BONSUCRO EU-RED

MASS BALANCE CHAIN OF

CUSTODY STANDARD INCLUDING
IMPLEMENTATION GUIDANCE

Version 5.1
March 2019
Bonsucro Mass Balance Chain of Custody Standard including Implementation Guidance 2

About this Document

Bonsucro Bonsucro Mass Balance Chain of Custody Standard Version 5.1 and Bonsucro EU RED Mass Balance Chain of
Custody Standard Version 5.1 were approved by the Bonsucro’s Board of Directors on 31st January 2019. They become
effective from 11th March 2019.

Any Bonsucro Mass Balance Chain of Custody audit taking place between 11th March 2019 and 11th June 2019 can be
carried out against:
• Bonsucro Mass Balance Chain of Custody Standard Version 5.1 or
• Bonsucro EU RED Mass Balance Chain of Custody Standard Version 5.1 or
Version 5.1 • Bonsucro / Bonsucro EU RED Mass Balance Chain of Custody Standard Version 4.1
Published March 2019
Any Bonsucro Mass Balance Chain of Custody audit taking place from 12th June 2019 must be carried out against:
• Bonsucro Mass Balance Chain of Custody Standard Version 5.1 or
• Bonsucro EU RED Mass Balance Chain of Custody Standard Version 5.1

All Bonsucro Mass Balance Chain of Custody certificate holders must be in compliance with Bonsucro Mass Balance
Chain of Custody Standard Version 5.1 or Bonsucro EU RED Mass Balance Chain of Custody Standard Version 5.1 by 12th
June 2020.

About Bonsucro
Bonsucro is a global multi-stakeholder non-profit organisation that exists to promote sustainable sugarcane production,
processing and trade around the world. Bonsucro supports a community of over 500 members in over 40 countries, from
all elements of the sugarcane supply chain, including, farmers, millers, traders, buyers and support organisations.

Bonsucro’s vision is a sugarcane sector with thriving, sustainable producer communities and resilient, assured supply
chains.

Our mission is to ensure that responsible sugarcane production creates lasting value for the people, communities,
Contact
businesses, economies and eco-systems in all cane-growing origins. Bonsucro’s strategy builds a platform to accelerate
Bonsucro, The Wenlock change for the largest agricultural commodity in the world – sugarcane.
50-52 Wharf Road
N1 7EU, London, UK
Bonsucro’s strategy builds a platform to accelerate change for the largest agricultural commodity in the world –
info@bonsucro.com
sugarcane.
www.bonsucro.com

Bonsucro is a full member of the ISEAL Alliance and conducts the process of standards revision in
accordance with the ISEAL Standard Setting Code with input from membership, global stakeholders,
the Smallholder Steering Committee, and the Bonsucro Technical Advisory Board.com

Front & back cover photo: © Joe Woodruff / Bonsucro

Bonsucro Mass Balance Chain of Custody Standard including Implementation Guidance 3

CONTENTS
About this Document................................................. 2 THE BONSUCRO EU-RED CHAIN OF Indicator 2.1.6: Inventory periods. . ......................... 19

About Bonsucro......................................................... 2 CUSTODY (EU-RED ChoC) STANDARD Indicator 2.1.7: Balancing Bonsucro EU-RED
volumes during and between inventory
Contact....................................................................... 2 PRINCIPLE 1 - Implementing the Bonsucro EU-RED
Chain of Custody...................................................... 12 periods..................................................................... 19
Indicator 2.1.8. Expiration of Bonsucro EU-RED
Criterion 1.1 The economic operator shall implement
sustainability data................................................. 20
INTRODUCTION.............................................. 4 the Bonsucro EU-RED ChoC requirements within the
scope identified Indicator 2.1.9. Attribution of Bonsucro EU-RED
Objective of the EU-RED Chain of Custody
Indicator 1.1.1: Overall management sustainability characteristics.................................... 20
Standard..................................................................... 4
responsibility........................................................... 12 Indicator 2.1.10. Wastes and Residues. . ................. 20
Scope of the Bonsucro EU-RED ChoC Standard... 4
Indicator 1.1.2: Procedures. . .................................... 12
Acknowledgements .................................................. 5
Indicator 1.1.3: Record keeping. . ............................. 12 Criterion 2.2 Greenhouse gas data
History of the Document........................................... 5 Indicator 1.1.4: Training........................................... 13 Indicator 2.2.1: Options to comply with the EU-RED
Definitions................................................................... 6 Indicator 1.1.5: Internal audits................................ 13 greenhouse gas criterion.. ...................................... 21

Indicator 1.1.6: Defining the unit of certification for Indicator 2.2.2: Information to be included in
the Bonsucro EU-RED ChoC................................... 13 actual greenhouse gas emissions.......................... 21
SYSTEM DESCRIPTION 6 Indicator 1.1.7: Outsourcing activities.................... 14 Indicator 2.2.3: GHG data transfer through the
Elements Of The Bonsucro Certification System... 8 supply chain............................................................22
PRINCIPLE 2 - Validating and reconciling Bonsucro
EU-RED data............................................................. 15 Indicator 2.2.4: Averaging of GHG data................23
Relation Between the Bonsucro Choc Standard
and the Bonsucro EU-RED ChoC Standard............ 9 Criterion 2.1 The economic operator shall validate
Supply Chain Models................................................ 9 and document Bonsucro EU-RED data
Indicator 2.1.1: Verification of Bonsucro EU-RED
Unit of Certification................................................... 9
status of the supplier.............................................. 15
Summary of Differences Between ChoC Standard Indicator 2.1.2 Verification of data of the incoming
and the EU-RED ChoC Standard............................10 Bonsucro EU-RED certified product...................... 15
Indicator 2.1.3: Conversion rates............................ 16
Indicator 2.1.4: Mixing of Bonsucro certified
products with products fungible with sugarcane-
derived products..................................................... 17
Indicator 2.1.5: Supply of Bonsucro EU-RED
certified product..................................................... 18
Bonsucro Mass Balance Chain of Custody Standard including Implementation Guidance 4

INTRODUCTION
Objective of the Bonsucro Mass Balance Chain of Custody regarding Bonsucro EU-RED certified material shall hold a valid EU-RED
Standard ChoC certificate.

The objective of this Bonsucro EU-RED Mass Balance Chain of Custody Note that in cases of differing requirements between the ChoC standard and
(EU-RED ChoC) Standard is to provide assurance that claims of compliance the EU-RED ChoC Standard the latter standard always prevails if pursuing
with EU-RED requirements can be tracked along the supply chain. The compliance with EU-RED requirements.
Bonsucro EU-RED Chain of Custody Standard is a separate standard to the
generic Bonsucro Chain of Custody Standard (ChoC) and contains
specific requirements for sugar derived products to be qualified for Structure of the Bonsucro Mass Balance Chain of Custody
the EU-RED biofuels and bioliquids markets. Standard including Guidance
This document will outline the Bonsucro EU – RED Mass Balance Chain of
The Bonsucro EU-RED ChoC Standard is intended for ethanol, ETBE or
Custody (ChoC) Standard indicators AND guidance document on how
other products wishing to demonstrate compliance with the EU Renewable
to implement these indicators correctly. The guidance material is clearly
Energy Directive (RED- 2009/28/EC), the EU Fuel Quality Directive (FQD-
distinguishable as it will be surrounded by a grey box.
2009/30/EC), amendments included in Directive 2015/1513 and additional
communication from the European Commission (Com 2010/C 160/02 and BK/
gs/ener.c.1(2014)3648524).

Economic operators undergoing the Bonsucro chain of custody certification

process who wish to sell products in the EU-RED markets must comply with
Bonsucro ChoC Standard and this Bonsucro EU-RED ChoC Standard. It
must also be used by certification bodies and auditors when carrying out
certification audits and surveillance audits.

Scope of the Bonsucro Mass Balance Chain of Custody

Standard
The Bonsucro EU-RED ChoC Standard applies to any economic operator
purchasing, handling and/or trading physical Bonsucro EU-RED compliant
material who wishes to make any claim about the status of the material
or representation of the material in relation to EU-RED sustainability
requirements. It describes the requirements to ensure the traceability of
Bonsucro EU-RED compliant material by implementing a mass balance
supply chain model. Any economic operator that wishes to make a claim
Bonsucro Mass Balance Chain of Custody Standard including Implementation Guidance 5

Acknowledgements History of the Document

The Bonsucro Secretariat would like to express their gratitude to the In September 2018, upon the recommendation of the Bonsucro Secretariat,
participants of the Standard Revision Working Group (SRWG) who have the Board of Directors agreed to start the revision process of the Bonsucro
dedicated time, knowledge and passion to this project. Without their guidance, Mass Balance Chain of Custody Standard and Guidance documents. The
advice and decisions, the Bonsucro Mass Balance Chain of Custody Standard Board instructed the Secretariat to follow the Standard Revision Procedure
including Guidance to the Bonsucro Mass Balance Chain of Custody would set up in line with the ISEAL Code of Best Practice for Standard Setting. The
not have been achieved the expected improvement and relevance. Secretariat called for one representative of each class of membership to
form the Standard Revision Working Group (SRWG). The SRWG met remotely
The Secretariat would also like to thank all stakeholders, including members in October and December 2018. The SRWG was given the task to draft the
of Bonsucro and licensed Certification Bodies, who have shared their new version of the Bonsucro Mass Balance Chain of Custody Standard and
experience and knowledge with the SRWG and ensure the resulting Standard Guidance. All meeting minutes are publicly available on the Bonsucro website.
and guidance are in line with the reality of the industry. Finally the Secretariat
would also like to thank Liza Murphy and Arjen Brinkmann who acted as
independent consultants in guiding the revision process. PUBLICATION DATE OF DESCRIPTION OF
Nahuel Tuñón VERSION PUBLICATION AMENDMENT
Standards Manager Version 3.0 March 2011

Version 4.0 October 2015 Revision in light of amendments

Standard Revision Working Group (SRWG): to RED and FQD, as described
in Directive 2015/1513.
• Dorothee Luisa Polzer, Copersucar
Version 4.1 October 2016 Revision in light of amendments
• Robert Quirk, Independent Farmer
to RED and FQD, as described
• Meredith Smith, ED&F Man in Directive 2015/1513.
• Marionne Lips, CNV International
Version 5.1 March 2019 • Revision of Mass Balance
• Natasha Schwarzbach, PepsiCo principle excluding EU-RED
principles.
• Rewording for consistency and
clarity with revised Bonsucro
ChoC Standard.
Bonsucro Mass Balance Chain of Custody Standard including Implementation Guidance 6

Definitions holds a Bonsucro ChoC certificate, it is referred to as Bonsucro ChoC

Certificate Holder or Certificate Holder.
Normative references for definitions referring to:
EU RED (2009/28/EC) and EU FQD (2009/30/EC) • In relation to EU-RED the term economic operator is used: this is the
organisation seeking or holding Bonsucro EU-RED ChoC certification.
• Agriculture Residues: Agricultural residues are generated directly from An economic operator in the case of Bonsucro EU-RED ChoC may only
sugarcane agriculture (e.g. leaves, thrashes, tops, stumps, roots). They include a single legal entity.
do not include residues from related industries or processing, with the Processing Residues: is a substance that is not the end product(s) that a
exception of sugarcane bagasse, which is considered as an agricultural production process directly seeks to produce. It is not a primary aim of the
residue, as per Annex V, part C, point 18 of EU RED (2009/28/EC). production process and the process has not been deliberately modified to
produce it.
• Biofuel: Liquid or gaseous fuel for transport produced from biomass.
• Site: A single functional unit of an organisation or a combination of units
• Bioliquid: Liquid fuel for energy purposes other than for transport, situated at one locality which is geographically distinct from other units.
including electricity and heating and cooling, produced from biomass. (Adapted from EU RED and Draft ISO Chain of Custody Standard 2015).

• Biomass: Biodegradable fraction of products, waste and residues • Waste: In the context of the EU RED, waste can be understood as any
from biological origin from agriculture (including vegetal and animal substance or object which the holder discards or intends or is required
substances), forestry and related industries including fisheries and to discard. Raw materials that have been intentionally modified, or
aquaculture, as well as the biodegradable fraction of industrial and contaminated, to count as waste (e.g. by adding waste material to a
municipal waste. material that was not waste) are not covered by this definition. See also:
Article 3(1) of Directive 2008/98/EC of the European Parliament and of
• Economic operator: Individual, company or organisation which has the Council.
ownership and/or control of sugarcane and/or all sugarcane derived
products, from their origin to their market availability, for one or several
steps in the supply chain. Please refer to the definition for Organisation
as well. Symbols and Abbreviations
• ChoC: Chain of Custody
• EU-RED: European Union Directive on the promotion of the use of energy • G: Grams
from renewable sources (Renewable Energy Directive, 2009/28/EC). • GHG: Greenhouse Gass(es)
• Ha: Hectares
• Finished product: A finished product is a product where no further • HCV: High Conservation Value
modification occurs (including repacking). • KG: Kilograms
• KJ: Kilojules
• GHG: greenhouse gas(es). • L: Liters
• MJ: Megajoules
• Organisation: legal entity or group of legal entities with one or more sites, • T: Metric Tonne
seeking or holding Bonsucro ChoC certification. In case the organisation • Y: Year
Bonsucro Mass Balance Chain of Custody Standard including Implementation 7

SYSTEM DESCRIPTION
Bonsucro Mass Balance Chain of Custody Standard including Implementation Guidance 8

Elements Of The Bonsucro Certification System Certification process

The Bonsucro Certification System consists of three main elements:
• Only after certification (date when the certificate is issued and the organisation starts
to be listed on the “certified members” list of Bonsucro’s webpage) are organisations
Standards
allowed to make public claims about their purchase of Bonsucro certified products
and/or sell Bonsucro certified products. Any claims must adhere to the Claims &
• The “Bonsucro Production Standard” contains principles and criteria for achieving
Labelling Guidelines as published on the Bonsucro Website.
sustainable production of sugarcane and all sugarcane derived products in respect
of economic, social and environmental dimensions. Bonsucro has developed
• In order to achieve certification with the Bonsucro ChoC Standard, companies must
guidance documents for members that provide further information on how to
be members of Bonsucro and be found in full compliance with all indicators of the
become compliant with the Bonsucro Production Standard.
ChoC Standard.
• The “Bonsucro Production Standard for Smallholder Farmers”, an adaptation of the
• The certification decision will be based on the audit report. Documents showing
Production Standard applicable for smallholder farmers.
evidence of compliance with the indicators must be presented by the organisation to
the independent auditors who will verify them during the audit process.
• The “Bonsucro Mass Balance Chain of Custody Standard” (ChoC) presents the
requirements for Mass Balance activities. The standard includes references to Credit
• The audit must be performed by Bonsucro Licensed Certification Bodies according to
Trading however this is outside the scope of this Standard.
the frequency defined by the Bonsucro Certification Protocol.
• The “Bonsucro EU-RED Mass Balance Chain of Custody Standard” (EU-RED ChoC)
which is a separate standard to the ‘generic’ Bonsucro Mass Balance Chain of
Custody Standard and contains specific requirements for sugarcane products to be
qualified for the EU-RED biofuels and bioliquids markets.

Guidance for implementation

Bonsucro has developed guidance documents for members that provide further
information on how to become compliant with the Bonsucro Production Standard and/or
Chain of Custody Standard.

The “Bonsucro Certification Protocol

Bonsucro has developed a Certification Protocol for auditors that lists the process and
procedures for certification against the Bonsucro Standards.
This includes: 1) rules and requirements for independent Certification Bodies to audit
against the Bonsucro standards, and 2) audit procedures for independent Certification
Bodies to verify compliance with the Bonsucro Standards.

Together, these three elements form the Bonsucro Certification System. As such, these
individual documents must always be used in relation to each other.
Bonsucro Mass Balance Chain of Custody Standard including Implementation Guidance 9

Relation Between the Bonsucro Choc Standard and the Bonsucro throughout the supply chain that:
EU-RED ChoC Standard • takes legal ownership, and
• physically handles Bonsucro certified products at a location under the control of an
The Bonsucro EU-RED ChoC shall be used in conjunction with the valid version of the organisation including outsourced contractors.
Bonsucro ChoC Standard and the Bonsucro Production Standard.
After the end product manufacturer, when the product has been put in its final form
Audits of economic operators against the requirements of the Bonsucro EU-RED ChoC and package there is no further requirement for Chain of Custody certification. This
Standard may only be carried out as an add-on to the requirements of the Bonsucro means that retailers and distributors of finished products do not need Chain of Custody
ChoC Standard and the Bonsucro Production Standard. This means that under the certification.
Bonsucro EU-RED ChoC Standard, all requirements of the Bonsucro ChoC Standard
and the Bonsucro Production Standard must be met (including all EU-RED specific These Chain of Custody requirements also apply under Bonsucro EU-RED Chain of
requirements in the Bonsucro Production Standard. This includes the EU-RED greenhouse Custody. This means that warehouses taking legal ownership and physically receiving
gas calculation methodology included in that Standard). Bonsucro EU-RED certified products into storage shall be Bonsucro EU-RED certified
with the same exemptions applying before they may participate in the Bonsucro EU-RED
Note that in cases of differing requirements between the ChoC standard and the EU-RED scheme.
ChoC Standard the latter standard always prevails if pursuing compliance with EU-RED
requirements. The Bonsucro EU-RED ChoC Standard does not allow credit trading of EU-RED compliant
material, as per EU RED legislation.
If an economic operator is not already Bonsucro ChoC certified, the Bonsucro ChoC and
the Bonsucro EU-RED ChoC audit process may occur simultaneously.
Unit of certification
It is not possible to have operations certified against the Bonsucro EU-RED ChoC
Standard without having a valid Bonsucro ChoC certificate in place that covers that same Under Bonsucro EU-RED ChoC an economic operator has two options for its chosen unit
operation. Should the Bonsucro ChoC certification lapse for any reason the Bonsucro of certification. These are:
EU-RED Choc certification shall also lapse at the same time.
• Single site: a single functional part of an economic operator’s operations or a
combination of parts situated at one locality, e.g. sugarcane mill, terminal, food
Supply chain models processing, storage, tanks.

Bonsucro follows a mass balance approach for tracing Bonsucro certified material in • Multi- site: 2.More than one location either within a single legal entity or across legal
the supply chain, ensuring that at every point in the supply chain volumes of Bonsucro entities that are related via an ownerships structure (e.g. common holding company).
certified outputs match volumes of Bonsucro certified inputs. The following conditions apply:
• Each site in a multi-site certificate shall maintain its own mass balance calculations
In mass balance the volume of Bonsucro certified output is balanced with a physical and records. Mass Balance volumes shall not be transferred between sites.
volume of Bonsucro certified input. This allows the tracking of Bonsucro certified • Multi-site as a unit of certification for facilities that do any processing or
material along the entire supply chain from field to mill (including transportation), transformation is not permitted.
through various steps of production (for example conversion processing, manufacturing, • Multi-site auditing for storage/tanks or any other holding facility is permitted,
transformation) to warehousing, transportation and trade up to and including the end provided that the sites follow a common Internal Control System (ICS) and that
product manufacturer. the Central Office is always subject to audit.
For mass balance the Chain of Custody requirements shall apply to every organisation • One site shall be designated as responsible for maintaining the central
Bonsucro Mass Balance Chain of Custody Standard including Implementation Guidance 10

administration of the ChoC requirements including the individual site mass balance Summary of Differences Between ChoC Standard and the EU-RED
accounting using an Internal Control System (ICS). This site is designated as the ChoC Standard
Central Office.
All operators wishing to comply with EU-RED requirements, and wishing to use multi-site This table is meant to highlight the areas of difference between the Bonsucro ChoC
certification, shall be subject to the following sampling formula for the minimum number Standard and the EU-RED Choc Standard, with particular emphasis on requirements
of audits required for initial assessments: which are stricter in the EU-RED ChoC Standard.

Square root of the total number of sites, rounded up to a whole number for each set of Requirement in ChoC Differences in EU-RED
assessments (audits), plus Central Office. ChoC
Scope Global sugarcane and Specific to products which
The applicable multi-site sampling formulas shall be used as a minimum, and may derived markets shall meet EU-RED requi-
be increased depending on the complexity and risk associated with the operations rements for biofuels and
(depending on the auditor’s professional judgement). bioliquids markets
Requirements for For mills: compliance with For mills: compliance with
As an example: Participation the Production Standard Production Standard inclu-
A multi site storage facility with 7 sites, including the designated Central office: and ChoC standard ding all EU- RED requi-
• Square root of 7 sites equals 2.6, rounded to 3 sites rements, and compliance
• Central Office audit = 1 site with both ChoC Standard
• Total required site audits = 4 sites and EU-RED ChoC Stan-
dard.
All other supply chain ope- All other supply chain ope-
rators require compliance rators require compliance
with the ChoC Standard with both the ChoC and the
EU-RED ChoC
Unit of Certification Single Site Single Site
Multi-Site Multi-Site for storage faci-
lities only.
Each site shall maintain in-
dividual mass balance cal-
culations and records.
Criterion 1.1 Implementing Indicators 1.1.1 through 1.1.8 Differences are in focus of
ChoC Standard content - not implementa-
tion.
Criterion 2.1 Validating Indicators 2.1.1 through 2.1.8 Additional EU-RED data re-
Data quired.
Carryover shall be met with
physical stock, otherwise
not allowed.
Criterion 2.2 Greenhouse No requirements Indicators 2.2.1 through
Gas Data 2.2.4
Bonsucro Mass Balance Chain of Custody Standard including Implementation 11

THE BONSUCRO EU-RED

CHAIN OF CUSTODY
(EU-RED CHOC)
STANDARD
Bonsucro Mass Balance Chain of Custody Standard including Implementation Guidance 12

PRINCIPLE 1 - Implementing the Bonsucro EU-RED Mass Balance Chain of Custody

Criterion 1.1 The economic operator shall implement the Bonsucro EU-RED ChoC requirements within the scope identified

Indicator 1.1.1: Overall management responsibility

The organisation shall establish and document its commitment to implement and maintain the Bonsucro ChoC requirements. The commitment of the organisation shall be made available
to its personnel, suppliers, clients and other stakeholders.

Guidance

As per the ‘generic’ ChoC standard.

Indicator 1.1.2: Procedures

The economic operator shall have written procedures and/or work instructions or equivalent to ensure the implementation of all elements of the Bonsucro EU-RED ChoC requirements.
This shall include at minimum the following:

• Complete and up to date procedures covering the implementation of all the elements of the supply chain model requirements.
• Complete and up to date records and reports that demonstrate compliance with the supply chain model requirements (including training records).
• Identification of the role of the person(s) having overall responsibility for and authority over the implementation of these requirements and compliance with all applicable requirements.
This person(s) shall be able to demonstrate awareness of the economic operator’s procedures for the implementation of this standard.

Guidance

As per the ‘generic’ ChoC standard.

Indicator 1.1.3: Record keeping

The organisation shall maintain accurate, complete, up-to-date and accessible records and reports covering all aspects of the Bonsucro ChoC Standard requirements. Retention times for
all records and reports shall be a minimum of five (5) years.

Guidance

This includes e.g. purchase and sales documents, production records and volume summaries, records of internal procedures and changes thereof, records on training of personnel,
records of internal audits. The system for recording data and documents (e.g. software) shall be adequate to the complexity of the economic operator.
Bonsucro Mass Balance Chain of Custody Standard including Implementation Guidance 13

Indicator 1.1.4: Training

The economic operator shall have a training plan covering Bonsucro EU-RED ChoC Standard requirements, which is subject to on-going review.
Appropriate training shall be provided by the economic operator for personnel carrying out the tasks critical to the effective implementation of the EU-RED ChoC Standard requirements.
Training shall be specific and relevant to the task(s) performed. Records of participants and content shall be maintained

Guidance

As per the ‘generic’ ChoC standard.

Indicator 1.1.5: Internal audits

The organisation shall conduct an annual internal audit to determine whether the organisation;

• Conforms to the requirements in the Bonsucro ChoC Standard.

• Effectively implements and maintains the standard requirements within its organisation. Any non-conformities found as part of the internal audit shall direct corrective actions to be
taken. The outcomes of the internal audits and all actions taken to correct nonconformities shall be subject to management review at least annually. The organisation shall maintain
the internal audit records and reports.
• Corrective actions taken as a result of any nonconformities identified in the internal audit shall be documented, including dates and descriptions of actions taken to resolve them.
The procedure for the annual internal audit process shall be documented.

Guidance

As per the ‘generic’ ChoC standard.

Indicator 1.1.6: Defining the unit of certification

The economic operator shall define and document its unit(s) of certification.
In the case of multi-site certification, the economic operator shall define and document the legal entities and sites covered by the multi-site Bonsucro EU-RED ChoC certificate, including
details on the site designated as the Central Office for administering Bonsucro EU-RED ChoC data.

Under Bonsucro EU-RED ChoC each site in a multi-site certificate shall maintain its own mass balance calculations and records. Mass balance data shall not be transferred between sites
for the purpose of calculating mass balance volumes.

The relationship between the sites shall be described and documented. The economic operator shall document any changes that may occur in the scope of the unit(s) of certification, and
notify its certification body and the Bonsucro Secretariat at least one week before the change goes into effect.
Bonsucro Mass Balance Chain of Custody Standard including Implementation Guidance 14

Guidance

A Multi-Site certificate can be more than one location either within a single legal entity or across legal entities that are related via an ownerships structure (e.g. common holding
company). The following conditions apply:

• Each site in a multi-site certificate shall maintain its own mass balance calculations and records. Mass Balance volumes shall not be transferred between sites.
• Multi-site as a unit of certification for facilities that do any processing or transformation is not permitted.
• Multi-site auditing for storage/tanks or any other holding facility is permitted, provided that the sites follow a common Internal Control System (ICS) and that the Central Office is
always subject to audit.
• One site shall be designated as responsible for maintaining the central administration of the ChoC requirements including the individual site mass balance accounting using an
Internal Control System (ICS). This site is designated as the Central Office.

Indicator 1.1.7: Outsourcing activities

In cases where a Bonsucro EU-RED ChoC certified economic operator outsources activities to independent third parties (e.g. subcontractors for storage, transport or other outsourced
activities), the certified economic operator shall ensure that the independent third party complies with the requirements of the Bonsucro EU-RED ChoC Standard.

This requirement is not applicable to outsourced storage facilities where the management of the Bonsucro certified product(s) and instructions for tank movements are controlled by the
certified economic operator (not the tank farm manager).

A Bonsucro certified economic operator which includes outsourcing within the scope of their Bonsucro EU-RED ChoC certificate shall ensure the following:

• The certified economic operator has legal ownership of all input material to be included in outsourced processes;
• The certified economic operator has an agreement or contract covering the outsourced process with each contractor through a signed and enforceable agreement with the contractor.
The certified economic operator shall ensure that its certification body has access to the outsourcing contractor or operation if an audit is deemed necessary, including all necessary
documentation. If this is not possible, the outsourced contractor shall obtain a Bonsucro EU -RED ChoC certificate independently.
• The economic operator has a documented control system with explicit procedures for the outsourced process which is communicated to the relevant contractor.
• The economic operator shall record the names and contact details of all contractors used for the processing or physical handling of Bonsucro EU-RED certified products. An up to date
record shall be made available to the economic operators certification body at its next audit.

Guidance

As per the ‘generic’ ChoC standard.

Bonsucro Mass Balance Chain of Custody Standard including Implementation Guidance 15

PRINCIPLE 2: Validating and reconciling Bonsucro EU-RED data

Criterion 2.1 The economic operator shall validate and document Bonsucro EU-RED data

Indicator 2.1.1: Verification of Bonsucro EU-RED status of the supplier

The receiving economic operator shall verify the current Bonsucro EU-RED status of the supplier at the time of the purchase.
No incoming material certified under other schemes can be considered as Bonsucro EU-RED compliant.
Incoming material which does not comply with the EU-RED requirements in the Bonsucro Production Standard and/or is from a supplier that is not Bonsucro EU-RED ChoC certified shall
not be considered as Bonsucro EU-RED compliant.

Guidance

This includes checking the validity of the supplier’s Bonsucro EU-RED ChoC certificate. All Bonsucro EU-RED certified entities and certificate numbers are displayed on the Bonsucro
website. In cases of uncertainty, the Bonsucro secretariat must be contacted for clarification.
No incoming material certified under other schemes can be considered as Bonsucro EU compliant.

Indicator 2.1.2: Verification of data of the incoming Bonsucro EU-RED certified product

The receiving economic operator shall verify that the supplier contract, invoice and/or supporting documentation, including associated sustainability characteristics of Bonsucro EU-RED
certified products meet the following requirements:

• Specification of original raw material or intermediary product: Sugarcane, Sugarcane juice, Sugarcane molasses, Sugarcane bagasse, Sugarcane straw, Sugarcane thrashes (tops,
leaves, roots).
• The mass (kg or tonnes) or volume (litres or m3).
• Specification of sugar (sugar content in % sucrose), molasses for fermentation (% Brix), or specification of ethanol (alcohol content in % v/v) or for any other derived products the
appropriate measure of purity.
• Evidence showing compliance with the Bonsucro EU-RED Production Standard.
• Buyer and seller contact information.
• Country of origin.
• Date when biofuel/bioliquid installation started operations.
• Whenever actual GHG values are used, the actual GHG values [kg CO2eq] per dry tons (sugarcane, sugar, molasses, bagasse and other intermediary products) or per MJ (bioethanol)
calculated according to the Annex V of the EU Renewable Energy Directive (2009/28/EC), Annex IV of the EU Fuel Quality Directive (2009/30/EC), and Annex II of Directive 2015/1513
and EC Note BK/abd/ener.c.1(2015)4507918, using any EC-approved GHG calculation tool. See also Annex 3 of Bonsucro Production Standard for more details.
• Accurate data on all relevant elements of the GHG emission calculation formula,( i.e. eec, el, ep,etd and eee) See also Annex 3 of Bonsucro Production Standard for more details.
• If at any point in the chain of custody emissions have occurred and are not recorded, so that the calculation of an actual value is no longer feasible for operators downstream in the
chain of custody, this must be clearly indicated in the delivery notes.
Bonsucro Mass Balance Chain of Custody Standard including Implementation Guidance 16

• Whenever default GHG values are used, the mention “default value”, with the exception of bioethanol producer, who shall indicate the default value as per EU RED Annex V and the
corresponding GHG savings, compared to the fossil reference.

The data shall be entered into the receiving economic operator’s administrative system within one month of taking ownership.

Guidance

‘Country of origin’ is the country where the sugar cane was grown.
‘Date when biofuel/bioliquid installation started operations’ refers to the date on which the installation that produces the biofuels or bioliquids first became operational.

For installations* starting operations after 5 October 2015:

The greenhouse gas emission saving from the use of biofuels and bioliquids shall be at least 60 % less than the threshold established by the European Union legislation based on a Fossil
Fuel Comparator (FFC) of 83.8 g CO2eq/MJ**. Therefore, the global warming burden of compliant biofuel and bioliquids shall be less than 33.5 g CO2 eq/MJ.

For installations* having started operations on or before 5 October 2015:

Until 31 December 2017, the greenhouse gas emission saving from the use of biofuels and bioliquids shall be at least 35 % less than the threshold established by the European Union
legislation based on a Fossil Fuel Comparator (FFC) of 83.8 g CO2 eq/MJ**. Therefore, the global warming burden of compliant biofuel and bioliquids shall be less than 54.4 g CO2 eq/
MJ until 31 December 2017. With effect from 1 January 2018, the greenhouse gas emission saving from the use of biofuels and bioliquids shall be at least 50 % (therefore less than 41.9 g
CO2 eq/MJ).

* The term ‘installation’ includes any processing installation used in the sugar, sugarcane or ethanol production process. This does not include production facilities that might have been
intentionally added to the production chain only to qualify for the exemption foreseen in this provision.

** Should the threshold, FCC value, or default values change as established by European Union Legislation, this will be reflected in the scheme with immediate effect.

‘Evidence showing compliance with the Bonsucro EU – RED Production Standard’ means evidence that the producer from which the sugarcane was obtained holds a valid Bonsucro EU
– RED Production Standard certificate. For Supply chain actors evidence means that the suppliers from which the Bonsucro certified material is purchased from holds a valid Bonsucro
EU-RED ChoC Standard certificate.

In case of discrepancies between the documentation and the material received, the receiving economic operator shall contact its supplier and require for data correction. Corrected
data shall be received and entered into the receiving economic operator’s administrative system before sustainability data is passed on to the next economic operator.

Multiple receipts with common supplier and with identical Bonsucro EU-RED sustainability characteristics may administratively be combined as one batch for reporting purposes

Indicator 2.1.3: Conversion rates

A conversion rate describes the change in quantity of a specific material that occurs due to processing of the respective material at a specific site. Conversion rates and the resulting
changes of quantities shall be site-specific and product-specific. Conversion rates shall be based on actual data (e.g. processing or production data). The output weight or volume after
Bonsucro Mass Balance Chain of Custody Standard including Implementation Guidance 17

conversion shall be expressed as 100% sucrose or ethanol equivalents.

Conversion rates used shall be documented and are subject to verification during the audit.

Conversion rates shall be provided by any Bonsucro EU-RED ChoC certificate holder that modifies their inputs in any way all the elements of the chain of custody each time such a change
in quantity occurs.

In the case of multi-site certificates the designated Central Office shall keep records of conversion rates realized at each site included in the multi-site certificate and for all products
processed on those sites.

Guidance

As per the ‘generic’ ChoC standard.

Indicator 2.1.4: Mixing of Bonsucro certified products with products fungible with sugarcane-derived products

In every case where a batch of Bonsucro certified product was mixed with other products which are fungible with sugarcane-derived products, the Bonsucro data may be allocated to
any physical consignment taken from that batch, provided that input and output of Bonsucro data match (no overclaiming of Bonsucro data).

Guidance

Example:
“Clean Energy” buys different biofuels. On May 4th, the economic operator bought 1,000 m3 of Bonsucro EU RED certified ethanol produced in Brazil. On the same day, it bought 500 m3
biodiesel certified by ABC and with origin in Asia. On the next day, “Clean Energy” bought 2,000 m3 ethanol produced from corn and with XYZ certification. On May 6th, the economic
operator sold to one of its clients, 500 m3 of biodiesel with ABC certification and 1,000 m3 Bonsucro EU RED certified ethanol. Since, biodiesel and ethanol are not fungible, i.e. cannot be
mixed without losing its characteristics, the volumes must maintain the original certification. “Clean Energy” is compliant with indicator 2.1.4.

Procurement department
Date Supplier Product Feedstock Origin Certification Quantity
04/05/2018 X Ethanol Sugarcane Brazil Bonsucro 1000
04/05/2018 Y Biodiesel Palm Asia ABC 500
05/05/2018 Y Ethanol Corn USA XYZ 2000

Commercial department
Date Client Product Origin Certification Quantity
06/05/2018 A Biodiesel Asia ABC 1000
06/05/2018 A Ethanol Brazil Bonsucro 1000
Bonsucro Mass Balance Chain of Custody Standard including Implementation Guidance 18

Indicator 2.1.5: Supply of Bonsucro EU-RED certified product

The economic operator shall ensure that the delivery contract, invoice and/or supporting documentation, including associated sustainability characteristics of Bonsucro EU-RED certified
products meet the following requirements:

• Specification of original raw material or intermediary product: Sugarcane, Sugarcane juice, Sugarcane molasses, Sugarcane bagasse, Sugarcane straw, Sugarcane thrashes (tops,
leaves, roots).
• The mass (kg or tonnes) or volume (litres or m3).
• Specification of product purity (sucrose content % in sugar), molasses for fermentation (% Brix), or specification of ethanol (alcohol content in % v/v) or for any other derived products
the appropriate measure of purity.
• Evidence showing compliance with the Bonsucro EU-RED Production Standard.
• Buyer and seller contact information.
• Country of origin.
• Date when biofuel/bioliquid installation started operations.
• Whenever actual GHG values are used, the actual GHG values [kg CO2eq] per dry tons (sugarcane, sugar, molasses, bagasse and other intermediary products) or per MJ (bioethanol)
calculated according to the Annex V of the EU Renewable Energy Directive (2009/28/EC), Annex IV of the EU Fuel Quality Directive (2009/30/EC), and Annex II of Directive 2015/1513
and EC Note BK/abd/ener.c.1(2015)4507918, using any EC-approved GHG calculation tool. See also Annex 3 of Bonsucro Production Standard for more details.
• Accurate data on all relevant elements of the emission calculation formula, (i.e. eec, el, ep,etd and eee). See also Annex 3 of Bonsucro Production Standard for more details.
• If at any point of the chain of custody emissions have occurred and are not recorded, so that the calculation of an actual value is no longer feasible for operators downstream in the
chain of custody, this must be clearly indicated in the delivery notes.
• Whenever default GHG values are used, the mention “default value”, with the exception of bioethanol producer, who shall indicate the default value as per EU RED Annex V and the
corresponding GHG savings, compared to the fossil reference.

The sale data shall be entered into the economic operator’s administrative system within one week terminating ownership.

Guidance

‘Country of origin’ is the country where the sugar cane was grown.
‘Date when biofuel/bioliquid installation started operations’ refers to the date on which the installation that produces the biofuels or bioliquids first became operational.

For installations* starting operations after 5 October 2015:

The greenhouse gas emission saving from the use of biofuels and bioliquids shall be at least 60 % less than the threshold established by the European Union legislation based on a Fossil
Fuel Comparator (FFC) of 83.8 g CO2eq/MJ**. Therefore, the global warming burden of compliant biofuel and bioliquids shall be less than 33.5 g CO2 eq/MJ.

For installations* having started operations on or before 5 October 2015:

Until 31 December 2017, the greenhouse gas emission saving from the use of biofuels and bioliquids shall be at least 35 % less than the threshold established by the European Union legis-
lation based on a Fossil Fuel Comparator (FFC) of 83.8 g CO2 eq/MJ**. Therefore, the global warming burden of compliant biofuel and bioliquids shall be less than 54.4 g CO2 eq/MJ until
31 December 2017. With effect from 1 January 2018, the greenhouse gas emission saving from the use of biofuels and bioliquids shall be at least 50 % (therefore less than 41.9 g CO2 eq/
MJ).

* The term ‘installation’ includes any processing installation used in the sugar, sugarcane or ethanol production process. This does not include production facilities that might have been
Bonsucro Mass Balance Chain of Custody Standard including Implementation Guidance 19

intentionally added to the production chain only to qualify for the exemption foreseen in this provision.

** Should the threshold, FCC value, or default values change as established by European Union Legislation, this will be reflected in the scheme with immediate effect.

‘Evidence showing compliance with the Bonsucro EU – RED Production Standard’ means evidence that the producer from which the sugarcane was obtained holds a valid Bonsucro EU
– RED Production Standard certificate. For Supply chain actors evidence means that the suppliers from which the Bonsucro certified material is purchased from holds a valid Bonsucro
EU-RED ChoC Standard certificate.

The sustainability characteristics of the batch may be delivered in any form or layout and are required to reference the specific batch. For example the sustainability characteristics may
be included as part of the Delivery Note, and Invoice or be attached as an Annex to the the chosen contract document.
Multiple receipts with common supplier and with identical sustainability characteristics may administratively be combined as one batch for reporting purposes (internally and for client
documentation).

Indicator 2.1.6: Inventory periods

The economic operator shall undertake inventories of the input/output balance of the Bonsucro EU-RED certified product at fixed regular intervals, for each operation site, with the
intervals not exceeding three months.
Fixed inventory periods shall be continuous in time, i.e. gaps between inventory periods shall not occur. During any periods without movement of Bonsucro EU-RED certified material mass
balances shall be kept.
The inventory periods for the certification period shall be clearly documented at the beginning of the certification term by the economic operator and shall be verified during the audit. For
each inventory period a mass balance calculation including sustainability data transfer to the next period (carry over) must be documented and provided during the audit.
The inventory shall be undertaken at individual site level.

Guidance

An economic operator may choose an inventory period less than three months.

Example: During the month of January, the economic operator buys 50 m3 of Bonsucro EU-RED certified ethanol and 40 m3 of Bonsucro certified ethanol (ChoC standard) and 10 m3
of non Bonsucro certified ethanol. In February, the economic operator sells 70 m3 of Bonsucro EU-RED certified ethanol. At the end of the month of February, the balance of Bonsucro
EU-RED certified product is negative by 20 m3. However, in March, the economic operator buys 30 m3of Bonsucro EU-RED certified ethanol, bringing the balance at the end of the
3-month period to +10 m3 and, therefore, the economic operator is compliant with indicator 2.1.6.

Indicator 2.1.7: Balancing Bonsucro EU-RED volumes during and between inventory periods

The volume of Bonsucro certified product received shall be greater than or equal to the volume of Bonsucro certified product supplied to clients over a fixed inventory period of maximum
three months.
Where the balance of inputs and outputs is positive at the end of organisation’s inventory period, sustainability data for the positive balance may be carried into the next inventory period.
Bonsucro Mass Balance Chain of Custody Standard including Implementation Guidance 20

This is called carry over. Carry over is only possible from one inventory period to the next if at least the equivalent amount of physical material is in stock, as registered in the sustainability
data stated in the bookkeeping records. This means it is not possible to have more carry over into the next inventory period than the quantity that is physically in stock at the end of any
inventory period.

Guidance

The generic ChoC Standard allows to carry over more sustainability data than there is physical material in stock at the end of an inventory period. This is not allowed under EU-RED
ChoC.

Indicator 2.1.8. Expiration of Bonsucro sustainability data

Bonsucro EU-RED sustainability data entered into an economic operator’s mass balance system shall no longer be attached to outgoing consignments after one year from the date of entry
into the system. Carryover is to be adjusted downward to reflect any expiring date of the material.
If the economic operator’s Bonsucro EU-RED ChoC certificate is no longer valid, any remaining sustainability data in the economic operator’s administrative system becomes invalid.

Indicator 2.1.9. Attribution of Bonsucro EU-RED sustainability characteristics

Whenever multiple sugarcane-derived products are produced at a given step in the sugarcane supply chain (e.g. mill), Bonsucro EU-RED sustainability characteristics shall be attributed
to all materials equally with the exception of GHG emissions which shall be allocated on an energy basis.

Guidance

For details on allocation of GHG emissions refer to Annex 3 of the Bonsucro Production Standard.

All the sugarcane-derived products produced at a given step shall carry the same sustainability characteristics, in line with the mass balance of entering Bonsucro or Bonsucro EU-RED
compliant product (i.e. percentage of Bonsucro/Bonsucro EU-RED entering material + conversion factors).
Examples of multiple products include, juice and bagasse following the crushing of sugarcane, sugar and molasses following the refining of sugarcane juice and ethanol and vinasse
following the fermentation of molasses.

Indicator 2.1.10. Wastes and Residues

The economic operator must ensure that the raw material and derived intermediary products and final biofuel are clearly identified and that no Bonsucro EU-RED compliant material is
intentionally modified or discarded to be considered as a waste or residue, including through deliberate modification of the production process.
Bonsucro Mass Balance Chain of Custody Standard including Implementation Guidance 21

Guidance

• Article 3(4) in the EU Renewable Energy Directive (2009/28/EC) requires EU Member States to achieve that 10% of the energy used in transport comes from renewable sources.
For this purpose, certain feedstocks are “double counted”, i.e. their energy content is counted twice towards the objectives, compared to other feedstocks. A list of double-counted
feedstock is included in the EU Renewable Energy Directive as Annex IX, which is added as per Directive 2015/1513 Annex II.
• The exact raw material of origin shall be included in the product documentation (See Annex 1).
• In addition, consignments containing or derived from sugarcane, sugar, straw and bagasse must be accounted for separately. Consignments of ethanol based on sugar, bagasse or
straw must be accounted for separately.

Criterion 2.2 Greenhouse gas data

IIndicator 2.2.1: Options to comply with the EU-RED greenhouse gas criterion

One of the following options shall be used for the EU-RED greenhouse gas criterion:

• Use of a total default value specified in Annex V of EU-RED. Default values can only be applied where el, calculated in accordance with point 7 of part C of Annex V of EU-RED is equal
or less than zero; or
• Use of actual greenhouse gas values to calculate total greenhouse gas savings according to the EU-RED methodology; or
• Use of a combination of disaggregated default values and actual values.

For actual greenhouse gas calculations, the requirements of the Bonsucro EU-RED Greenhouse Gas Methodology included in Annex 3 of the Bonsucro Production Standard shall be
followed.

Indicator 2.2.2: Information to be included in actual greenhouse gas emissions

When using actual values, at each step of the chain of custody, GHG emission estimates shall be added to the GHG value included in the documentation to the consignment purchased
from the previous operator in the chain of custody.
Bioethanol producers shall convert the total GHG emissions into g CO2eq/MJ and calculate GHG savings as: SAVING = (EF-EB)/EF Where EB = total GHG emissions from bioethanol EF =
total GHG emissions from fossil fuel comparator (83.8 g CO2eq/MJ)

Guidance

The following GHG emissions shall be considered:

• Additional emissions from transport and/or processing have to be added to ep and or etd respectively.
Bonsucro Mass Balance Chain of Custody Standard including Implementation Guidance 22

• Energy losses occurred during processing or if relevant transportation or storage have to be taken into account using a ‘feedstock factor’.
• Whenever a processing step yields co-products, emissions need to be allocated using an ‘allocation factor’ following the rules set out in the GHG emission calculation methodology.
• At the last processing step the emission estimate needs to be converted into the unit g CO2eq/MJ of final biofuel.

For further details on actual greenhouse gas calculations, the requirements of the Bonsucro EU-RED Greenhouse Gas Methodology included in Annex 3 of the Bonsucro Production
Standard shall be followed.

Whenever actual values are calculated at each step of the chain of custody, the additional emissions from transport and/or processing need to be added to ep and/or etd, respectively.
Additionally, a ‘feedstock factor’ shall be applied to all emissions to take the energy losses occurred into account.
This applies to each processing step, but can be also relevant for other steps in the chain of custody e.g. drying of feedstock and seasoning of woody biomass. Whenever a processing
step yields co-products, emissions need to be allocated as set out in the GHG emission calculation methodology. Put more formally, the following formula should be applied to emissions
from cultivation when processing intermediate products:

At the last processing step, additionally, the emission estimate needs to be converted into the unit CO2eq/MJ of final biofuel. For this transformation, the following formula should be
applied to emissions from cultivation :

Indicator 2.2.3: GHG data transfer through the supply chain

Each consignment transacted shall contain information on GHG emissions, including accurate data on all relevant elements of the emission calculation formula. In case actual values are
not used, information on the amount of GHG emissions shall not be transmitted through the chain of custody before the last processing step. If at any point of the chain of custody emissions
have occurred and are not recorded, so that the calculation of an actual value is no longer feasible for operators downstream in the chain of custody, this must be clearly indicated in the
delivery notes.
Bonsucro Mass Balance Chain of Custody Standard including Implementation Guidance 23

Indicator 2.2.4: Averaging of GHG data

Where a combined consignment is supplied to a client, averaging GHG data is not allowed. The original GHG value of each component of the consignment can be allocated to a similar
amount of outgoing material. Alternatively, a group consignment can use the worst GHG performance.

Guidance

No averaging of GHG values from consignments grouped together is permissible. Each separate GHG value must be reported on the documents going to the client (buyer) or the highest
(worst) GHG value can be used for the entire consignment. Other sustainability data such as country of origin and feedstock type can be grouped if identical.

Example 1:
“Clean Energy” buys Bonsucro EU RED certified ethanol from two different suppliers. Each consignment, A and B, have different GHG values, 24 and 20 g C02eq/MJ, respectively.
Consignments are mixed and stored in the same tank, D. Since there is no procedure in place to account for the different GHG values, the worst GHG value of 24 gC02eq/MJ is assigned
to the mixture. “Clean Energy” then sells consignments F, G, H and I, which together sum the original volume of A+B-losses. All consignments F, G, H and I are assigned the GHG value of
D, 24 CO2eq/MJ.

Example 2:
“BioFuel” buys Bonsucro EU RED certified ethanol from two different suppliers. Each consignment, A and B, have different GHG values, 24 and 20 g C02eq/MJ, respectively. Consignments
are mixed and stored in the same tank, D. “BioFuel’s” system is prepared to keep the individual consignment GHG values after they are mixed into a group consignment. “BioFuel” knows
that it has in tank D, 100 m3 of ethanol with 20 g CO2eq/MJ and 100 m3 of ethanol with 24 gCO2/MJ. “BioFuel” then sells consignments F, G, H and I, which together sum the original
volume of A+B-losses (which in the example is considered to be 0). To different consignments F, G, H and I the original GHG values of consignments A and B are assigned, as long as the
respective sum of the volumes matches the original consignments.
Bonsucro Mass Balance Chain of Custody Standard including Implementation Guidance 24

Example 3:
“BioSugarFuel” buys Bonsucro EU RED certified ethanol from two different suppliers. Each consignment, A and B, have different GHG values, 24 and 20 g C02eq/MJ, respectively.
Consignments are mixed and stored in the same tank, D. “BioSugarFuel” system averages GHG values after volumes are mixed into a group consignment. “Wrong#” knows that it has
in tank D, 200 m3 of ethanol with 22 g CO2eq/MJ. “BioSugarFuel” then sells consignments F, G, H and I, which together sum the original volume of A+B-losses (which in the example is
considered to be 0) and have a GHG value of 22 gCO2eq/MJ.
The Wenlock +44 (0)20 3735 8515
50-52 Wharf Road info@bonsucro.com
London N1 7EU, UK bonsucro.com