must be used.
• Third-party, representative compositional analysis by an acCertificateed laboratory. Frequency and volume will depend on feedstock composition, biogenic fraction and variability and must be agreed with Isometric in writing.
• Data from existing monitoring obligations, such as the EU ETS MRR.

Criterion ID and Type

Requirement

Documentation Requirements

SC6.1 Validation Requirement

The biofuel feedstock must not originate from crops cultivated on land that held any of the following statuses in or after January 2008, whether or not the land continues to hold that status:

1. Primary forest and other wooded land, namely forest and other wooded land of native species, where there is no clearly visible indication of human activity and the ecological processes are not significantly disturbed.
2. Old-growth forest as defined by the country of harvest.
3. Highly biodiverse forest or other wooded land that is species-rich and not degraded, and formally identified as highly biodiverse by the relevant competent authority.
4. Designated protection areas, including habitats of IUCN-listed threatened species.
5. Highly biodiverse grassland spanning more than one hectare that is:

a. Natural – grassland that would remain grassland in the absence of human intervention and that maintains its natural species composition and ecological characteristics and processes. b. Non-natural – grassland that would cease to be grassland in the absence of human intervention, that is species-rich and not degraded, and that has been identified as highly biodiverse by the relevant competent authority.

1. Heathland, namely vegetated land with low and closed cover, dominated by bushes, shrubs, dwarf shrubs (heather, briars, broom, gorse, laburnum etc.) and herbaceous plants, forming a climax stage of development.
2. Peatland unless evidence is provided that feedstock cultivation/harvesting did not contribute to drainage.

The Project Proponent must provide one of the following:

• Evidence that the region is covered by a current, valid regional risk assessment published by an approved third-party sustainability assurance framework as listed in Table C.1, confirming compliance with this criterion.

• A geospatial exclusion assessment demonstrating the sourcing region of the feedstock does not overlap with any category listed. Suitable geospatial tools include:

• Intact Forest Landscapes 2025 viewer for primary and old-growth forests (free)

• IBAT for designated protection areas and IUCN-listed species habitat (subscription)

• Global Peatland Database for peatland (free)

• Remote sensing evidence demonstrating the sourcing acreage has been in continuous agricultural use since January 2008. In accordance with Section 1.1.1 sourcing acreages may be grouped and assessed using a sub-sampling approach, subject to up-front engagement and written approval from Isometric.

• Evidence that feedstock is certified by a valid certification program under an EC-recognised voluntary scheme with the RED agricultural biomass scope (SURE, REDcert, ISCC EU), or a non-EU equivalent. Equivalent frameworks may be considered on a case-by-case basis pending a demonstration of equivalent assessment scope to those listed above by the Project Proponent.

SC6.2 Validation Requirement

The feedstock must not originate from crops cultivated on land that held any of the following statuses in January 2008, and no longer holds that status:

1. Wetland, defined as land that is covered with or saturated by water permanently or for a significant part of the year.
2. Continuously forested land over one hectare, with trees over five metres and canopy cover above 30%, or trees able to reach those thresholds where they stand.
3. Land with 10-30% canopy cover over one hectare, trees over five metres, or able to reach those thresholds.

The Project Proponent must provide one of the following:

• Evidence that the region is covered by a current, valid regional risk assessment published by an approved third-party sustainability assurance framework as listed in Table C.1, confirming compliance with this criterion.
• A geospatial exclusion assessment demonstrating the sourcing region of the feedstock does not overlap with any category listed. Suitable geospatial tools include:

https://global-surface-water.appspot.com/map

• Remote sensing evidence demonstrating the sourcing acreage has been in continuous agricultural use since January 2008. In accordance with Section 1.1.1 sourcing acreages may be grouped and assessed using a sub-sampling approach, subject to up-front engagement and written approval from Isometric.
• Evidence that feedstock is certified by a valid certification program under an EC-recognised voluntary scheme with the RED agricultural biomass scope (SURE, REDcert, ISCC EU), or a non-EU equivalent. Equivalent frameworks may be considered on a case-by-case basis pending a demonstration of equivalent assessment scope to those listed above by the Project Proponent.

SC6.3

Validation Requirement

The Project is an Eligible Retrofit or Integration.

The Project Proponent must demonstrate that the Project is an Eligible Retrofit or Integration Project demonstrating compliance with the requirements in Appendix E.1, including all documentation requirements, and demonstrate that all feedstock would have been consumed in the absence of the Project intervention.

Criterion ID and Type

Requirement

Documentation Requirements

SC7.1 Validation Requirement

The feedstock must originate from a documented conservation, habitat or ecological management activity undertaken for ecological purposes independent of the Project. Eligible management activities include but are not limited to:

• Wildfire mitigation residues
• Invasive species removal (native² or non-native) residues
• Habitat restoration and maintenance (e.g., heathland, biodiverse grassland) residues
• Residues from native woodland or scrub management undertaken for ecological or biodiversity purposes
• Removal of infested or hazardous trees by a tree surgeon
• Disaster recovery debris (e.g., urban windfall trees, flood-damaged construction materials, post-hurricane clearance debris) undertaken by a third-party.
• Government-sanctioned land clearing residues from non-protected, non-high-value ecosystems, provided land-use-change emissions are attributed to the primary purpose of the clearing activity rather than the Project, and any ecological compensation measures required under the statutory framework governing the clearing activity have been implemented.

The Project Proponent must provide one of the following:

• A documented site management plan approved by a competent conservation authority predating the CDR project that covers the feedstock.
• Evidence of statutory or regulatory management obligations for the site (e.g., SSSI management agreements, Ramsar site obligations) that covers the feedstock.
• Evidence that the feedstock originates from activities undertaken, managed, overseen or authorised by a recognised conservation organisation such as the Wildlife Trust, RSPB, the Nature Conservancy or equivalent.
• Classification of the feedstock as invasive by a regional, national or international authority, accompanied by a documented removal plan.
• A dated forester, arborist or tree surgeon report, issued by an appropriately licensed or certified practitioner (e.g., ISA-certified or local equivalent), identifying the specific tree(s) by location and species, the diagnosed condition (disease, infestation, or structural hazard), and confirming the removal is not conducted under, or scheduled within, a forest management plan or felling licence covering the site.
• Evidence that the feedstock is a residue created by an Isometric Biosphere Project. The BiCRS Project and the Biosphere Project must each demonstrate independent economic feasibility.
• Evidence of a clearing authorisation issued by a competent authority for the land-use-change activity, identifying the site and its stated purpose (e.g., urban development, pipeline or powerline construction), together with documentation confirming the site does not hold a protected area or high-value ecosystem designation, and evidence that any ecological compensation measures required under the applicable statutory framework for the clearing activity have been implemented.
• Evidence that the feedstock is sourced from Eligible Wildfire Mitigation activities as defined in Appendix E.2.

SC7.2 Verification Requirement

The volume of feedstock obtained by the Project must not exceed the volume that would have been generated by the conservation or management activity in the absence of the Project, including existing feedstock end-use.

The Project Proponent must provide one of the following:

• A management plan specifying treatment areas, frequency and estimated yields with contracted feedstock volumes demonstrably within these bounds, including other feedstock offtakes/end-uses.
• A management plan specifying treatment areas, frequency and estimated yields expressed in the units used in the prescription itself (e.g., basal area, stems per acre, or fuel-load/canopy reduction targets) where volume data is not the prescription's native unit accompanied by a reasoned, conservative translation of those metrics into an estimated feedstock volume, with contracted feedstock volumes demonstrably within these bounds, including other feedstock offtakes/end-uses.
• Yield data from the management activity confirming the contracted volume does not exceed the supply of feedstock from the management activity.
• An independent, conservative assessment of the expected feedstock generation volume from the management activity demonstrating that the generated feedstock volumes meet or exceed the Project demand, including other feedstock offtakes/end-uses.
• A legally binding affidavit from the land manager estimating expected generation volumes, corroborated by historical removal records.
• A legally binding affidavit from the feedstock supplier demonstrating that the management behaviour, including the volume of feedstock produced, will not be influenced by the Project offtake, activities or other incentives.
• A purchase agreement demonstrating that the total contribution paid to the feedstock supplier, inclusive of revenue sharing and in-kind benefits, does not exceed the supplier's documented cost of recovering and transporting the feedstock at the point of transfer. This includes cases where the feedstock is received free of charge or the Project Proponent is paid a tipping fee. Where the feedstock supplier is a related party of the Project Proponent, this evidence option is not available.
• Evidence of the extent of the treatment footprint, such as remote sensing time-series documentation, demonstrating that the extent of the treatment is consistent with historical treatment areas or treatment plans that were established before Project involvement, established by a statement from the feedstock supplier.
• Evidence demonstrating the treatment extent and intensity is consistent with historical or comparable treatments conducted by the feedstock supplier.
• Evidence that the treatment extent is equal to or less than the amount set by a permit, stewardship plan or land managers plan predating project engagement confirmed by a statement from the relevant authority.

SC7.3 Verification Requirement

The recovery and transportation of the feedstock must not compromise biosecurity or increase the risk of undesired proliferation of the feedstock species or of any pest or pathogen it carries.

The Project Proponent must provide one of the following:

• A declaration that the Project Proponent’s involvement in the activity presents no plausible risk of pest, disease or invasive-species proliferation.
• Evidence demonstrating that the feedstock, or its affliction, is not at risk of undesirable proliferation.
• A harvesting and transport plan detailing biosecurity measures appropriate to the species based on relevant authority requirements.
• Confirmation that recovery and transportation activities take place before seed set or alternative measures are in place to prevent viable propagule dispersal.

Criterion ID and Type

Requirement

Documentation Requirements

CF1: All feedstock submissions must describe what would have happened to each feedstock in the absence of the Project.

CF1.1 Validation Requirement

The feedstock counterfactual fate must be evidenced. The Project Proponent must demonstrate that the volume of feedstock subject to the claimed counterfactual fate in the sourcing region meets or exceeds the Project’s contracted volume. Where a Project Proponent relies on historical evidence of the counterfactual fate, that evidence must cover a minimum lookback period ending immediately before the Project start date. The minimum lookback period is 5 years for forestry and wood-processing residues, to capture long-term fluctuations in market trends, and 3 years for all other feedstocks. Where data availability or feedstock specifics justify a shorter period, a reduction may be accepted subject to a case-by-case review by Isometric and the VVB. Feedstocks with mixed counterfactual fates must be accurately assessed using mass balance. Where this data resolution is not available, the Project Proponent must select, from the fates evidenced, the fate that produces the largest counterfactual storage deduction under Section 2.4.5 when combined with the corresponding market leakage deduction under Section 2.5, so that the most conservative yet coherent counterfactual fate is selected.

The Project Proponent must provide one of the following:

• Evidence of statutory or regulatory obligations requiring the feedstock to be disposed of or treated via a specific route in the absence of the Project (e.g., waste management regulations, environmental permits, burn permits, or regulatory guidance mandating a defined disposal pathway), or evidence of a regulatory shift that has moved the plausible counterfactual (e.g., a landfill ban shifting the counterfactual to incineration/composting).
• Financial or contractual records demonstrating the existing counterfactual fate of the feedstock. Records must clearly identify the feedstock, counterparties, payment terms and counterfactual fate.
• A demonstration that the Project is an Eligible Retrofit or Integration Project to an underlying facility, demonstrating compliance with the requirements in Appendix E.1, and the counterfactual fate, volume and source of the upstream feedstock remains unchanged by the Project.
• A bespoke independent study from a third party demonstrating the volume of feedstock attributable to defined counterfactual fates.
• Geotagged and timestamped photographic, videographic, or remote sensing data demonstrating the counterfactual fate of the feedstock within the sourcing region. This must include all of the following: the evidence must cover the sourcing region spanning a minimum of 3 years prior to the Project start date, at sufficient frequency and geographic distribution to demonstrate a consistent widespread practice; photographic/videographic evidence must include embedded GPS coordinates and metadata confirming the date and time, with self-aggregated evidence verified by an independent source such as a VVB during a site visit or another independent third party; and the evidence package must demonstrate that the established counterfactual fate is of sufficient magnitude to exceed Project demand, for example via market reports, regional statistics, or an independent specialist assessment confirming that disposal of the feedstock via this route is regionally widespread and demonstrably exceeds project demand.
• Market or economic analysis demonstrating the counterfactual fate of the feedstock — such as market analysis showing the feedstock would have been mobilised for a specific end-use, or an assessment of the expected counterfactual fate based on the most economically viable option in the sourcing region, including all data, references and assumptions used.
• A legally binding affidavit from the feedstock supplier, informed personnel or an independent industry expert with no financial interest in the Project, demonstrating the counterfactual fate of the feedstock and the basis for that determination, with corroborating evidence such as photographic, videographic or evidence of typical industry practice, a cited market report, industry guidance document, regulatory data specific to the feedstock and region, stakeholder interviews, purchase/disposal records.
• Reference-based evidence of the counterfactual fate, where feedstock-specific evidence is not available — either default counterfactual fate assumptions published by a recognised government, intergovernmental, or industry body (e.g., IPCC guidance, EU RED implementing rules, or a recognised life-cycle inventory database), accompanied by a demonstration that the feedstock and sourcing region fall within scope of that default; or documented evidence of the counterfactual fate for an analogous feedstock from the same category and a comparable sourcing region, accompanied by a reasoned justification of the analogy and any conservative adjustments made.

Criterion ID and Type

Requirement

Documentation Requirements

CS1: The feedstock does not meet the conditions of CS2 or CS3. The counterfactual storage of the feedstock must therefore be quantified, whether or not that quantification returns a value of zero.

CS1.1 Validation and Verification Requirement

The counterfactual storage of the feedstock is quantified. This quantification may demonstrate that no counterfactual storage is associated with the feedstock or demonstrate that the feedstock would act as a counterfactual carbon sink in the absence of the Project.

The Project Proponent must provide all of the following:

• A quantification of $CO_2e_{Counterfactual}$ and all relevant parameters as defined in Section 2.4.5.
• All model versions, data, and references used in the quantification.

CS2: The biogenic carbon contained within the feedstock would be fully released into the atmosphere in the absence of the Project. Feedstocks demonstrating compliance with the criterion will be assigned 0 counterfactual storage.

CS2.1 Validation Requirement

The feedstock is subject to conditions that would contribute to full release of the contained biogenic carbon to the atmosphere in the absence of the Project intervention, within 15 years. Documentation requirements to demonstrate the counterfactual fate are included above in Section 2.4.1.

The Project Proponent must provide one of the following:

• Evidence that the feedstock would be subject to high-temperature oxygenic combustion in the counterfactual, such as disposal through controlled or pit burning.
• Evidence that the feedstock is subject to a statutory/regulatory obligation to be incinerated, such as certain controlled wastes.
• Evidence that the feedstock would be combusted in a waste-to-energy facility with no carbon capture in the counterfactual.
• Evidence that the feedstock would be combusted for bioenergy with no carbon capture in the counterfactual, such as projects that are Eligible Retrofits or Integrations to underlying bioenergy/pulp & paper facilities demonstrating compliance with the requirements in Appendix E.1.
• Evidence that the downstream counterfactual fate of the feedstock is emission as a CO₂ stream, such as landfill gas or anaerobic digestion CCS projects.
• Evidence that the feedstock is highly labile, such as fruit pulp, vegetable trimmings or sugarcane bagasse subject to natural or accelerated decay (such as composting).
• Evidence that the feedstock is herbaceous green waste such as grass cuttings subject to natural or accelerated decay (such as composting).
• Evidence that the feedstock is untreated sewage sludge, biosolids or manure that is subject to natural decay (not soil incorporated, landfilled or lagooned etc.).
• Evidence that the feedstock is a non-lignified crop residue, such as a herbaceous crop, obtained at or below the Sustainable Usage Rate. More information on calculating a Sustainable Usage Rate can be found in Appendix D, Section D.1.
• Literature evidence or modelling that demonstrates the most recalcitrant components of the feedstock have a decay rate of k ≥ 0.353 yr^-1 (a half life of 2 years or less) under the counterfactual fate and climate regime. The value of k (or half life) must be cited from peer-reviewed literature or a published national inventory for a demonstrably comparable feedstock, fate and climate.
• Evidence that woody feedstock is processed into chips/sawdust in the counterfactual and undergoes rapid decomposition on the soil surface, without environmental protection, in regions where yearly temperatures average 15°C or above, with an aridity index of 1 or more⁴.

CS3: The feedstock is a residue from wildfire mitigation. Feedstocks demonstrating compliance with the criterion will be assigned 0 counterfactual storage.

CS3.1 Validation Requirement

The feedstock is a residue from wildfire mitigation activities.

The Project Proponent must provide evidence that the feedstock is sourced from Eligible Wildfire Mitigation activities as defined in Appendix E.2.

Model

Developer

Primary Application

Applicable feedstocks

Notes on use

C-BREC

Fingerman et al. (2021) Schatz Energy Research Center and Humboldt State University Department of Environmental Science and Management

Biomass residue counterfactual storage, designed for BiCRS feedstock evaluation.

Forestry residues Agricultural residues Conservation/management residues

Central to conservative depending on parameter selection. Highly robust model for single-pool modelling for woody and agricultural biomass. Climate parameterisation allows translation across climates.

IPCC First Order Decay Model

IPCC

Decomposition for organic waste in landfill. GHG evolution from landfilled organics.

Controlled wastes Manure

Conservative for aerobic decomposition scenarios. Can be very conservative for anaerobic scenarios depending on landfill conditions.

RothC

Rothamsted Research

Soil organic matter and residue decomposition in agricultural systems.

Agricultural residues

Central, well-validated in temperate conditions. Very conservative for decay in tropical soils.

CBM-CFS3

Canadian Forest Service

Forest residue and dead organic matter decomposition.

Forestry residues Conservation residues

Central to conservative. Well validated in boreal conditions. Very conservative for warmer/more humid conditions.

Yasso20 (Yasso07/Yasso15 accepted where required for consistency with a national inventory submission)

Finnish Meteorological Institute

Organic matter decomposition across climate zones. Used in European national inventories.

Forestry residues Conservation residues

Conservative for woody litter. Stable humus fraction is treated as non-decomposable which is very conservative depending on feedstock.

EPA WARM

US EPA

US Waste stream counterfactual decomposition, landfill GHG evolution.

Controlled wastes

Central, well-validated for US waste streams. Application outside the US requires validation against waste composition/climate parameters.

BEAM

NEBRA

US biosolids emission characterisation in various scenarios.

Biosolids

Central, well-validated for US biosolids.

Criterion ID and Type

Requirement

Documentation Requirements

ML1: the Project Proponent must quantify market leakage emissions associated with the feedstock sourced. This criterion only applies to feedstock submissions that are non-compliant with ML2-ML10.

ML1.1 Validation and Verification Requirement

The Project Proponent must conservatively quantify the market leakage emissions, CO₂eLeakage, associated with feedstock sourcing, in accordance with Section 2.5.2.

The Project Proponent must provide all of the following:

• A referenced, conservative quantification of CO₂eLeakage per tonne of feedstock in accordance with the methodology in Section 2.5.2, subject to a review from Isometric and the VVB.
• All documentation and literature used in this quantification.
• All data sets and assumptions used in this quantification.
• A justification of any conservative adjustments made to account for uncertainty, identifying the specific leakage risk pathway and feedstock market characteristics the adjustment addresses, with sensitivity analysis demonstrating the adjustment's effect on the quantified CO₂eLeakage where applicable.

ML2: the Project does not contribute significantly to the revenue of the feedstock supplier. Feedstocks that demonstrate compliance with ML2.1 are considered to have no market leakage emissions, therefore CO₂eLeakage = 0.

ML2.1 Verification Requirement

The Project Proponent's contribution to the revenue of the feedstock supplier is negligible, with no other upstream incentives (e.g., revenue sharing, side payments, or in-kind benefits) provided to the supplier. Where the feedstock supplier is a related party of the Project Proponent, this evidence option is not available.

The Project Proponent must provide one of the following:

• Evidence that the Project receives the feedstock for free, and no other revenue/benefit sharing is made upstream.
• Evidence that revenue contributed to the feedstock supplier, including revenue sharing and in-kind benefit, is equivalent to, or less than, the cost of feedstock recovery and transportation.
• Evidence that the Project Proponent is paid a tipping/gate fee to accept the material, with no other upstream incentives such as revenue sharing or in-kind benefit.
• A benchmarked market analysis of the co-products produced by the supplier, calculated per unit of feedstock produced, which demonstrates revenue contributions including revenue sharing or in-kind benefit, are equal to or lower than the cost of recovery and transportation.
• A legally binding affidavit from a qualified, independent third party with specific regional and industry experience, verifying that payments of this scale and nature to these types of suppliers in the given sector and region would not reasonably affect sourcing, production, or management practices, backed by supporting evidence such as customary local transaction patterns.

ML3: The feedstock has no economic use in the absence of the Project. Feedstocks that demonstrate compliance with ML3.1 and ML3.2 are considered to have no market leakage emissions, therefore CO₂eLeakage = 0.

ML3.1 Validation Requirement

The feedstock serves no alternative economic purpose.

The Project Proponent must provide one of the following:

• Evidence that the feedstock is subject to a statutory or regulatory obligation requiring disposal, such that no alternative use is available.
• Contracts or disposal records demonstrating that the feedstock has had no market purchasers for a minimum of 3 years prior to the Project start date.
• Evidence that the feedstock is a controlled waste at the terminal point of its value chain, such as waste classification or waste disposal records.
• Evidence that the Market Price for the feedstock has been negative for the last 3 years, such that the feedstock supplier or generator is required to pay for its removal (e.g. tipping fee records or disposal invoices).
• Evidence that removal of the feedstock is mandated under an environmental, safety, or land management permit, order, or plan (e.g. hazard mitigation, invasive species control, or wildfire fuel load reduction), demonstrating that retaining the feedstock in its current state would be ecologically or environmentally detrimental.
• An independent ecological or technical assessment that the feedstock, if left in its current state and location, would provide no economic or environmental function.
• Evidence of an operational or physical storage/handling constraint requiring disposal of the feedstock – such as a legally binding attestation from the facility operator, corroborated by dated inventory or photographic records demonstrating that on-site storage capacity has been reached or is imminently exceeded, and that no additional storage or handling capacity is reasonably available.

ML3.2 Validation and Verification Requirement

The Project Proponent does not source the feedstock above the rate at which it is produced.

The Project Proponent must provide one of the following:

• Evidence of a supplier-level Baseline Feedstock Generation Rate, demonstrated over a minimum of 3 years, showing that the surplus available meets or exceeds Project demand.
• Evidence that a regional production surplus of the feedstock has been sustained for a minimum of 3 years and meets or exceeds Project demand.
• A legally binding affidavit from the feedstock supplier, with corroborating evidence such as stockpiles accumulated over a minimum of 3 years, demonstrating that the demand for the feedstock will not exceed supply.
• A legally binding affidavit from a commodities broker, market intermediary or industry expert with relevant regional experience confirming that the regional excess supply of feedstock has persisted for a minimum of 3 years and exceeds project demand.
• Evidence of feedstock disposal at volumes that have exceeded Project demand for a minimum of 3 years, such as regional waste statistics, data from waste facilities or affidavits from waste organisations.
• Contractual agreements between the Project Proponent and the feedstock supplier demonstrating feedstock production volumes that the Project will not exceed.
• Government or agency-published statistics demonstrating that regional feedstock generation, availability, or waste volumes have exceeded Project demand for a minimum of 3 years (e.g. national agricultural residue surveys, biomass resource assessments, or public waste-stream data).
• An independent third-party audit of the source facility's or supplier's production or throughput records over a minimum of 3 years, corroborating the volumes claimed.

ML4: There is a surplus of feedstock that the market cannot absorb. Feedstocks that demonstrate compliance with ML4.1 and ML4.2 are considered to have no market leakage emissions, therefore CO₂eLeakage = 0.

ML4.1 Validation and Verification Requirement

The regional feedstock supply exceeds the demand resulting in a surplus that meets or exceeds Project demand.

The Project Proponent must provide one of the following:

• Evidence of a supplier-level Baseline Feedstock Generation Rate, demonstrated over a minimum of 3 years, showing that the surplus available meets or exceeds Project demand.
• Evidence that a regional production surplus of the feedstock has been sustained for a minimum of 3 years and meets or exceeds Project demand.
• A legally binding affidavit from the feedstock supplier, with corroborating evidence such as stockpiles accumulated over a minimum of 3 years, demonstrating that the demand for the feedstock will not exceed supply.
• A legally binding affidavit from a commodities broker, market intermediary or industry expert with relevant regional experience confirming that the regional excess supply of feedstock has persisted for a minimum of 3 years and exceeds project demand.
• Evidence of feedstock disposal at volumes that have exceeded Project demand for a minimum of 3 years, such as regional waste statistics, data from waste facilities or affidavits from waste organisations.
• Government or agency-published statistics demonstrating that regional feedstock generation, availability, or waste volumes have exceeded Project demand for a minimum of 3 years (e.g. national agricultural residue surveys, biomass resource assessments, or public waste-stream data).
• An independent third-party audit of the source facility's or supplier's production or throughput records over a minimum of 3 years, corroborating the volumes claimed.

ML4.2 Verification Requirement

The Project Proponent’s financial contribution to the feedstock supplier is below the threshold that would reasonably incentivise changes in feedstock production, sourcing or management behaviour.

The Project Proponent must provide one of the following:

• Financial data from the feedstock supplier demonstrating revenue contributions from the Project constitute 10% or less of the total revenue generated by the feedstock supplier.
• A benchmarked market analysis of the co-products produced by the supplier, calculated per unit of feedstock produced, which demonstrates revenue contributions constitute 10% or less of the total revenue generated by the feedstock supplier.
• A legally binding affidavit from the feedstock supplier demonstrating that the procurement of the feedstock will not alter feedstock generation behaviour.
• Evidence that the price paid for the feedstock is at or near the cost of its transport, handling, and/or disposal, such that the payment does not exceed what the supplier would otherwise have spent to dispose of the material.
• A legally binding affidavit from a commodities broker, market intermediary, or industry expert with relevant regional experience confirming that payments of this type and magnitude would not reasonably be expected to influence the supplier's production, sourcing, or management behaviour.
• Evidence that the Project's total annual payment to an individual feedstock supplier does not exceed 10% of the average annual income per person in the supplier's country, as measured by the World Bank's GNI per capita (PPProd)⁵ figure for that country and year. This ensures the payment is small enough, relative to typical local income, that it would not reasonably be expected to influence the supplier's production, sourcing, or waste management behaviour, regardless of the supplier's individual revenue or scale. The Project Proponent must provide the underlying payment records for the supplier, together with the applicable World Bank GNI per capita (PPProd) figure used.

ML5: The feedstock serves an economic use, but can be extracted/diverted at a Sustainable Usage Rate. Feedstocks that demonstrate compliance with ML5.1 and ML5.2 are considered to have no market leakage emissions, therefore CO₂eLeakage = 0.

ML5.1 Verification Requirement

The feedstock must not be extracted/diverted above the Sustainable Usage Rate.

The Project Proponent must provide a quantification of the Sustainable Usage Rate, demonstrating that existing services fulfilled by the feedstock will not be impacted by feedstock extraction/diversion, with evidence that the Project's contracted volume does not exceed the SUR. This quantification must be conducted using one of the following:

• A recognized, field-specific erosion and soil-quality modeling methodology (e.g., USDA NRCS's RUSLE2 and Soil Conditioning Index, RUSLE/USLE, WEPP, EPIC/APEX, or a national soil conservation model), applying site-specific soil, slope, climate, tillage, and yield inputs, conducted or reviewed by a qualified agronomist or NRCS-certified Technical Service Provider (or regional equivalent).
• An alternative quantification methodology, with a referenced justification of its suitability for the feedstock and region in question, subject to Isometric review.

ML5.2 Verification Requirement

The Project Proponent’s financial contribution to the feedstock supplier is below the threshold that would reasonably incentivise changes in feedstock production, sourcing or management behaviour.

The Project Proponent must provide one of the following:

• Financial data from the feedstock supplier demonstrating revenue contributions from the Project constitute 10% or less of the total revenue generated by the feedstock supplier.
• A benchmarked market analysis of the co-products produced by the supplier, calculated per unit of feedstock produced, which demonstrates revenue contributions constitute 10% or less of the total revenue generated by the feedstock supplier.
• A legally binding affidavit from the feedstock supplier demonstrating that the procurement of the feedstock will not alter feedstock generation behaviour.
• Evidence that the price paid for the feedstock is at or near the cost of its transport, handling, and/or disposal, such that the payment does not exceed what the supplier would otherwise have spent to dispose of the material.
• A legally binding affidavit from a commodities broker, market intermediary, or industry expert with relevant regional experience confirming that payments of this type and magnitude would not reasonably be expected to influence the supplier's production, sourcing, or management behaviour.
• Evidence that the Project's total annual payment to an individual feedstock supplier does not exceed 10% of the average annual income per person in the supplier's country, as measured by the World Bank's GNI per capita (PPP)⁵ figure for that country and year. This ensures the payment is small enough, relative to typical local income, that it would not reasonably be expected to influence the supplier's production, sourcing, or waste management behaviour, regardless of the supplier's individual revenue or scale. The Project Proponent must provide the underlying payment records for the supplier, together with the applicable World Bank GNI per capita (PPP) figure used.

ML6: The feedstock is certified under a recognised third-party scheme to establish that the feedstock's sourcing does not incur market leakage. Feedstocks that demonstrate compliance with ML6.1 and ML6.2 are considered to have no market leakage emissions, therefore CO₂eLeakage = 0.

ML6.1 Verification Requirement

The feedstock is certified under a recognised third-party sustainability scheme demonstrating the material qualifies as a genuine waste or residue and has not been diverted from an existing use or market.

The Project Proponent must provide one of the following:

• Evidence that the feedstock is certified under the RSB Low iLUC Risk Biomass Module (RSB-STD-04-001), (satisfying Criteria 1.1 and either 1.2 or 1.3 and 1.4), demonstrating the material is an eligible waste/residue that is generally discarded via landfilling or incineration in the region where it is generated, or was not previously used for electricity generation, heat and power, soil inputs, or as food, feed, or fibre.
• Evidence of certification under an equivalent scheme, accompanied by a demonstration that the scheme's criteria are equivalent in scope and rigor to RSB-STD-04-001, as approved by Isometric on a case-by-case basis.

ML6.2 Verification Requirement

The Project Proponent's financial contribution to the feedstock supplier is below the threshold that would reasonably incentivise changes in feedstock production, sourcing, or management behaviour.

The Project Proponent must provide one of the following:

• Financial data from the feedstock supplier demonstrating revenue contributions from the Project constitute 10% or less of the total revenue generated by the feedstock supplier.
• A benchmarked market analysis of the co-products produced by the supplier, calculated per unit of feedstock produced, which demonstrates revenue contributions constitute 10% or less of the total revenue generated by the feedstock supplier.
• A legally binding affidavit from the feedstock supplier demonstrating that the procurement of the feedstock will not alter feedstock generation behaviour.
• Evidence that the price paid for the feedstock is at or near the cost of its transport, handling, and/or disposal, such that the payment does not exceed what the supplier would otherwise have spent to dispose of the material.
• A legally binding affidavit from a commodities broker, market intermediary, or industry expert with relevant regional experience confirming that payments of this type and magnitude would not reasonably be expected to influence the supplier's production, sourcing, or management behaviour.
• Evidence that the Project's total annual payment to an individual feedstock supplier does not exceed 10% of the average annual income per person in the supplier's country, as measured by the World Bank's GNI per capita (PPP)⁵ figure for that country and year. This ensures the payment is small enough, relative to typical local income, that it would not reasonably be expected to influence the supplier's production, sourcing, or waste management behaviour, regardless of the supplier's individual revenue or scale. The Project Proponent must provide the underlying payment records for the supplier, together with the applicable World Bank GNI per capita (PPP) figure used.

ML7: The feedstock is obtained from an Eligible Wildfire Mitigation programme. Feedstocks that demonstrate compliance with ML7.1 and ML7.2 are considered to have no market leakage emissions, therefore CO₂eLeakage = 0.

ML7.1 Verification Requirement

The feedstock is a residue from wildfire mitigation activities.

The Project Proponent must provide evidence that the feedstock is sourced from Eligible Wildfire Mitigation activities as defined in Appendix E.2.

ML7.2 Verification Requirement

The feedstock does not have a competing offtake.

The Project Proponent must provide one of the following:

• A signed affidavit from the feedstock supplier confirming the feedstock had no alternative economic/environmental use corroborated by evidence such as evidence of previous disposal (disposal records, time stamped & geotagged photographic/videographic evidence).
• Evidence demonstrating there is a regional surplus of such residues that meet or exceed the Project's demand. This may include instances where the Project or underlying facility for an Eligible Retrofit or Integration Project is specifically contracted to reduce the high-hazard fuel burden of a given region such as the BioRAM program.
• Evidence demonstrating the feedstock holds a negative market value in the given sourcing region over the preceding 3 years.
• Evidence that revenue contributed to the feedstock supplier, including revenue sharing and in-kind benefit, is equivalent to, or less than, the cost of feedstock recovery and transportation.
• Evidence of regional stockpiles or disposal data that meet or exceed the Project's demand for the feedstock over the preceding 3 years.

ML8: The feedstock is consumed by the underlying facility regardless of the Project and the Project is an Eligible Retrofit or Integration Project. Feedstocks that demonstrate compliance with ML8.1 and ML8.2 are considered to have no market leakage emissions for the corresponding feedstock, therefore CO₂eLeakage = 0.

ML8.1 Validation Requirement

The Project is an Eligible Retrofit or Integration.

The Project has demonstrated compliance with the requirements in Appendix E.1

ML8.2 Validation and Verification Requirement

The Project must account for any changes to feedstock sourcing, energy generation or changes in the export of primary products that are introduced by the Project to the underlying facility. Where a Project results in a change to the export of the primary products of the underlying facility, the feedstock submission must account for this under ML1 and is ineligible for ML8. Where a Project increases or sustains the demand for feedstock, the marginal feedstock volumes must be conservatively quantified and assessed as a separate greenfield feedstock submission. Where a Project introduces a parasitic load to the system that will be compensated by grid import or behind the meter, non-biomass based energy generation, this must be accounted for in the Project’s LCA.

The Project Proponent must provide evidence covering each of the effects listed in the Requirement column that is applicable to the Project, selecting from the following. Where an effect is not applicable, the Project Proponent must state why:

• Design specification demonstrating no parasitic load, subject to an evaluation of operational performance after commissioning.
• A legally binding statement from the underlying facility or chief engineer confirming that the Project introduces no parasitic load to the underlying facility, corroborated by a single independent site inspection or engineering sign-off, conducted after commissioning, confirming that no additional load-drawing equipment has been installed as part of the Project.
• Continuous monitoring data demonstrating no parasitic load.
• Grid import/export records, combined with feedstock input and primary product output data demonstrating consistent volumes before and after Project establishment.
• Documentation demonstrating the method under which the parasitic load will be compensated, and the emissions associated with the production of the energy required to compensate for the parasitic load accounted for in the LCA.
• A conservative calculation demonstrating the marginal feedstock volumes required to compensate for the parasitic load and/or drop in primary product export accompanied by a separate feedstock submission equivalent to the increased feedstock consumption rate, assessed as a greenfield feedstock submission.

ML9: The Project is an Eligible Retrofit Project in which the underlying facility has a higher baseline emission rate that exceeds the amount that could be captured by the Project. Feedstocks that demonstrate compliance with ML9.1 and ML9.2 are considered to have no market leakage emissions, therefore CO₂eLeakage = 0.

ML9.1 Validation Requirement

The capture capacity of the Project, when accounting for capture efficiency, does not exceed the rate of emission from the underlying facility prior to the Project intervention. The underlying facility must be in good standing, and not subject to imminent closure, decommissioning, insolvency, or non-renewal of operating permits.

The Project Proponent must provide all of the following:

• the Project is an Eligible Retrofit Project demonstrating compliance with the requirements in Appendix E.1.
• A quantification of the capture capacity of the Project, accounting for capture efficiency, demonstrating the emission rate necessary to fulfill the capture capacity.
• A quantification of the emission rate of the underlying facility for 3 years prior to the Project implementation, obtained from monitoring systems such as CEMS, intermittent monitoring systems representative of the facility’s emissions extrapolated to uptime, or modelled based on feedstock input and combustion conditions/flue stack scrubbing.
• A demonstration that the historical emission rate of the underlying facility would have exceeded the capture capacity of the Project for 80% or more of the uptime of the facility, when accounting for capture efficiency.
• Evidence of current and valid operating/environmental permits with no near-term expiry or an affidavit from facility ownership or management confirming no current intention to cease operations within the Crediting Period.

ML9.2 Validation and Verification Requirement

The Project must account for any changes to feedstock sourcing, energy generation or changes in the export of primary products that are introduced by the Project to the underlying facility. Where a Project results in a change to the export of the primary products of the underlying facility, the feedstock submission must account for this under ML1 and are ineligible under ML9. Where a Project increases or sustains the demand for feedstock, the marginal feedstock volumes must be conservatively quantified and assessed as a separate greenfield feedstock submission. Where a Project introduces a parasitic load to the system that will be compensated by grid import or behind the meter, non-biomass based energy generation, this must be accounted for in the Project’s LCA.

The Project Proponent must provide evidence covering each of the effects listed in the Requirement column that is applicable to the Project, selecting from the following. Where an effect is not applicable, the Project Proponent must state why:

• Design specification demonstrating no parasitic load, subject to an evaluation of operational performance after commissioning.
• A legally binding statement from the underlying facility or chief engineer confirming that the Project introduces no parasitic load to the underlying facility, corroborated by a single independent site inspection or engineering sign-off, conducted after commissioning, confirming that no additional load-drawing equipment has been installed as part of the Project.
• Continuous monitoring data demonstrating no parasitic load.
• Grid import/export records, combined with feedstock input and primary product output data demonstrating consistent volumes before and after Project establishment.
• Documentation demonstrating the method under which the parasitic load will be compensated, and the emissions associated with the production of the energy required to compensate for the parasitic load accounted for in the LCA.
• A conservative calculation demonstrating the marginal feedstock volumes required to compensate for the parasitic load and/or drop in primary product export accompanied by a separate feedstock submission equivalent to the increased feedstock consumption rate, assessed as a greenfield feedstock submission.

ML10: The Project is an Eligible Retrofit or Integration Project that does not change the rate at which the feedstock is consumed by the underlying facility or the source of the feedstock and does not decrease the outputs of the underlying facility. Feedstocks that demonstrate compliance with ML10.1 and ML10.2 and ML10.3 are considered to have no market leakage emissions, therefore CO₂eLeakage = 0.

ML10.1 Validation Requirement

The Project is an Eligible Retrofit or Integration.

The Project Proponent must demonstrate compliance with the requirements laid out in Appendix E.1.

ML10.2 Validation and Verification Requirement

The Baseline Feedstock Consumption Rate for the underlying facility is defined and remains unchanged by the Project.

The Project Proponent must provide a quantification of the Baseline Feedstock Consumption Rate as defined in Appendix D and continue to report this for each Reporting Period to ensure the Project does not affect the rate at which the underlying facility sources feedstock.

ML10.3 Validation and Verification Requirement

The rate of production of the outputs of the underlying facility remains unchanged by the Project.

The Project Proponent must provide one of the following:

• An assessment of the input-to-output ratios of the underlying facility confirming the Project has not affected the production efficiency of the underlying facility.
• Monitoring data demonstrating that the output rate of all products has not been changed by the Project compared to the pre-intervention baseline over the 5 years prior to the Project intervention. Shorter lookback periods may be considered with appropriate justification in agreement with Isometric and the VVB. Such deviations will be reported in an explanatory note on the Isometric registry to ensure full transparency.

Criterion ID and Type

Requirement

Documentation Requirements

DSC1.1 Validation Requirement

The feedstock must not originate from land that held any of the following statuses in or after January 2008, whether or not the land continues to hold that status:

1. Primary forest and other wooded land, namely forest and other wooded land of native species, where there is no clearly visible indication of human activity and the ecological processes are not significantly disturbed.
2. Old-growth forest as defined by the country of harvest.
3. Highly biodiverse forest or other wooded land that is species-rich and not degraded, and formally identified as highly biodiverse by the relevant competent authority, unless the production of the raw material is carried out as a prescribed activity under an approved conservation or restoration management plan for that area, consistent with the plan's stated objectives.
4. Highly biodiverse grassland spanning more than one hectare that is:

a. Natural – grassland that would remain grassland in the absence of human intervention and that maintains its natural species composition and ecological characteristics and processes.

b. Non-natural – grassland that would cease to be grassland in the absence of human intervention, that is species-rich and not degraded, and that has been identified as highly biodiverse by the relevant competent authority, unless harvesting is necessary to preserve its status as highly biodiverse grassland.

5. Heathland, namely vegetated land with low and closed cover, dominated by bushes, shrubs, dwarf shrubs (heather, briars, broom, gorse, laburnum etc.) and herbaceous plants, forming a climax stage of development.
6. Peatland unless evidence is provided that feedstock cultivation/harvesting did not contribute to drainage.
7. Riparian buffer zones, unless evidence is provided that the production of the raw material did not interfere with the performance of the buffer zone.
8. Areas where production of feedstock would introduce risk to Higher Conservation Values (HCVs) as defined by the HCV Network.
9. Areas designated for nature protection, either by law or by the relevant competent authority, or for the protection of rare, threatened or endangered ecosystems or species recognised by international agreements or listed by an intergovernmental organisation or the IUCN, unless the Project can demonstrate production did not interfere with those nature protection purposes.

The Project Proponent must provide one of the following:

• A geospatial exclusion assessment demonstrating the sourcing region of the feedstock does not overlap with any category listed. Suitable geospatial tools include:

• Intact Forest Landscapes 2025 viewer for primary and old-growth forests (free)

• IBAT for designated protection areas and IUCN-listed species habitat (subscription)

• Global Peatland Database for peatland (free)

• Remote sensing evidence demonstrating the sourcing acreage has been in continuous agricultural use since January 2008. In accordance with Section 1.1.1 sourcing acreages may be grouped and assessed using a sub-sampling approach, subject to up-front engagement and written approval from Isometric.

• Evidence that feedstock is certified by a valid certification program under an EC-recognised voluntary scheme with the RED agricultural biomass scope (SURE, REDcert, ISCC EU), or a non-EU equivalent.

• Evidence that the harvest is an explicit, prescribed activity under a currently valid conservation or restoration management plan for the specific area, approved by the competent governing authority, where the harvest activity is consistent with the plan's stated management actions. Documentation must include the management plan itself and evidence that the harvested area falls within its geographic scope.

DSC1.2 Validation Requirement

The feedstock must not originate from land that held any of the following statuses in January 2008, and no longer holds that status:

• Wetland, defined as land that is covered with or saturated by water permanently or for a significant part of the year.
• Continuously forested land over one hectare, with trees over five metres and canopy cover above 30%, or trees able to reach those thresholds where they stand.
• Land with 10-30% canopy cover over one hectare, trees over five metres, or able to reach those thresholds, unless the carbon stock loss since the land's reference state is quantified under Section 3.3.2.1.1 and deducted under CO₂e_{Establishment}, and the Project still delivers net removals. The reference state is the land use in January 2008, or twenty years before the feedstock was obtained, whichever is later.

The Project Proponent must provide one of the following:

• A geospatial exclusion assessment demonstrating the sourcing region of the feedstock does not overlap with any category listed.
• Remote sensing evidence demonstrating the sourcing acreage has been in continuous agricultural use since January 2008. In accordance with Section 1.1.1 sourcing acreages may be grouped and assessed using a sub-sampling approach, subject to up-front engagement and written approval from Isometric.
• Evidence that feedstock is certified by a valid certification program under an EC-recognised voluntary scheme with the RED forest biomass scope (SBP EU RED, PEFC RED, ISCC EU), or a non-EU equivalent.
• Evidence that the feedstock is certified against SBP Feedstock Standard v2.1 or equivalent.
• Evidence that feedstock is certified by a valid certification program under an EC-recognised voluntary scheme with the RED agricultural biomass scope (SURE, REDcert, ISCC EU), or a non-EU equivalent.
• Evidence that the feedstock is sourced from Eligible Wildfire Mitigation activities as defined in Appendix E.2.

DSC1.3 Verification Requirement

The feedstock production must not contribute to water scarcity. Where this changes throughout the Project lifetime, and the Project is relying on the stress level of the basis to demonstrate compliance, the Project must then shift cultivation/production behaviour.

The Project Proponent must provide one of the following:

• The feedstock originates from a water basin not categorized as “High” or "Extremely High” water stress under the WRI Aqueduct Water Risk Atlas.
• The feedstock production results in a net reduction in net water extraction compared to the prior land use, typically demonstrated using a water balance equation.
• The feedstock is rain-fed and the Project Proponent demonstrates that no irrigation water is abstracted from the basin for feedstock production.
• the Project Proponent can provide exceptional evidence demonstrating the water used to produce the feedstock has no competing demand, such as unused water treatment effluent, the use of saline water in the context of aquatic/halophytic flora or by the provision of net-new water influx (e.g., Project constructed desalination).

DSC1.4 Validation Requirement

The feedstock production must not contribute to the erosion of high erosion areas.

The Project Proponent must provide one of the following:

• The cultivation area does not exceed a 15% (8.5°) slope gradient using a digital elevation model analysis. Publicly available tools include Copernicus DEM, SRTM or equivalent.
• The area will maintain vegetative cover continuously across the year. Where the feedstock is a perennial crop with a rhizome/root mat persisting harvests, this condition is satisfied.
• An erosion model demonstrating equivalent or lower erosion rates compared to the counterfactual.
• Evidence that the feedstock is sourced from Eligible Wildfire Mitigation activities as defined in Appendix E.2.

DSC1.5 Validation Requirement

The feedstock production must not result in a net warming effect due to albedo.

The Project Proponent must provide one of the following:

• The feedstock produced is non-woody.
• The counterfactual land-use is also wood production.
• The production does not occur on any areas where there is a net warming effect indicated by the data from Hasler et al., 2024*, with the threshold being inclusive of biome-specific uncertainty in the data (see the Isometric Reforestation Protocol Appendix B).
• Local or regional-scale peer-reviewed studies or scientific models demonstrating that the feedstock production area retains a net climate benefit inclusive of albedo effects.

DSC1.6 Verification Requirement

Demand for feedstock production on prime agricultural land* as a main crop, excluding intermediate crops, such as catch crops and cover crops, must be less than 7% of the feedstock intake by LHV. In the context of EU member states, this cap must be 1 percentage point above the member state’s actual 2020 share, or 7%, whichever is lower.

The Project Proponent must provide one of the following:

• Evidence that 100% of the feedstock is produced on non-agricultural land.
• Evidence that ≥93% of the feedstock by LHV is produced on non-prime agricultural land⁶.
• Evidence of crop plans demonstrating the feedstock is an intermediate crop.

DSC1.7 Verification Requirement

The feedstock production must not increase the risk of undesired proliferation.

The Project Proponent must provide one of the following:

• Projects must demonstrate that the feedstock species is not listed on the applicable national invasive species list in the country of operation and provide evidence from a recognised invasive species database (such as GBIF, EPPO, CABI) that the feedstock species has no recorded invasive history in the relevant biogeographic region.
• Projects must confirm that the species variety used has confirmed sterility, both by the vendor and by corroborating evidence such as a lab-based trial or other regionally relevant demonstrations using the same cultivar.
• Projects must implement controls sufficient to demonstrate a low-risk of undesired proliferation. This could include cultivation in a closed system, harvest timings to prevent seed set or buffer zones between cultivation and natural habitats, depending on the feedstock type.
• Evidence that the feedstock was already established and that the Project will not contribute to increased or sustained proliferation.
• Evidence that the feedstock is sourced from Eligible Wildfire Mitigation activities as defined in Appendix E.2.

DSC1.8 Validation and Verification Requirement

The Project Proponent must ensure the feedstock production does not compromise the local environment.

The Project Proponent must provide evidence demonstrating compliance with all requirements in Appendix E.3.

Criterion ID and Type

Requirement

Documentation Requirements

DSC2.1 Validation and Verification Requirement

The feedstock must be sourced from management practices audited against high standards of social and environmental sustainability. Key sustainability principles include:

1. Harvesting is legal.
2. Harvested areas are regenerated in a timely manner. Where the activity aim is to clear an invasive woody species, active restoration of the treatment area must be targeted to the natural state.
3. Protected areas remain protected.
4. Harvesting maintains or enhances soils and biodiversity.

a. Stumps & roots remain in the ground unless belonging to invasive species which are being targeted for removal. b. Forests are not converted into plantations c. Vulnerable soils are not logged d. Clear-cuts stay within size limits set by the country of harvest e. Deadwood and other residues are retained at levels appropriate to the local ecology f. Logging systems & equipment are chosen to prevent harm to the soil quality and to maintain biodiversity and habitats

5. The forest’s long-term capacity to produce is maintained or enhanced.
6. Resource provision to local communities and indigenous people is maintained or enhanced.
7. All management activities comply with international labour laws.

The Project Proponent must demonstrate one of the following:

• Evidence that the feedstock is sourced from Eligible Wildfire Mitigation activities as defined in Appendix E.2.
• Evidence that the feedstock was harvested from an FSC Forest Management (Standard FSC-STD-01-001 or the applicable FSC National Forest Stewardship Standard) certified management unit or a PEFC Sustainable Forest Management (the relevant version of PEFC ST 1003 as implemented through a PEFC-endorsed national scheme for the applicable jurisdiction) certified management unit. The Project Proponent must provide the certificate code and holder, the certification scope, validity dates, and evidence that the harvest area falls within the certified scope accompanied by the chain-of-custody records required under FC1.3 linking the delivered feedstock to that management unit; or
• Completion of the Isometric Forestry Risk Assessment demonstrating a low risk of non-compliance with all criteria. Where an elevated risk is present, the feedstock may still be eligible subject to the implementation and monitoring of appropriate mitigation measures that reduce the subsequent risk to low.
• Evidence that the feedstock production method is considered an environmental restoration activity by an authority and all evidence required in Appendix E.3.

DSC2.2 Validation and Verification Requirement

Projects must demonstrate that the forest carbon stocks in the sourcing region* are stable or increasing. Datasets used must include data from at least as recent as 12 months prior to the start of the Project sourcing activities. The ecological disturbance exemption present in SC1.2 is not available for use here unless the Project can demonstrate the Project is taking an active role in contributing to the mitigation of such an ecological disturbance such as wildfire mitigation, as defined in Appendix E.2 or the removal of infested or invasive woody species or where the Project can demonstrate that the landscape carbon stock will be improved by the Project intervention.

The Project Proponent must provide one of the following:

• Evidence demonstrating, using published forest inventory data, that carbon stocks in the sourcing region are either stable or increasing when comparing the most recent five years to the preceding five-year period. Publicly available datasets that enable carbon stock trend analysis at the jurisdictional level include:

• jmrv.ctrees.org

• Reference an applicable third-party assurance framework that demonstrates that carbon stocks are stable/increasing within the sourcing region.

• Evidence demonstrating compliance with regionally defined maximum allowable cuts relative to growth when comparing the most recent five years to the preceding five-year period.

• Evidence that the feedstock was obtained as a forestry residue from an Isometric Improved Forestry Management, Reforestation or Mangroves Restoration Project (not Agroforestry). The Biosphere Project and the Project utilizing the feedstock must demonstrate independent economic feasibility.

• Independent satellite derived aboveground biomass change products such as ESA CCI biomass or GEDI-derived datasets, accompanied with a justification for why none of the above options was achievable by the Project.

• Evidence that the feedstock is sourced from Eligible Wildfire Mitigation activities as defined in Appendix E.2.

• Evidence that the feedstock is considered invasive in the sourcing area by an authority.

• Evidence that the intervention by the Project Proponent will increase the landscape carbon stock within 15 years from the harvesting event. This evidence must demonstrate the carbon stock is enhanced by complying with the requirements in DLUC1 or DLUC2.

DSC2.3 Validation Requirement

The feedstock must not originate from land that held the following status in or after January 2008, whether or not the land continues to hold that status:

• Primary forest, old-growth forests and other wooded land, namely forest and other wooded land of native species, where there is no clearly visible indication of human activity and the ecological processes are not significantly disturbed.
• Peatland unless evidence is provided that feedstock cultivation/harvesting did not contribute to drainage.

The Project Proponent must provide one of the following:

• Evidence that the region is covered by a current, valid regional risk assessment published by an approved third-party sustainability assurance framework as listed in Table C.1, confirming compliance with this criterion.

• A geospatial exclusion assessment demonstrating the sourcing region of the feedstock does not overlap with primary forests. Public third-party tools include:

• https://peatfires-153915.projects.earthengine.app/view/ifl2025

• Evidence that feedstock is certified by a valid certification program under an EC-recognised voluntary scheme with the RED forest biomass scope (SBP EU RED, PEFC RED, ISCC EU), or a non-EU equivalent. Equivalent frameworks may be considered on a case-by-case basis pending a demonstration of equivalent assessment scope to those listed above by the Project Proponent.

• Evidence that the feedstock was obtained as a forestry residue from an Isometric Biosphere Project through one of the following Protocols: Improved Forestry Management, Reforestation or Mangroves Restoration (not Agroforestry). The Biosphere Project and the Project utilizing the feedstock must demonstrate independent economic feasibility.

• Evidence that the feedstock is sourced from Eligible Wildfire Mitigation activities as defined in Appendix E.2.

DSC2.4 Validation and Verification Requirement

The feedstock must neither have been used in, nor be suitable for use in, a wood-based product in the absence of the Project. This includes use in a wood-based product, extending the service life of a wood-based product, re-use as a wood-based product, and recycling into a wood-based product. This does not apply to material that has already fulfilled its use as a wood-based product and cannot be re-used or recycled into one.

The Project Proponents must provide one of the following:

• End-use/disposal data for the feedstock covering the preceding five years demonstrating a lack of use in wood-based products.
• A legally binding affidavit from the feedstock supplier or an appropriate member of the chain-of-custody, detailing the final fate of the feedstock over the previous five years, corroborated by evidence demonstrating the given fate such as delivery, disposal or sales records.
• Third-party log-grading data, accompanied by an auditable monitoring plan, demonstrating the wood's unsuitability for long-lived wood or pulpwood mills (e.g., characteristics like diameters or lengths falling outside mill tolerances).
• A legally binding affidavit from the feedstock supplier or an appropriate member of the chain-of-custody confirming the wood is unmarketable due to damage (e.g., insect damage, decay, fire-damage), accompanied by dated photographic evidence or a third-party inspection report.
• Contamination data (e.g., chemicals or embedded materials) indicating levels that exceed mill tolerances.
• Letters of rejection or detailed tender/auctions confirming the feedstock is unsuitable for pulpwood or long-lived wood products dated within the preceding 12 months.
• A report demonstrating the absence of an available market for the material within the defined supply base. This report must reference specific mills and include defensible evidence of supply/demand data and the constraints of the defined supply base, which must be appropriate for the material being sourced.
• Evidence that the feedstock is covered by a certificate issued under an EC-recognised voluntary scheme (Article 30(4) of Directive (EU) 2018/2001) or a Member State national scheme (Article 30(6)) whose recognised scope covers forest biomass – such as PEFC RED, SBP, ISCC EU, SURE or KZR INiG – together with documentary evidence that the sourcing jurisdiction applies the cascading use of biomass under Article 3(3) to the feedstock in question and that no Article 3(3a) derogation has been invoked for it.
• Evidence that the feedstock is sourced from Eligible Wildfire Mitigation activities as defined in Appendix E.2.

DSC2.5 Validation and Verification Requirement

The feedstock must not displace, defer or substitute for the production of a wood-based product.

The Project Proponent must provide evidence that the feedstock is sourced from Eligible Wildfire Mitigation activities as defined in Appendix E.2 or provide all of the following:

• Management plans and harvest records for the sourcing region covering the five years preceding the Project start date, and the forward management plan or rotation schedule covering the Crediting Period, demonstrating that no merchantable harvest was scheduled or reasonably foreseeable on the harvested area.
• An assessment of the assortments the stand would have yielded at its counterfactual rotation age, demonstrating they would not have met the accepted tolerances of any wood-based product mill within the accessible sourcing region.
• A legally binding affidavit from the landowner or responsible party, limited to their own holding, confirming that no merchantable harvest of the harvested area was scheduled, contracted or planned, corroborated by financial and harvesting records.

Criterion ID and Type

Requirement

Documentation Requirements

LUD1: All dedicated feedstock submissions must demonstrate what would have happened to the land used for feedstock production in the absence of the Project.

LUD1.1 Validation Requirement

The historical land use for the land used to produce the feedstock is accurately documented.

The Project Proponent must provide one of the following:

• Remote sensing or equivalent independent land-cover time series covering the previous 3 years. Where ambiguity exists, field-based evidence must be included to corroborate the claim.
• Historical land-use records from a land registry, agricultural census or equivalent over the previous 3 years.
• Financial or insurance records tied to specific land and land use covering the previous 3 years.

Criterion ID and Type

Requirement

Documentation Requirements

DLUC1: The production of the feedstock requires/results in the conversion of land. CO₂edLUC is quantified. This may include cases where the Project increases the landscape carbon stocks.

DLUC1.1 Validation Requirement

Where feedstock is produced from land that has undergone a land-cover conversion, the Project Proponent must quantify dLUC as the difference between the carbon stock including above and belowground and soil carbon pools, consistent with the Land Use Declaration. All sustained (>15 year) carbon stock losses must be subtracted from Project removals. Where default values are used, CarbonStockCF must be taken at the upper bound and CarbonStockProj at the lower bound of the published uncertainty range for the applicable land-use category, ecological zone and climate domain.

The Project Proponent must provide one of the following:

• A quantification of CO₂e_dLUC using the framework below, of carbon stock change using Tier 2, country-specific, IPCC default values demonstrating the difference between the carbon stock between the two land states, including the calculation methodology with all data-sets, assumptions and emission/removal factors used. This assessment must demonstrate the applicability of the default value to the given site.
• A quantification of CO₂e_dLUC, using the framework below, of carbon stock change using Tier 1 IPCC default values, with a confirmation that Tier 2 values were not available, demonstrating the difference between the carbon stock between the two land states, including the calculation methodology with all data-sets, assumptions and emission/removal factors used. This assessment must demonstrate the applicability of the default value to the given site.
• A quantification of CO₂e_dLUC, using the framework in Section 3.3.2.1.1, demonstrating both the baseline and post-conversion stock levels derived from direct field measurements or directly comparable regional studies, including the calculation methodology with all data-sets, assumptions and emission/removal factors used.

DLUC2: The production of the feedstock requires a change to management or harvest regime of woody biomass by the Project Proponent, such as the restoration of abandoned plantation systems or the removal of infested trees. CO₂edLUC is quantified.

DLUC2.1 Verification Requirement

The feedstock must have been assessed under DSC2. Where a feedstock is produced from an existing forestry or plantation system subject to a newly introduced or materially intensified harvest regime, such as the restoration of an abandoned plantation or the removal of invasive/infested trees, the Project Proponent must quantify dLUC in accordance with Section 3.3.2.1.2 – establishing the carbon stock removed by the harvest, accounting for the foregone growth as a result of that harvest, and demonstrating the stand is modelled to recover at least 85% of the harvested carbon within 15 years and 100% within 30 years. The fraction of carbon stock that does not recover by year 15 must be subtracted from gross removals. Where a stand subject to a newly introduced or materially intensified harvest regime does not meet the recovery thresholds, feedstock from that stand is ineligible for Certifying under this Module.

The Project Proponent must provide all of the following:

• A determination of $HarvestedStock_i$and quantification of $CO_2e_{dLUC,i}$ consistent with Section 3.3.2.1.2, including the method used, all underlying inventory data, and the calculation methodology, data-sets, assumptions and emission/removal factors applied.
• Evidence that the modelled regrowth trajectory meets the recovery thresholds required for eligibility, including the conservative growth assumption applied and its supporting data sources.
• At the point of any refund claim under Section 3.3.2.1.2, updated field-inventory data demonstrating the actual carbon stock, $CStock_{Actual,i}(t_v)$, consistent with the sampling requirements in Appendix F, Section F.1.

DLUC3: The production of the feedstock does not result in a change in land use or land cover and does not result in a decrease in landscape carbon stocks. Feedstock submissions that demonstrate compliance with the criteria do not result in Direct Land Use Change, therefore CO₂edLUC = 0.

DLUC3.1 Validation Requirement

The feedstock production is consistent with the existing land-use. If the feedstock is an intermediate crop, the feedstock may be eligible under this criterion depending on evidence demonstrating that the introduction of this intermediate crop does not introduce a requirement for a change in agricultural practises that would result in decreases in soil carbon stocks (such as increasing/changing the need/extent of tillage).

The Project Proponent must provide one of the following:

• Evidence of continuous land-use consistent with the Project use over the previous 3 years, demonstrating the Project’s production replaces an existing production regime of demonstrable similarity, such as the continuous cultivation of a perennial crop or a replacement of a perennial crop with another perennial crop. A switch between perennial and annual systems in either direction must be quantified under DLUC1.
• Evidence that the feedstock is an intermediate crop, such as a cover crop, grown between commercial crops, evidenced by planting/harvest data or crop plans for the production land over the previous 3 years and the window of intermediate crop cultivation & harvesting.

DLUC4: The feedstock is produced from wildfire mitigation activities. CO₂edLUC = 0.

DLUC4.1 Validation Requirement

The feedstock is produced from wildfire mitigation programs as defined in Section 1.4.

The Project Proponent must provide evidence that the feedstock is sourced from wildfire mitigation activities as defined in Section 1.4.

Criterion ID and Type

Requirement

Documentation Requirements

ILUC1: The production of the feedstock results in the displacement of productivity. CO₂eLeakage is quantified.

ILUC1.1 Validation and Verification Requirement

The Project Proponent must calculate any indirect land-use change emissions associated with the production of the feedstock.

The Project Proponent must provide all of the following:

• An assessment of the pre-project productivity that was present on the land prior to the Project establishment.
• A quantification of CO₂e_Leakage in accordance with Section 3.3.3.

ILUC2: The land used for feedstock production had no agricultural/forestry production or land use. Feedstocks that demonstrate compliance with this criterion are considered to have no ILUC emissions, therefore CO₂eLeakage = 0.

ILUC2.1 Validation Requirement

The feedstock is produced on one of the following:

• A built environment on land not previously used for agriculture (bioreactors/vertical farming).
• Water or aquatic substrate (e.g., marine biomass) provided the Project Proponent demonstrates that the cultivation area is not subject to an existing aquaculture licence, tenure or concession, and that the area is not subject to commercial fishing effort.
• Land unsuitable for agricultural/forestry production due to soil characteristics (e.g., halophyte cultivation on coastal saline flats).

Land where productivity is only limited by reversible aspects that can be corrected for through typical agricultural management (drainage, soil amendment) is not eligible under ILUC2. Projects may use such land if the Project Proponent can demonstrate that such interventions would not be carried out in the counterfactual due to aspects such as capital intensive requirements.

The Project Proponent must provide one of the following:

• Land-use records demonstrating the historic land use.
• A demonstration of characteristics that make the land unsuitable for agricultural/forestry production.

ILUC3: The land used for feedstock production is reclaimed non-agricultural land. Feedstocks that demonstrate compliance with iLUC3.1 and iLUC3.2 criteria are considered to have no iLUC emissions, therefore CO₂eLeakage = 0.

ILUC3.1 Validation Requirement

The land used for feedstock production was previously extractive, industrial, infrastructural or otherwise non-agricultural with no record of commercial cropping, commercial-intensity grazing or commercial timber harvest over the past 5 years.

The Project Proponent must provide sufficient evidence to demonstrate the absence of commercial agriculture over the past 5 years. Suitable evidence includes but is not limited to:

• Land inventory data
• Regulatory permits/filings (e.g., mining permits)
• Environmental impact assessments
• Site-history documentation prepared for remediation or redevelopment

ILUC3.2 Validation Requirement

The land used for feedstock production is not suitable for commercial agriculture.

The Project Proponent must provide one of the following:

• Remediation obligation under environmental law restricting conventional agricultural uses.
• A regulatory restriction on remediated/reclaimed land such as contamination thresholds above food-crop limited.
• A structural feature preventing conventional agriculture (e.g., a landfill cap preventing tillage, residual mine workings preventing equipment access)
• A contractual restriction such as a deed, conservation easement or post-closure covenant.

ILUC4: The feedstock is an intermediate crop grown on agricultural land. Feedstocks that demonstrate compliance with iLUC4.1 and iLUC4.2 are considered to have no ILUC emissions, therefore CO₂eLeakage = 0.

ILUC4.1 Validation Requirement

The feedstock occupies a window in the agricultural calendar in which no commercial crop was produced on the production unit during the previous 3 years.

The Project Proponent must provide one of the following:

• Direct farm based evidence demonstrating cash-crop planting & harvesting windows and fallow periods (e.g., cropping plans, crop-insurance filings, USDA FSA records or equivalent).
• A remote-sensing time series demonstrating a fallow window through the absence of vegetation indices consistent with active cropping.

ILUC4.2 Verification Requirement

The primary cash crop(s) yields remain at or above the pre-implementation baseline. Feedstocks grown as intermediate crops that result in yield reductions may still be eligible but must account for iLUC emissions through ILUC1.

The Project Proponent must provide one of the following:

• A report demonstrating identical crop rotations in a demonstrably comparable region has not lowered the primary crop(s) yields.
• Peer-reviewed literature evidence demonstrating that identical crop rotations in a demonstrably similar system do not affect primary crop(s) yields, subject to continuous monitoring of yield data.

Where the above cannot be evidenced, the Project must comply with iLUC1. A conservative yield based adjustment can be introduced in consultation with Isometric. Yield data collected before and after Project intervention can be used to demonstrate the yield effect (or lack there of), assessed as a pre-project yield average multiplied by yield growth rate. Variation in regional production of the same crop may be used to demonstrate Project independent variation in yield data. Further information can be found in Section 3.3.3.1.8. If no statistical impact on yield is determined after 5 years, Isometric will refund the conservative adjustment, proportional to the yield data. If a yield reduction of 15% or more is detected, the feedstock will not be eligible for further Certifying.

ILUC5: The land used for feedstock production generated no displaced commodity output in the absence of the Project. Feedstocks that demonstrate compliance with iLUC5.1 and iLUC5.2 are considered to have no iLUC emissions, therefore CO₂eLeakage = 0.

ILUC5.1 Validation Requirement

The feedstock is the product of silvicultural management introduced by the Project, such as thinning, sanitation harvesting or salvage logging, into a stand that was not under an active commercial harvest regime. The harvested area must not have generated any commodity output other than wood products in that period, and the Project’s harvest must not reduce or defer any production of wood products. Where the harvested area supports grazing, non-timber forest product or other commodity output that the Project's harvest reduces or defers, the feedstock is not eligible under ILUC5 and CO₂eLeakage must be quantified under ILUC1. Displacement of wood-product output is assessed in DSC2.4 and DSC2.5 which classifies diversion of long-lived wood products as ineligible.

The Project Proponent must provide all of the following:

• The harvested area’s management history for the five years preceding the Project start date, demonstrating the absence of active commercial harvest regime, such as management plans, felling licences or harvest permits and harvest records. Where no such evidence exists the land-owner must attest to that fact.
• the Project’s harvesting plan, identifying treatment areas, prescription and expected yields.
• An inventory of all commodity outputs from the harvested area for the five years preceding the Project start date, including non-timber forest products, drawn from landowner records or grazing lease agreements or a legally binding affidavit from the landowner or responsible party, limited to their own holding, confirming that the inventory of commodity outputs and that no commercial harvest regime was in force, corroborated by financial or harvesting records.

ILUC5.2 Validation Requirement

The production of the feedstock does not displace other harvesting or the production of products that preceded the Project intervention.

The Project Proponent must provide all of the following:

• Harvest plans from the forest/plantation owner over the previous 5 years demonstrating the isolation of the Project’s harvesting from all other harvesting and production of Products.
• A legally binding affidavit from the land-owner or responsible party demonstrating the Project does not disrupt the production of harvested wood products from the relevant sourcing region, corroborated by financial/harvesting records.

ILUC6: The land used for feedstock production is abandoned agricultural land. Feedstocks that demonstrate compliance with iLUC6.1 and iLUC6.2 are considered to have no iLUC emissions, therefore CO₂eLeakage = 0.

ILUC6.1 Validation Requirement

The feedstock is cultivated on land that transitioned out of an agricultural use at least 5 years prior to Project start date.

The Project Proponent must provide one of the following:

• Land-use records demonstrating the historic land use.
• Satellite data demonstrating the absence of any agricultural production on the land for the preceding 5 years.

ILUC6.2

The land is not enrolled in, and has not been enrolled within the preceding 5 years in, a set-aside, conservation reserve, fallow, or agri-environment payment scheme.

The Project Proponent must provide all of the following:

• A legally binding affidavit that the land is not and has not been enrolled in a relevant program for the preceding 5 years.
• An exhaustive list of any easements or land-use contracts the land has been entered into within the past 5 years.

ILUC7: The feedstock is produced from Eligible Wildfire Mitigation activities. Feedstocks that demonstrate compliance with iLUC7.1 are considered to have no iLUC emissions, therefore CO₂eLeakage = 0.

ILUC7.1 Validation Requirement

The feedstock is produced from government supported wildfire mitigation programs.

The Project Proponent must provide evidence that the feedstock is sourced from Eligible Wildfire Mitigation activities as defined in Appendix E.2.

ILUC7.2 Validation Requirement

The production of the feedstock does not displace other harvesting or the production of products that preceded the Project intervention.

The Project Proponent must provide all of the following:

• Harvest plans from the forest/plantation owner over the previous 5 years demonstrating the isolation of the Project’s harvesting from all other harvesting and production of Products.
• A legally binding affidavit from the land-owner or responsible party demonstrating the Project does not disrupt the production of harvested wood products from the relevant sourcing region, corroborated by financial/harvesting records.