Author: Alun Williams

The BSL Administrator is aware that some people have had issues since the re-introduction of the fuel quality criteria on 23rd November 2023. If you have been affected, please see below:

• Have you purchased the fuel since the 22nd of November? If yes,
  • check the BSL number on the invoice
  • go back to your supplier and query whether the BSL number is correct.
• If you haven’t purchased the fuel since 22nd of November:
  • check with your supplier that the BSL number is correct; and 
  • advise Ofgem that you purchased the fuel before the suspension was lifted.
• If you are still experiencing issues after this:
  • forward on your communication with the supplier and OFGEM RHI team and to the BSL helpdesk with a brief explanation of your situation.”

The BSL Helpdesk can be contacted in the following ways or by completing the contact enquiry form here:

Email: helpdesk@bsladmin.org
Tel: (+44) 01684 215253 

The Helpdesk is open Monday to Thursday, 9:30am to 5pm and to 4:30pm on Friday. 

The Biomass Suppliers List administration team will be on hand between Christmas and new year, with the Helpdesk being available between 9am and 11am from the 27th to 29th December. The Helpdesk will close at midday on Friday 22nd December.

Our usual opening hours of 8:30am to 5pm will commence from the 2nd January 2024. 

Please contact the team on 01684 215253 or send us a message via the website.

From the BSL team, we wish you a very merry Christmas and happy new year.

Following a recent successful call for nominations for the Biomass Suppliers List Advisory Panel, we are now in a position to open voting for categories where a number of nominations were received. Where there are multiple nominees for the same category, the panel member will be elected by the BSL registrants. The panel members are representing their BSL scheme participants or stakeholders and will be expected to raise matters to the Advisory Panel and report back directly to their relevant members on any outcomes or decisions via the BSL Administrator.

Advisory Panel purpose

The Panel serves a number of purposes, including:

• Provides strategic advice to the Department for Energy, Security & Net Zero (DESNZ) on the supply of biomass wood fuel through meetings of this Panel;
• Ensures that all participants within the biomass sector have open and fair access to the BSL;
• Ensures that fees applied to Suppliers on the BSL are appropriate and kept within reasonable and affordable limits;
• Ensures that scheme administration and any improvements raised reflect user needs;
• Escalates BSL Advisory Panel concerns to DESNZ; and
• Develops terms of reference of the annual audit of the BSL Administrator

The Panel shall consist of up to 18 Members from the following categories:

• Members representing BSL suppliers (self-suppliers, producers, producer-traders, traders) 
• Members representing fuel types (pellets, chip, logs, waste wood)
• Members representing raw materials (forestry, waste wood, arboricultural arisings, sawmill residues)
• Members representing industry bodies (forestry, waste wood fuel, wood heating)
• Advisory Panel Non Voting Members (fuel quality certification scheme, government forestry (England), government forestry (Scotland), government forestry (Wales)

Some members may represent multiple categories, depending on their experience and expertise.
Closing date for voting is 2pm on the 6th December 2023.

You will be required to enter your details so the BSL Administrators can confirm validity for voting. You can only vote in categories relating to your own membership with BSL.

The full ‘Terms of Reference’ for the BSL Advisory Panel, are available to view on the BSL website.

How to vote

All members of the Biomass Suppliers List will have received an email with voting details. Please check your inbox for details. Contact the team here if you haven’t received the email.

As BSL Administrators we would like to open nominations for a new Advisory Panel. To nominate yourself please follow the link below. The nomination process will close on 12th November. Where we receive multiple nominees for the same category, the BSL registrants will be asked to vote for their preferred candidate.

Advisory Panel purpose

The Panel serves a number of purposes, including:

• Provides strategic advice to the Department for Energy, Security & Net Zero (DESNZ) on the supply of biomass wood fuel through meetings of this Panel; 
• Ensures that all participants within the biomass sector have open and fair access to the BSL; 
• Ensures that fees applied to Suppliers on the BSL are appropriate and kept within reasonable and affordable limits;
• Ensures that scheme administration and any improvements raised reflect user needs; 
• Escalates BSL Advisory Panel concerns to DESNZ; and 
• Develops terms of reference of the annual audit of the BSL Administrator.

The Panel shall consist of up to 18 Members from the following categories:

• Members representing BSL suppliers (self-suppliers, producers, producer-traders, traders)
• Members representing fuel types (pellets, chip, logs, waste wood)
• Members representing raw materials (forestry, waste wood, arboricultural arisings, sawmill residues)
• Members representing industry bodies (forestry, waste wood fuel, wood heating)
• Advisory Panel Non Voting Members (fuel quality certification scheme, government forestry (England), government forestry (Scotland), government forestry (Wales)

Some members may represent multiple categories, depending on their experience and expertise.

Please note: closing date for nominations is Sunday 12th November 2023.

If you would like to be considered to represent industry on the Biomass Suppliers List Advisory Panel, please complete the short survey by clicking ‘Make your nomination’.

The full ‘Terms of Reference’ for the BSL Advisory Panel can be viewed here.

On the 10th August 2023 government published their Biomass Strategy. This strategy sets out the role sustainable biomass can play in reaching net zero, what government is doing to enable that objective, and where further action is needed.

The Biomass Strategy sets out steps government intends to take to strengthen biomass sustainability and the opportunities for the use of sustainable biomass across multiple sectors of the economy in support of achieving the UK’s net zero target.

It builds on the 2021 Biomass policy statement and the Powering up Britain strategy which emphasised the important role that biomass will play in Britain’s fully decarbonised power system by 2035, subject to security of supply.

The Biomass Strategy document can be downloaded from the .gov website.

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: 

1. A telephone audit where an auditor will call you and ask you to talk through what you do.  

2. 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’  

3. A site audit, where an auditor will visit your depot.  

4. 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. 

Raw materials 

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:

• Self-Suppliers
• Waste

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/) 

Fuels 

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! 

The audit process

The BSL Administrators are reminding everyone with authorised fuels of the audit process to help ensure ongoing scheme compliance. If you have any questions on the process, the BSL Helpdesk in on hand to discuss this update in more detail with you.

Audit types

The BSL audit team conduct both site and desktop (telephone) audits. If you are selected for a telephone audit, you will receive an email from us advising you that you have been selected for audit and requesting documents that we require to conduct it. Once we have received these documents we will then send you a selection of dates and times to choose a convenient time for your audit. Once the audit has been conducted you will receive an audit report with a deadline to complete your actions. If you fail to complete these actions within the deadline your BSL number may be suspended, and this may result in removal of your BSL number.

If you are selected for a site audit, the auditor will contact you directly to request any documentation required prior to the audit and to book in their visit. You will also received an audit report following the audit, and these actions must be completed by the deadline given to avoid suspension or removal from the BSL.

Pre-audit documentation

The documentation we require, depends upon your supplier type and the type of fuel you produce or trade.

Self-suppliers

We require:

For all fuels:

• A copy of the emissions certificate for your boiler (if your boiler was installed before 24^th September 2013, please provide evidence of the date of installation and evidence of the fuel type and moisture content your boiler can take)
• Your records illustrating the amount of fuel your boiler uses for the last 12 months
• Your records illustrating that you are monitoring the moisture content
• A copy of your fuel quality certification (if applicable)

If you are processing wood fuel from your own woodland:

• A copy of your felling licence/management plan/alternative evidence to prove that you have the legal right to harvest the biomass 

If using waste wood:

• Any permits/exemption certificates that you have and a description/photograph of your raw materials and fuel

If purchasing top up fuel:

• Please provide 5 copies of your top up fuel invoices (these should show the BSL number of the fuel supplied by your supplier)

Producers and producer-traders

For all fuels:

• An explanation of how you calculate your quarterly returns
• Test results for the moisture content of your raw material and your product 
• 5 invoices for your raw material
• A copy of your fuel quality certificate (if applicable)

For waste fuels:

• Copies of your exemptions/permits if you are processing or using waste wood
• A brief description of your raw material and/or photographs of your raw material

If you are selling your fuel:

• Your distance to customer and the information you used to calculate this at the time of your application
• 5 invoices to your customers (please note: customer details and pricing information are not required)

If you are using your fuel in your own boiler/s:

• A copy of your boiler emissions certificate(if your boiler was installer before 24th September 2013, please provide evidence of the date of installation and evidence of the fuel type and moisture content your boiler can take)
• Your records illustrating the amount of fuel your boiler uses for the last 12 months

Traders

• Copies of 5 sales invoices for the fuel being audited
• Copies of 5 supplier invoices for the fuel being audited (please note: customer details and pricing information are not required)
• A copy of your fuel quality certification (if applicable)
• A description of your delivery method and, if supplying bagged fuels, a photograph of the bags

• The list of your depots and any other BSL numbers you have
• The list of your BSL fuel suppliers
• If trading with overseas suppliers, please also provide shipping notes

If you are unsure about any of the documentation required, please contact the audit team. If you don’t keep some of the records required, the auditor will discuss this with you during the audit and advise ways that you can comply in future.

Contact the BSL Helpdesk

Click here to contact the BSL Helpdesk using our contact enquiry form, or call the team on (+44) 01684 215253. The Helpdesk is open Monday to Thursday, 9:30am to 5pm and to 4:30pm on Friday. 

The BSL Administrators would like to remind everyone with authorised fuels of the membership renewal process.

Membership fee is due on 1st January each year. The membership fee is a flat fee per account, not per fuel, and is calculated based on company size information provided during registration. For individuals, a membership fee of £25 + VAT will be charged.

Membership fee by company size: for individuals £25 + VAT. For small / micro companies £120 + VAT. For medium / large companies £295 + VAT. Self-Suppliers will be charged an annual membership fee each January. Producers, Producer-Traders and Traders will be charged on a quarterly basis in January, April, July and October to coincide when quarterly reporting data is submitted, and tonnage fees are paid. In the case of removal of a fuel or supplier by the BSLadministrator, no fees will be refunded.

Quarterly reporting data will be accepted from the first day of the month following the end of the reporting period (“QR Date”) and can be reported up to 30 days after QR Date. If, after this date, quarterly reports have not been submitted, the fuel(s) may be audited and/or suspended or removed from the BSL. Once the quarterly report has been submitted, payment can be made. This is by PayPal or BACS. Payment date is on or before QR Date +30 days and is not +30 days from the date you submit your quarterly report.

• In January, suppliers will need to report on woodfuel sold in the period between 1st October to 31st December. 
• In April, suppliers will need to report on woodfuel sold in the period 1st January to 31st March 
• In July, suppliers will need to report on woodfuel sold in the period 1st April to 30th June 
• In October, suppliers will need to report on woodfuel sold in the period 1st July to 30th September.

Late submissions of quarterly figures may be accepted in exceptional cases where prior permission is applied for from, and granted by, the BSL Administrator. Any person wishing to apply for such an exemption should contact the helpdesk as far in advance of the Quarterly Report date as possible, and never later than QR Date +35 days. The BSL helpdesk will take details of the length of extension being requested, the reason, and any supporting evidence. The helpdesk will confirm to the applicant in writing the outcome of their request, usually in a maximum of five working days. Dispensations will be on a strictly case-by-case basis. Since the veracity of evidence will likely be difficult to validate, all such requests will have an impact on the Supplier’s risk profile.

Get in touch with the BSL Helpdesk on 01684 215253 or email helpdesk@bsladmin.org.

Renewable Energy Association undertake independent review of fuel quality implementation

In January 2021 fuel quality legislation was laid in Schedule 4A of the RHI regulations.  

Schedule 4A was intended to come into force on 1^st April 2022 and cover the implementation of fuel quality standards for all biomass boilers participating in the Domestic and Non-Domestic RHI that are burning wood.   The fuel quality requirements were put into legislation by BEIS, enforced by Ofgem and impacted on suppliers and self suppliers alike.   Anyone claiming RHI payments needs to comply either with a BSL number or if a self reporter to Ofgem, evidence that they comply with the legislation.  

The new requirements were originally to come into force in April 2022. However, implementation was delayed until June 2022 due to it becoming clear that the industry was neither fully aware or prepared for them to come into effect.  

REA’s independent review seeks to identify what went wrong with Schedule 4A’s implementation, what went right – and to deliver recommendations for future implementation of similar regulations so that lessons can be learned from this experience. If you are interested in giving your opinion, we will be sharing a link to the REA stakeholders review in early 2023 and we will advise all BSL participants of this review.  

The REA is well placed to conduct this review as the Biomass Heat industry trade body and an independent observer to the implementation of the scheme.