Bioledger Ltd
Software as a service company providing applications to support companies regulated by the Renewable Energy Directive.
ID: 288624549125-94
Lobbying Activity
Response to COMMISSION DELEGATED REGULATION on extending the scope of traceability of the Union database
7 Nov 2024
Bioledger, an EU UDB Service Provider and Access Point, provides software enabling biofuel and feedstock companies across all supply chains and certification schemes to meet EU RED and UDB reporting requirements. With our attached feedback considered, Bioledger supports the efforts of the Draft Delegated Regulation to address the barriers that have prevented effective implementation in May 23, Nov 23, Jan 24, and that seemingly still threaten Nov 24 despite 4 years of stakeholder consultation, legal definition and training. While the EC UDB Team makes progress on technical and training requests, we believe clear, binding timelines are now essential to ensure coordinated implementation across all stakeholders. The DR must include a mandatory binding timeline for enforcement since this is the only issue that prevents coordinated adoption. As the European Energy Commissioner emphasized at the 15th Oct Energy Council, the UDB is the only immediately effective tool that can provide EU regulators with near real-time transparency and (with Voluntary Schemes, CBs and MS) the legal authority to block fraudulent sustainability claims within the global EU RED supply chain. Bioledger supports full UDB implementation as mandated in EU RED, IR 2022/996 and the EC approved Voluntary Schemes at the earliest feasible date to achieve the systemic transformation that European regulators and industry associations have long advocated for, addressing the severe commercial, environmental, and human impacts of fraud and unfair competition. We do not support strict enforcement of UDB compliance if stakeholders can identify objective, technical barriers to compliance. We recommend a binding legal implementation deadline be added to the DR, but encourage the Commission to work with Voluntary Schemes to downgrade UDB non-compliance identified by auditors to minor non-conformities during a transitional period. The EC UDB Team has spent two years responding to user feedback and resolving technical barriers to adoption including bulk and automated options for reporting. Bioledger has invested almost 2 million euros in developing integrated systems to make UDB reporting automatic and useful for companies and we will continue to support companies and voluntary schemes to resolve outstanding issues over the implementation period. We remain committed to support companies, auditors and voluntary schemes in implementing the UDB in their businesses according to the guidance published by the EC UDB Team. Our detailed feedback on the Draft Regulation is attached.
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