In order for registrants to meet the Land Criteria, we need to be satisfied that the land on which non-wood fuels were grown was not a protected site back in 2008. For individual applicants who are self-supplying fuels such as straw from their own farm, this is reasonably easy to prove. They simply need to send us land records (e.g. Rural Payments documentation) or a relevant Google Earth image of the land where the fuel was produced. See this previous blog for more information.
However, for a trader of non-wood pellets who is perhaps intending to import thousands of tonnes of material, this sort of evidence is unrealistic if not impossible to provide. So how do large importers of non-wood pellets meet the Land Criteria?
In such circumstances, the applicant needs to produce robust evidence that the material they are importing has a low risk of being from a formerly protected site. This can take the form of a bespoke Land Criteria Declaration.
So, for instance, let’s say a trader wanted to import Sunflower Husk Pellets (SHP) from Ukraine. By providing a Land Criteria Declaration, they can tell us:
- Details of any national quality assurance scheme that farmers sign up to (e.g. similar to the UK’s Red Tractor). There are many across the world for cereals and oil crops.
- Details of the region(s) of the country where the sunflower husks were sourced
- National statistical information on the type of farmland in the region(s) and the area of sunflower cultivated by farmers
- Details of average sunflower crop yield in the region(s)
- National reports indicating any trends in land use change
In this example, let’s assume the trader can provide official information that states that the region(s) from where the SHPs were accessed:
- Has 1 million hectares of land
- 70% of this is arable land
- Sunflower makes up 20% of the cropped area (140,000 hectares)
- The yield of sunflowers is 2.2 tonnes per hectare, of which husks make up 30%.
An import of 1,000 tonnes of SHP would, therefore, require just 1% of the sunflower area and 0.2% of the total arable area. On this basis, we would be in a position to assume that there was a very low-level risk of the cultivation of SHP failing to meet the land criteria.
We will also require details of where the fuel is grown, where it is processed and the supply chain e.g. farming area – primary storage location - processing location – secondary storage location, the port in country 1, the port in country 2 etc.
An annotated Google Earth image showing how the fuel is moved e.g. by rail, road or sea will help with our understanding of the greenhouse gas sections of the application.
Another important part of the jigsaw is providing information on the processing facility. Images of the pelleting factory and a website address for this will indicate that it exists where the applicant says it does.
Something that traders should be aware of is whether the pellets they are importing have any additives e.g. binders? If so, a separate land criteria assessment will be required for that component as well.
One final thing to note: traders who provide a Land Criteria Declaration need to accept that, if audited by SFR, the burden of proof of meeting the Land Criteria lies with them. Hence, there is no substitute for sound information at the outset.