Biomass Feedstock Accounting

The feedstock supplier(s) are defined. For more details on how to handle feedstock aggregators/intermediaries, handling diverse feedstock portfolios and more, see Section 1.3.2 and the Feedstock Supplier definition in Section 1.4.

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 and benefits exchanged

The feedstock Sourcing Region or Regions are classified. A Sourcing Region is defined in Section 1.4 as an area of similar ecological characteristics and the same regulatory requirements.

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 or relevant 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. Where this covers more than one Sourcing Region as defined in Section 1.4, multiple Sourcing Regions must be classified.

The feedstock must have an auditable chain-of-custody that 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, preserve 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.

Purpose-Grown and Standing Stock Feedstocks must use segregation or identity preservation; mass balance is not permitted.

Once a chain-of-custody is established, this remains valid until there is a change in the flow, model or organizations 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.

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 on an as-received basis with the appropriate justification, ensuring all other measurements/calculations are suitably adjusted so that assessments such as a demonstrable oversupply assess the upper bound of demand from a Project.

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 removal volume or compensate for a parasitic energy demand introduced by the Project), if any, must be represented here. Where there is no change to feedstock demand due to the Project intervention, the Project must declare this here with the appropriate justification.

The feedstock is accurately and completely characterized.

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

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 (>10 cm 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 (wet basis) (e.g., through drying or torrefaction), consistent with the EU CRCF.
• Evidence that 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 Project that changes neither the feedstock type/volume nor the storage conditions.
• Evidence that methanogenesis is otherwise avoided given the nature of the feedstock and storage conditions, such as through pile shape dynamics or active ventilation.

Emissions associated with feedstock storage conditions are accurately quantified.

The Project Proponent must provide a calculation of CH₄ emissions resulting from feedstock storage, adjusted to $GWP_{CH_4}$ (100-year basis), to be subtracted from gross removals. Calculation requirements can be found in Section 1.6.1.

The feedstock must not be both suitable for and in demand for use in wood-based products.

Recovered or post-consumer wood is eligible only where it will not practically be re-used or recycled. Saw logs, veneer logs, and industrial-grade roundwood are ineligible.

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. Where the feedstock is not assessed under SC1, a three-year look-back period may be adopted.
• 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 use in wood-based products (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 relevant mill tolerances.
• Letters of rejection or detailed tender/auction results confirming the feedstock is unsuitable for use in wood-based products, dated within the preceding 12 months, attributable to the entire feedstock volume utilized.
• 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. Where public supply and demand statistics are not available for the material, primary evidence such as written statements from the mills in the defined supply base, procurement specifications or tender records may be used.
• Evidence that the feedstock is covered by a certificate issued under an EC-recognized voluntary scheme (Article 30(4) of Directive (EU) 2018/2001) or a Member State national scheme (Article 30(6)) whose recognized scope covers forest biomass – such as PEFC RED, SBP, ISCC EU, SURE or KZR INiG – where the proof of sustainability or sustainability declaration for the consignment identifies the feedstock as a residue category (e.g., harvesting residues, pre-commercial thinnings, sawmill or other processing residues) and not as saw logs, veneer logs, industrial-grade roundwood, stumps or roots (Article 3(3c) of that Directive).
• 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 party² of the Project Proponent, this evidence option is not available.
• Evidence that the feedstock is already being consumed by an underlying facility, 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 of the underlying facility will remain unchanged by the Project. Any feedstock considered sourced directly for a Project must not use this evidence and must be assessed as a separate feedstock submission.
• Evidence that the feedstock is sourced from Eligible Wildfire Mitigation activities as defined in Appendix E.2.

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 three 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's 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.
• Evidence that the feedstock is already in use, and that 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.

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.

   1. Stumps & roots remain in the ground.

   2. Forests are not converted into plantations.

   3. Vulnerable soils are not logged.

   4. Clear-cuts stay within size limits set by the country of harvest.

   5. Deadwood and other residues are retained at levels appropriate to the local ecology.

   6. 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 Peoples is maintained or enhanced.

7. All management activities comply with international labor 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. For more information, see Appendix C.
  • 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 or Project must be provided. A chain-of-custody certificate alone (e.g., FSC CoC) does not satisfy this criterion as such a chain-of-custody may contain feedstock not assessed to a sufficient assurance level.
  • 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. Any feedstock sourced specifically for the Project, such as feedstock sourced to offset a parasitic energy load, must be assessed as a separate feedstock submission, demonstrating the volume has been assessed against a Tier 1 or Tier 2 sustainability assurance framework.
• Evidence that the feedstock is sourced from an area managed under a Tier 1 or Tier 2 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 and criteria to those listed in Table C.1 by the Project Proponent.
• Completion of the Tier 1 or 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 specifically for the Sourcing Region. 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 recognized 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 Biosphere Protocol such as Improved Forest Management, Reforestation or Mangrove Restoration Project. The Biosphere Project must be demonstrably financially independent.

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 not represented 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:
  • CTrees JMRV
  • USFS FIA EVALIDator
  • Forest Information System for Europe (FISE)
• Independent satellite-derived aboveground biomass change products such as ESA CCI biomass or GEDI-derived datasets, accompanied by a justification for why published inventory data or an assurance framework could not be used.
• Evidence referencing an applicable third-party assurance framework that demonstrates that carbon stocks are stable/increasing within the Sourcing Region.
• 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 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 and 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 Biosphere Protocol such as Improved Forest Management, Reforestation or Mangrove Restoration Project. The Biosphere Project must be demonstrably financially independent.

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, including old-growth forests.

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. Suggested geospatial tools include:
  • The Isometric Feedstock Sourcing Region Mapper
  • Intact Forest Landscapes 2025 viewer for primary and old-growth forests (free)
• Evidence that the feedstock is certified by a valid certification program under an EC-recognized 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. Where the feedstock is a downstream wood processing residue, the Project must demonstrate a low risk that the residue originated from an excluded zone.
• Evidence that the feedstock was obtained as a forestry residue from an Isometric Biosphere Protocol such as Improved Forest Management, Reforestation or Mangrove Restoration Project. The Biosphere Project must be demonstrably financially independent.

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:

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

   2. 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 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.

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 Sourcing Region is covered by a current, valid risk assessment issued under a scheme that assesses the land criteria in Article 29(3) and (5) of Directive (EU) 2018/2001, such as REDcert, SURE or ISCC EU, or an equivalent scheme assessing the same land categories, confirming compliance with this criterion.
• A geospatial exclusion assessment demonstrating the Sourcing Region of the feedstock does not overlap with any category listed. Suggested geospatial tools include:
  • The Isometric Feedstock Sourcing Region Mapper
  • Intact Forest Landscapes 2025 viewer for primary and old-growth forests (free)
  • Protected Planet (WDPA) for designated protection areas (free)
  • IBAT for designated protection areas and IUCN-listed species habitat (subscription)
  • Global Pasture Watch grassland map for native and non-native grassland (free)
  • Global Peatland Database for peatland (free)
  • Global Peatland Map 2.0 (UNEP) for peatland (free)
• Remote sensing evidence demonstrating the sourcing acreage has been in continuous agricultural use since January 2008. In accordance with Section 1.3.2, sourcing acreages may be grouped and assessed using a sub-sampling approach, subject to upfront engagement with the VVB and written approval from Isometric.
• Evidence that the feedstock is certified by a valid certification program under an EC-recognized 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.

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 meters 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, with trees over five meters, or trees able to reach those thresholds.

The Project Proponent must provide one of the following:

• Evidence that the Sourcing Region is covered by a current, valid risk assessment issued under a scheme that assesses the land criteria in Article 29(4) of Directive (EU) 2018/2001, such as REDcert, SURE or ISCC EU, or an equivalent scheme assessing the same land categories, confirming compliance with this criterion.
• A geospatial exclusion assessment demonstrating the Sourcing Region of the feedstock does not overlap with any category listed. Suggested geospatial tools include:
  • The Isometric Feedstock Sourcing Region Mapper
  • Global Surface Water Explorer for wetlands (free)
• Remote sensing evidence demonstrating the sourcing acreage has been in continuous agricultural use since January 2008. In accordance with Section 1.3.2, sourcing acreages may be grouped and assessed using a sub-sampling approach, subject to upfront engagement with the VVB and written approval from Isometric.
• Evidence that the feedstock is certified by a valid certification program under an EC-recognized 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.

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 1.3.2, sourcing acreages may be grouped and assessed using a sub-sampling approach, subject to upfront engagement with the VVB and written approval from Isometric.

The Project Proponent must provide one of the following:

• Evidence that the feedstock would not be 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 a Project emission.
• 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 recommends a 13–29% default deduction for a 30% take-rate as a conservative but widely applicable deduction for dry agricultural systems. Other systems may justify a different take-rate and discount supported by evidence such as peer-reviewed literature. Note that in some cases, depending on the take-rate and consequences, the conservative deduction may be 0.

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

An operation is considered unsustainable intensive where either:

1. It is a landless livestock system, meaning less than 10% of the dry matter fed to animals is produced on the farm and annual average stocking exceeds 10 livestock units (LU) per hectare of agricultural land.
2. Livestock are kept in continuous total confinement, meaning ruminants are not given grazing access for at least 120 days per year, or other livestock have no regular access to outdoor range.

The Project Proponent must provide one of the following:

• A purchase agreement showing total contribution to the supplier, including revenue sharing and in-kind benefits, does not exceed the supplier's documented cost of recovering and transporting the feedstock. This includes free-of-charge and tipping-fee cases. Not available where the supplier is a related party.
• Compliance with a market leakage (ML) criterion that demonstrates 0 market leakage, including cases where the market leakage has been quantified and returned 0.
• Annual records showing herd size and stocking density have not increased compared with the three years before first procurement.
• A legally binding affidavit from the feedstock supplier confirming that benefits contributed by the Project will not affect stocking density or practices.
• Evidence the feedstock carries Certified Animal Welfare Approved by A Greener World (AGW) certification, or USDA Organic certification for ruminants, or a demonstrable equivalent whose standard precludes the conditions in point 2.
• Independently corroborated herd and stocking records showing the given operation meets neither point 1 nor 2.
• Evidence that applicable legislation prevents the supplier's operation from increasing livestock numbers, such as a statutory herd-size cap or a production-rights system. The operation must be at its cap, or hold no unused rights or headroom, and must not have acquired additional rights since the Project's date of first procurement. This must be corroborated by the relevant permit or rights register.

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

1. Municipal Solid Waste (MSW), pharmaceutical waste and contaminated/spoiled food/feed
2. Sewage sludge, biosolids and DAF sludge
3. Construction/demolition waste

Other feedstocks may be eligible under this criterion subject to a case-by-case review by Isometric.

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 capture Project.
• Evidence of a waste management contract with a local/regional authority.
• Waste transfer/consignment notes, EPA waste manifests or equivalent.
• Gate/tipping fee documentation.
• Regulatory condemnation or destruction orders.
• Waste carrier or broker registration and transfer documentation.
• Import/export waste movement declaration, such as EU Waste Shipment Regulation documentation or equivalent.

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 wastewater 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 characterizing 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 license 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 waste status and absence of recoverable fractions.
• Source segregation documentation where the feedstock never entered a mixed waste stream demonstrating waste status.
• 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.

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:

• Where the Project is a BioCCS Project, the Project must provide demonstrable compliance with the fossil characterization methodology in the Isometric BioCCS Protocol, referencing that compliance.
• 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 ISO 21644:2021 (radiocarbon method) or ASTM D6866-24 for solid biomass, or ISO 13833 or ASTM D6866 for gaseous feedstock. Where the 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 accredited 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.

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 fiber processing residues.
• Beverage processing residues such as spent grains or wine pomace.
• Commercial landscaping residues such as park maintenance residues or road, rail & utility corridor vegetation.
• Pallet recycling residues.
• Post-industrial or post-consumer woody waste obtained directly from the generating industry or business rather than from a controlled waste stream, such as railway ties, telephone poles and fencing panels.
• Arboricultural residues.
• Compost overs and other green waste.
• Herbaceous/aquatic residues from wastewater treatment.
• A CO₂ stream from a facility consuming one of the above feedstocks.

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.

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 fiber, palm kernel shells/cake, empty fruit bunches, declinant palm stems or palm mill effluent.

The Project Proponent must demonstrate that the feedstock matches one of the feedstocks listed in the adjacent column or has been approved by Isometric in writing as equivalent.

Suitable evidence may include:

• A description of the feedstock generation process demonstrating that the feedstock meets the description of a feedstock in the adjacent column.
• A cross-reference to the feedstock characterization requirements under Section 1.5 demonstrating the feedstock meets the description of a feedstock in the adjacent column.
• A description of the feedstock and a sufficient justification for how the feedstock should be considered of equal sustainability and market leakage risk to the feedstocks presented in the adjacent column.
• Chain-of-custody information demonstrating the feedstock originates from a professional, facility, company or organization that produces the feedstock matching the description of the feedstocks in the adjacent column (e.g., the feedstock supplier is an arborist, or an industrial composting facility).

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:

• Where the Project is a BioCCS Project, the Project must provide demonstrable compliance with the fossil characterization methodology in the Isometric BioCCS Protocol, referencing that compliance.
• 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 ISO 21644:2021 (radiocarbon method) or ASTM D6866-24 for solid biomass, or ISO 13833 or ASTM D6866 for gaseous feedstock. Where the 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 accredited 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.

The Project is an Eligible Retrofit or Integration Project.

The Project Proponent must provide all of the following:

• Evidence demonstrating that the Project is an Eligible Retrofit or Integration Project, demonstrating compliance with the requirements in Appendix E.1, including all documentation requirements, and demonstrating that all feedstock would have been consumed in the absence of the Project intervention.
• Evidence demonstrating that the Project does not stimulate, increase or sustain the use of dedicated energy crops unless accounted for under Section 3. This can include a declaration from the Project Proponent, corroborated by an affidavit from the underlying facility demonstrating that all changes to the feedstock inputs are due to the demand for the Primary Products rather than motivated by the production of CDR, or evidence demonstrating that the Baseline Feedstock Consumption Rate of the underlying facility remains consistent before and after the Project intervention.

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:

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

   2. 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 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.

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 Sourcing Region is covered by a current, valid risk assessment issued under a scheme that assesses the land criteria in Article 29(3) and (5) of Directive (EU) 2018/2001, such as REDcert, SURE or ISCC EU, or an equivalent scheme assessing the same land categories, confirming compliance with this criterion.
• A geospatial exclusion assessment demonstrating the Sourcing Region of the feedstock does not overlap with any category listed. Suggested geospatial tools include:
  • The Isometric Feedstock Sourcing Region Mapper
  • Intact Forest Landscapes 2025 viewer for primary and old-growth forests (free)
  • Protected Planet (WDPA) for designated protection areas (free)
  • IBAT for designated protection areas and IUCN-listed species habitat (subscription)
  • Global Pasture Watch grassland map for native and non-native grassland (free)
  • Global Peatland Database for peatland (free)
  • Global Peatland Map 2.0 (UNEP) for peatland (free)
• Remote sensing evidence demonstrating the sourcing acreage has been in continuous agricultural use since January 2008. In accordance with Section 1.3.2, sourcing acreages may be grouped and assessed using a sub-sampling approach, subject to upfront engagement with the VVB and written approval from Isometric.
• Evidence that the feedstock is certified by a valid certification program under an EC-recognized 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.

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 meters 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, with trees over five meters, or trees able to reach those thresholds.

The Project Proponent must provide one of the following:

• Evidence that the Sourcing Region is covered by a current, valid risk assessment issued under a scheme that assesses the land criteria in Article 29(4) of Directive (EU) 2018/2001, such as REDcert, SURE or ISCC EU, or an equivalent scheme assessing the same land categories, confirming compliance with this criterion.
• A geospatial exclusion assessment demonstrating the Sourcing Region of the feedstock does not overlap with any category listed. Suggested geospatial tools include:
  • The Isometric Feedstock Sourcing Region Mapper
  • Global Surface Water Explorer for wetlands (free)
• Remote sensing evidence demonstrating the sourcing acreage has been in continuous agricultural use since January 2008. In accordance with Section 1.3.2, sourcing acreages may be grouped and assessed using a sub-sampling approach, subject to upfront engagement with the VVB and written approval from Isometric.
• Evidence that the feedstock is certified by a valid certification program under an EC-recognized 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.

The feedstock must originate from a documented conservation, habitat or ecological management activity undertaken for ecological, safety or land management purposes independent of the Project.

Eligible management activities include but are not limited to:

• Pre-committed wildfire mitigation (scheduled or legally committed and funded independently of CDR revenue).
• Invasive species removal (native³ 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 (subject to a demonstration of biogenic content in line with SC4.3), 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 Project that covers the feedstock.
• Evidence of statutory or regulatory management obligations for the site (e.g., SSSI management agreements, Ramsar site obligations) that cover the feedstock.
• Evidence that the feedstock originates from activities undertaken, managed, overseen or authorized by a recognized conservation organization such as The Wildlife Trusts, RSPB, The Nature Conservancy or equivalent.
• A management prescription for the activity, approved by a qualified conservation professional, confirming that the activity is ecologically necessary and consistent with the site's conservation objectives and that the prescription predates, or is otherwise independent of, the Project. The professional must provide evidence of qualifications and a signed conflict-of-interest declaration. A qualified conservation professional holds a professional credential in ecology, wildlife biology, ecological restoration or forestry with ongoing professional accountability, such as Certified Wildlife Biologist (The Wildlife Society), Certified Ecological Restoration Practitioner (Society for Ecological Restoration), Chartered Ecologist (CIEEM) or a credential listed in WF2.2, or is employed by a land management or conservation agency in a role with formal responsibility for habitat management, acting within the scope of that role.
• Classification of the feedstock as invasive by a regional, national or international authority, accompanied by a documented removal plan executed by a third party.
• 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 license covering the site.
• Evidence that the feedstock is a Residue created by an Isometric Biosphere Project. The Biosphere Project must be demonstrably financially independent.
• Evidence of a clearing authorization 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 pre-committed Eligible Wildfire Mitigation activities as defined in Appendix E.2, meaning the treatment was scheduled or legally committed and funded independently of CDR revenue. Wildfire mitigation performed by, or specifically stimulated by, the Project is a Standing Stock Feedstock assessed under SDLUC3.

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:

• Compliance with a market leakage (ML) criterion that demonstrates 0 market leakage, including cases where the market leakage has been quantified and returned 0, together with evidence that the activity would have occurred in the counterfactual, such as an affidavit from the feedstock supplier, harvest plans or clearance orders from authorities.
• 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, expressed as volumes or in the units used in the land manager's prescription (e.g., basal area, age class distribution or stand density) with a reasoned, conservative translation into feedstock volume, corroborated by historical removal records.
• A legally binding affidavit or contractual clause from the feedstock supplier demonstrating that the management behavior, 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, confirmed 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 manager's plan predating Project engagement, confirmed by a statement from the relevant authority.

Where applicable, 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, such as cases where the feedstock consists wholly of native species.
• 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. This includes where the feedstock is delivered to the Project Proponent and the entity transporting the feedstock holds a biomass management plan that covers biosecurity.
• Confirmation that recovery and transportation activities take place before seed set, or that alternative measures are in place to prevent viable propagule dispersal.

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 look-back period ending immediately before the Project start date. The minimum look-back period is five years for forestry and wood-processing residues, to capture long-term fluctuations in market trends, and three 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 consistent 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 historical counterfactual (e.g., a landfill ban shifting the counterfactual from landfill 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 remain unchanged by the Project. Any feedstock sourced specifically for the Project, or where the Project demands a change in feedstock sourcing by the underlying facility, must be assessed separately, without invoking Retrofit or Integration Project options.
• A bespoke study from an independent 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 the look-back period specified in the adjacent column, 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.
  • 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 mobilized 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 or videographic evidence, evidence of typical industry practice, a cited market report, industry guidance documents, regulatory data specific to the feedstock and region, stakeholder interviews, purchase/disposal records, etc., proportional to the claim and risk.
• Reference-based evidence of the counterfactual fate, where feedstock-specific evidence is not available – either default counterfactual fate assumptions published by a recognized government, intergovernmental, or industry body (e.g., IPCC guidance, EU RED implementing rules, or a recognized 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.

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.

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 and can be referenced here.

The Project Proponent must provide one of the following:

• Evidence that the feedstock would be subject to high-temperature oxidative combustion in the counterfactual, such as disposal through controlled or pit burning, or combustion in a waste-to-energy facility with no carbon capture.
• 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 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 feedstock is a CO₂ stream and the counterfactual fate of the feedstock is emission as a CO₂ stream, such as landfill gas or anaerobic digestion CCS Projects.

The feedstock is highly labile and subject to rapid decomposition in the counterfactual.

The Project Proponent must provide one of the following:

• Evidence that the feedstock is untreated sewage sludge, biosolids or manure that is subject to natural decay (e.g., not soil-incorporated, landfilled or lagooned).
• Evidence that the feedstock is a non-lignified crop residue, such as a herbaceous crop residue, obtained from a field at or below the Soil Health Sustainable Usage Rate (Appendix D.1.1).
• Literature evidence or modeling that demonstrates the most recalcitrant components of the feedstock have a decay rate of k ≥ 0.353 yr^-1 (a half-life of 1.96 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 or adjusted using modifiers such as those presented in the C-BREC model framework. The Project must demonstrate that the decay rate presented is representative of the feedstock and the counterfactual fate.
• Evidence that the feedstock is woody and is processed into hog fuel, chips, shavings or 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 more⁵. Where temperature within the Sourcing Region varies to a degree that a portion of the region falls below this threshold, the feedstock may be assessed as an area-weighted mean to determine the relevant value of counterfactual storage, which must be modeled according to the requirements in CS1.
• Evidence that the feedstock is highly labile, such as fruit pulp, vegetable trimmings, grass cuttings or sugarcane bagasse subject to natural or accelerated decay (such as composting).

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.

The Project Proponent must conservatively quantify the market leakage emissions, $CO_2e_{Leakage}$, 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 $CO_2e_{Leakage}$ per tonne of feedstock in accordance with the methodology in Section 2.5.2.
• 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 effect on the quantified $CO_2e_{Leakage}$ where applicable.

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 party² of the Project Proponent, this criterion cannot be used.

Where feedstocks have a demonstrable counterfactual economic use, this option is unavailable.

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 that 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.

The feedstock is in surplus: the volume available meets or exceeds Project demand.

This is demonstrated either because the feedstock serves no counterfactual economic purpose and is not sourced above the Baseline Feedstock Generation Rate, or because regional supply exceeds demand and the market cannot absorb the surplus.

The Project Proponent must provide one of the following:

• Evidence of a supplier-level Baseline Feedstock Generation Rate, demonstrated over the look-back period set out in Appendix D.2, showing that the surplus available after existing offtakes meets or exceeds Project demand.
• Evidence that a regional production surplus of the feedstock has been sustained for a minimum of three years and meets or exceeds Project demand, net of other existing and committed offtakes. This could be established through: the provision of a legally binding affidavit with corroborating evidence of stockpiles; an affidavit from an industry expert with relevant regional experience, regional waste statistics or data; government data on feedstock generation; or an independent third-party audit.
• 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 three years prior to the Project start date, and that the feedstock was not transferred (free of charge or otherwise) to a productive use such as energy recovery, animal bedding or soil amendment.
• Evidence that the feedstock is a controlled waste at the terminal point of its value chain, such as waste classification or waste disposal records, demonstrating the counterfactual use is not productive (e.g., in the absence of the Project the feedstock would not have been used for energy production or for Refuse-Derived Fuel (RDF)).
• Evidence that the market price for the feedstock has been negative for the last three years, such that the feedstock supplier or generator is required to pay for its removal, and that the disposal route involves no energy or material recovery (e.g., landfill without landfill-gas-to-energy, open burning, or incineration without energy recovery) (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, together with evidence that, once removed, the feedstock would be disposed of without productive use.
• 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.
• Evidence that the feedstock is certified under the RSB Low ILUC Risk Biomass Module (RSB-STD-04-001) (satisfying Criterion 1.1 and either (a) Criterion 1.2 or (b) Criteria 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 fiber. Equivalent schemes, accompanied by a demonstration that the scheme's criteria are equivalent in scope and rigor to RSB-STD-04-001, may be considered on a case-by-case basis.

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

Where the feedstock supplier is a related party² of the Project Proponent, this criterion cannot be used.

The Project Proponent must provide one of the following:

• Evidence that payments from the Project constitute 10% or less of the total revenue generated by the feedstock supplier. This may include: feedstock supplier financial records; or a benchmarked market analysis of the co-products produced by the supplier, calculated per unit of feedstock produced, which demonstrates that the Project's revenue contributions constitute 10% or less of the total revenue generated by the feedstock supplier.
• Evidence that the payments would not alter feedstock generation behavior. This could include: a legally binding affidavit from the feedstock supplier; 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; or a legally binding affidavit from an industry expert with relevant regional experience.
• 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, PPP⁶ (current international figure used).

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, previous application and region in question, subject to a review from Isometric.
• Where the existing service fulfilled by the feedstock is a non-market competing demand (e.g., manure relied upon locally for fertilization), the competing demand Sustainable Usage Rate set out in Appendix D.1.2.

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

Where the feedstock supplier is a related party² of the Project Proponent, this criterion cannot be used.

The Project Proponent must provide one of the following:

• Evidence that payments from the Project constitute 10% or less of the total revenue generated by the feedstock supplier. This may include: feedstock supplier financial records; or a benchmarked market analysis of the co-products produced by the supplier, calculated per unit of feedstock produced, which demonstrates that the Project's revenue contributions constitute 10% or less of the total revenue generated by the feedstock supplier.
• Evidence that the payments would not alter feedstock generation behavior. This could include: a legally binding affidavit from the feedstock supplier; 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; or a legally binding affidavit from an industry expert with relevant regional experience.
• 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, PPP⁶ (current international figure used).

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.

The feedstock does not have a competing use.

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, timestamped & geotagged photographic/videographic evidence).
• Evidence demonstrating there is a regional surplus of such residues that meets or exceeds 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 three 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 three years.

The Project is an Eligible Retrofit or Integration Project.

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

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.3 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.

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 five years prior to the Project intervention. Shorter look-back periods may be considered with appropriate justification in agreement with Isometric and the VVB.

The Project is an Eligible Retrofit or Integration Project.

The Project Proponent must demonstrate compliance with the requirements in Appendix E.1 and provide a justification for why ML6 cannot be complied with.

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 ML7, unless the facility operates within a binding emissions trading scheme in which increases in marginal power generation are met by a corresponding abatement of emissions, in which case the Project may reference this to remain compliant under this criterion. This includes where a bioenergy Retrofit or Integration reduces the quantity of energy exported to the grid compared to a non-capture baseline. The marginal reduction in export must be the basis for the leakage calculation.

Where a Project increases or sustains the demand for feedstock, the marginal feedstock volumes must be conservatively quantified and assessed as a separate feedstock submission without invoking any documentation options afforded to Eligible Retrofit or Integration Projects. This includes cases where the Project draws energy from the underlying facility and, to compensate, the underlying facility sources more biomass.

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, the feedstock is eligible under this criterion subject to robust accounting of the associated emissions 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.
• Design specification demonstrating the energy requirements for the Retrofit or Integration Project and a declaration of how these will be accounted for by grid import or non-biomass behind-the-meter energy generation.
• 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 before and after the Project intervention.
• 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 for the increased feedstock consumption that does not invoke any documentation options afforded to Eligible Retrofit or Integration Projects. This may be assessed directly as the change in continuous sourcing volumes of the underlying facility or through a bottom-up assessment of the relevant feedstock-to-energy ratio, using the assessed shortfall in energy output resulting from the Project divided by the energy content of the feedstock, correcting for any conversion inefficiencies.
• A demonstration that the power requirements of the Retrofit or Integration will be compensated for solely through a change in the export of electricity or heat, and the underlying facility exists within a binding emissions trading scheme approved under the Isometric BioCCS Protocol, such that any increase in emissions due to marginal energy generation will be met with a corresponding abatement. This includes the EU ETS when the Market Stability Reserve (MSR) does not trigger. Other emissions trading schemes may be eligible subject to a case-by-case review from Isometric.

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. Highly biodiverse grassland spanning more than one hectare that is:

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

   2. 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.

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 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 High 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 recognized by international agreements or listed by an intergovernmental organization 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. Suggested geospatial tools include:
  • The Isometric Feedstock Sourcing Region Mapper
  • Intact Forest Landscapes 2025 viewer for primary and old-growth forests (free)
  • Protected Planet (WDPA) for designated protection areas (free)
  • IBAT for designated protection areas and IUCN-listed species habitat (subscription)
  • Global Pasture Watch grassland map for native and non-native grassland (free)
  • Global Peatland Database for peatland (free)
  • Global Peatland Map 2.0 (UNEP) for peatland (free)
• Remote sensing evidence demonstrating the sourcing acreage has been in continuous, non-excluded use since January 2008. In accordance with Section 1.3.2, sourcing acreages may be grouped and assessed using a sub-sampling approach, subject to upfront engagement with the VVB and written approval from Isometric.
• Evidence that the feedstock is certified by a valid certification program under an EC-recognized 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 by a valid certification program under an EC-recognized voluntary scheme with the RED agricultural biomass scope (SURE, REDcert, ISCC EU), or a non-EU equivalent.

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 meters 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, with trees over five meters or trees able to reach those thresholds, unless the carbon stock loss since the land's reference state is quantified under Section 3.3.2.1 and deducted from gross removals in the Reporting Period in which the feedstock is utilized, and the Project still delivers net removals.

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. Suggested geospatial tools include:
  • The Isometric Feedstock Sourcing Region Mapper
  • Global Surface Water Explorer for wetlands (free)
• Remote sensing evidence demonstrating the sourcing acreage has been in continuous agricultural use since January 2008. In accordance with Section 1.3.2, sourcing acreages may be grouped and assessed using a sub-sampling approach, subject to upfront engagement with the VVB and written approval from Isometric.
• Evidence that the feedstock is certified by a valid certification program under an EC-recognized 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 the feedstock is certified by a valid certification program under an EC-recognized voluntary scheme with the RED agricultural biomass scope (SURE, REDcert, ISCC EU), or a non-EU equivalent.

The feedstock production must not contribute to water scarcity.

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 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 the provision of net-new water influx (e.g., Project-constructed desalination).

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

The Project Proponent must provide one of the following:

• Evidence that the cultivation area is previously developed and has been continuously hard-covered for the three years prior to the start of feedstock production, such as bioreactors situated on brownfield sites.
• 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. This includes where the cultivation area includes slopes that exceed this range but will remain undisturbed by the cultivation of the feedstock.
• The area will maintain vegetative cover continuously across the year. Where the feedstock is a perennial crop with a rhizome/root mat persisting between harvests, this condition is satisfied.
• An erosion model demonstrating equivalent or lower erosion rates compared to the counterfactual. This includes cases where the Project implements defined erosion mitigation practices such as terracing, contour planting, residue retention etc.
• Evidence that the cultivation of the feedstock is covered by an applicable third-party certification that assesses erosion risk as low.

The feedstock production must not result in a net warming effect due to albedo. This test is made at the Project level against the counterfactual land cover, at the steady state of the production system.

The Project Proponent must provide one of the following:

• Evidence that the feedstock produced is non-woody.
• Evidence that the counterfactual land use has an equivalent or higher canopy density.
• 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 Appendix B of the Isometric Reforestation Protocol).
• 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.

Demand for feedstock production on prime agricultural land⁷ as a main crop, excluding intermediate crops, such as catch crops and cover crops, must be 7% or less of the feedstock intake by LHV.

The Project Proponent must provide one of the following:

• Evidence that 100% of the feedstock is produced on non-agricultural land.
• Evidence that 100% of the feedstock cultivation footprint is considered non-prime agricultural land.
• Evidence that ≥93% of the feedstock by LHV is produced on non-prime agricultural land⁸.
• Evidence of crop plans demonstrating the feedstock is an intermediate crop.

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

The Project Proponent must provide one of the following:

• Evidence that the feedstock species is native to the biogeographic region of the cultivation area, from a regional flora, a national checklist, or native-range data from GBIF or Plants of the World Online.
• Evidence that the feedstock species is not listed on the applicable national invasive species list in the country of operation, together with evidence from a recognized invasive species database (such as GBIF, EPPO or CABI) that the species has no recorded invasive history in the relevant biogeographic region. For EU Member States, the species must also not appear on the Union list of invasive alien species under Regulation (EU) 1143/2014.
• Evidence that the feedstock species has been widely cultivated as a crop in the country or region of operation for at least five years with no recorded escape, naturalization or invasive behavior, supported by national agricultural statistics and an absence of records in recognized invasive species databases.
• An invasive species or weed risk assessment for the feedstock species, completed by a suitably qualified assessor using a recognized screening scheme (such as the Australian Weed Risk Assessment, the EPPO prioritization process for invasive alien plants, or the GB Non-native Risk Assessment scheme), with a low-risk outcome for the country and biogeographic region of operation.
• Written confirmation from the national plant protection or invasive species authority that cultivation of the feedstock species is permitted, or that the authority has no objection, in the area of operation.
• Evidence that the species variety used is sterile, from the vendor and corroborated by a lab-based trial or other regionally relevant demonstration using the same cultivar.
• Evidence of controls sufficient to demonstrate a low risk of undesired proliferation, such as cultivation in a closed system, harvest timings that prevent seed set, or buffer zones between cultivation and natural habitats, depending on the feedstock type.

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

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