This is to inform you that the Government have decided to end the suspension of the requirement to use EN Plus A1 pellets – when the 12-month suspension period lapses. This means that from 23 November 2023, all wood pellets used to claim NDRHI payments must adhere to the requirement to use EN Plus A1 pellets in accordance with the regulations.
When you receive an email from the Biomass Suppliers List (BSL) stating that you have been selected for an audit you may take it in your stride but for many people this email hits a stress button and you wonder why you have been selected and whether you have done something wrong! So, the first thing to understand is we have increased the percentage that is audited on an annual basis so you are now more likely to get one of these emails so there is no victimisation, we are selecting large batches each month to receive an audit. There is nothing to panic about, take a deep breath, keep calm and read the email carefully.
There are four main types of audit:
- A telephone audit where an auditor will call you and ask you to talk through what you do.
- A remote site audit where you will take the auditor for a walk around your production site using a phone app, for example ‘What’s App’ or ‘Teams’
- A site audit, where an auditor will visit your depot.
- E-audits where you are required to complete and return an online form. This form is very clever and should adapt to your answers, hopefully asking you only the questions that are relevant to you. If selected you will receive an email with instructions.
In all cases you will be asked in advance to gather together some information and send or upload to the e-audit form. What this is, depends on whether you are a self-supplier, a producer/trader, or a trader. Read through what is needed carefully and if you have any questions respond to the email with them and someone will get back to you with further clarification.
Following the audit, you may be sent an email to say that everything was fine, but in some cases, you may have some minor or even major non-conformances that need to be corrected. Minor non-conformances are often easily rectified, for example, you may have forgotten to send across a document or if you are a supplier, you may not be including everything that is required on an invoice. With respect to non-conformances there are strict deadlines which you must meet. If these are not met, your (suspended pending removal) fuels will be removed and if you still want a BSL number for that fuel you will need to make, and pay for, a new application for each fuel.
Types of Non-conformance
Immediate non-conformances mean that your application will be removed from BSL within 1 working day. This might be, for example, if you don’t hold any certification for fuel quality (e.g. Woodsure if you have virgin raw materials). Or for example that no evidence that the timber has been legally purchased e.g. lack of invoices or a notification of illegal felling/warning from the appropriate authority.
Major non-conformances mean that the application you currently have with the BSL doesn’t match what you have presented to the BSL team (specifically with regards to the sustainability or fuel quality criteria) and will lead to your fuel status being changed to “Suspended pending removal” of a fuel and you must act promptly to provide further evidence/clarification, or you may even need to make a new application. If you have any major non-conformances your fuel would be immediately suspended pending removal and you have 5 working days to complete any actions. If they were not completed by then your fuel is removed and you need to make a new application.
If you have minor non-conformances you have 20 working days to complete the actions, if they are not resolved within that time frame your fuel status will change to “suspended pending removal” and you have 5 working days to resolve the action. Again, if you do not meet this deadline your fuel will be removed and a new application would be required.
In the rest of this article, I will go through some of these minor and major non-conformances so that you can check your fuels and make sure everything is correct. If you find something needs updating, contact the BSL to seek advice and then make any changes if required.
What do we ask on an audit?
At the start of the audit, we go through all the details you have provided, including your correspondence and depot addresses, and contact details. If you have moved your production depot and have not made a new application this could be your first major non-compliance. Having a different depot will result in a change in the greenhouse gas emissions of the fuel so it’s critical that new applications are made if you move depot.
We then ask you to talk through everything you do, from sourcing your raw materials, through production to storage and use or delivery depending on what type of supplier you are.
Have your raw materials changed? If they are completely different than on your original application, you may be asked to make a new one. A common error is to select ‘Short Rotation Coppice’ (SRC) when you are actually using raw material derived from traditional coppice. SRC is coppice that is grown as an energy crop which is usually willow densely planted in fields and would be cut every 2-5 years using equipment like a forage harvester. Traditional coppice is cut on a longer cycle can be a range of different species and has a much bigger diameter. If you are using raw materials from traditional coppice and you were a self-supplier this would be classed as ‘virgin’ raw material. If you were a producer trader this would be hardwood roundwood.
If the distance that your raw materials travels to get to your depot changes by more than 10% a new application will be required. So, for example if you used to get your raw materials from 1 mile (which was included on the application) away and now its 50 miles, this affects your greenhouse gas emissions, resulting in a major non-conformance and a new application would be required.
The main area of error with raw materials is with the ‘Land Criteria’. Producers, Traders and Producer-Traders of virgin or virgin/waste blend must demonstrate their compliance with the Land Criteria rules. (Self-Suppliers have different land criteria and waste fuels are exempt from this, see the guidance which can be found using the following links:
As a Producers, Traders, and Producer-Traders when you applied you will have selected one of three types of Land Criteria. Category A is when you can demonstrate that your raw materials and fuel is FSC, PEFC or SBP. Further guidance can be found here https://www.biomass-suppliers-list.service.gov.uk/about/sustainability-criteria/ The main non-compliance associated with this is if you were certified but then at a later date have decided to leave the certification scheme. If you haven’t informed the BSL of this change this may be a minor compliance and you will be asked to change your Land Criteria type to a Category B.
Category B is split into two types, Category B full evidence is when you have a UKFS approved forestry plan in place for all your raw materials (usually appropriate only for those sourcing raw materials from a handful of woodlands), and Category B – Regional Risk Based Assessment (RBRA). Full evidence non-conformances may arise if the forest plan is no longer valid, or if this has been selected by mistake. RBRAs are one of the main areas for non-conformance issues include:
- Incorrect depots listed in section 3.
- Section 5 not being completed at all when it should be (If you source more than 750t of virgin timber annually this needs to be completed)
- Section 5 not matching the information included on the rest of the application.
- The types of evidence being collected are not included in the evidence boxes in section 5.
- Evidence is not being collected (e.g., felling licences, forest plan or FSC information)
- Evidence is not being checked for validity.
- Invoices are sent when asked but the information may be on the weight tickets, if so, these should be sent as well.
Sometimes evidence can be difficult to collect especially if you are obtaining most of your raw materials from smaller woodlands. If you are worried contact BSL and ask for more guidance or check the documents and guidance section on the BSL website (https://www.biomass-suppliers-list.service.gov.uk/documents-and-guidance/)
The key area for errors with the fuel is record keeping. Minor non-conformances often arise from:
- Not keeping any records – for self-suppliers and producers that force dry fuel – records of how much fuel is used in the boiler and the moisture content of the fuel.
- Not checking the moisture content of the fuel using an appropriate method (e.g., using a pin meter to check the moisture content of woodchip!)
- Not having a copy of the Emissions Certificate for the boiler
- Not having Woodsure or ENplus certification (this can lead to a major non-conformance)
If you are selling fuel
- Incorrect or insufficient information on invoices to customers
- The unit of sale (tonnes/m3/kWh) is not included.
- The ISO product specification is not included on invoices.
Invoices to your customers should include:
- Your business address
- Your customers address
- Dates sold and delivered
- The correct BSL number
- The moisture content
- The fuel specification
- Amount sold (including the unit of sale)
- If your fuel is a waste fuel the correct waste code
Major non-conformances can arise if the distance that you deliver the fuel to your customers changes dramatically. For example, if you only had one customer to start with that was less than 30 miles away and then as your business grew you now deliver nationally. However, it may not be if this was a one-off delivery, so keeping track of your weighted average distance to customers is definitely a good thing to keep on top of!
The key take home message is to keep your records up to date, and if make any changes to the type of raw materials, where you get it from, where you produce your fuel and where you deliver to get in touch with the BSL helpdesk to see if you need to make a new application. This way you can be sure of receiving the email thanking you for your time and stating you have no actions following your audit!