Feedstock Traceability & Compliance for Low Carbon Fuels: Key Requirements, Roadblocks and Solutions

Feedstock supply chain compliance is a critical driver of profitability and operational success for low carbon fuel producers. As regulatory requirements continue to expand across federal, state, and international programs, companies must ensure their supply chains meet stringent sustainability and traceability standards without creating unnecessary administrative burden. Proper development of feedstock supply chain traceability programs means the difference between a simple, profitable system and one that is cumbersome and costly. Leading frameworks such as the US Environmental Protection Agency Renewable Fuel Standard ( EPA RFS), the California Air Resources Board Low Carbon Fuel Standard (CARB LCFS), Environment and Climate Change Canada Clean Fuel Regulations (ECCC CFR), and International Sustainability and Carbon Certification for the European Union (ISCC EU) require robust oversight of feedstock sourcing. To remain competitive and minimize risk, fuel producers must implement streamlined, end-to-end compliance programs that are efficient, scalable, and aligned with evolving regulatory expectations.

Under the EPA RFS, low carbon fuel producers must maintain traceability information to each point of origin (POO), including amount of feedstock from each origin address and chain of custody and land eligibility information, depending on the type of feedstock. The CARB LCFS requires each entity in the feedstock supply chain to sign an attestation of compliance and accuracy on company letterhead verifying that feedstocks meet all sustainability criteria. Likewise, ECCC CFR mandates that all relevant parties in the supply chain complete signed compliance declarations and maintain verifiable mass balance systems demonstrating that the volume of eligible feedstock sold does not exceed the volume received and held in inventory. The ISCC EU framework requires implementation of mass balance systems, traceability of sustainable materials, and compliance with land-use, greenhouse gas (GHG) reductions, and chain-of-custody requirements under the Renewable Energy Directive (RED III).

These requirements pose challenges both for feedstock suppliers and low carbon fuel producers. Given the competitive importance of their upstream networks, feedstock suppliers treat their sourcing list as highly confidential and are often reticent to to disclose this information to fuel producers. This creates a need for confidential third-party recordkeeping and independent verification to ensure that the feedstock purchased by low carbon fuels producers is compliant with the subject program in order to minimize the fuel producer’s risk and maximize credit value.

Additionally, suppliers sometimes lack formal systems to efficiently collect, organize, retain and share required compliance data. Traceability is complicated by the decentralized nature of feedstock collection, where small volumes are aggregated from numerous locations using rudimentary measurement and tracking technology. Even when suppliers capture and provide the necessary information, it can be cumbersome for fuel producers to manage documentation, verify accuracy, and maintain consistent records across transactions. As a result, coordinating with suppliers, providing guidance, and tracking compliance at the trade level can become a complicated and time-intensive process.

TRICORD provides solutions to challenges of feedstock supply chain transparency across multiple low carbon fuel regulations. While there are recordkeeping platforms, such as Veriflux and Aegex, that collect and store supply chain data, these systems do not independently verify the completeness or accuracy of the information provided and do not review the uploaded documents against regulatory requirements. To address these gaps, TRICORD works directly both with low carbon fuels producers and feedstock providers to offer personalized, independent training and auditing services to evaluate and strengthen feedstock supply chain compliance, thereby minimizing compliance risk while maximizing efficiency for all parties. By acting as a neutral third-party operating under non-disclosure agreements (NDAs), TRICORD helps protect sensitive supplier relationships while ensuring necessary data is verified and meets regulatory requirements. Our team brings extensive experience supporting a wide range of suppliers, from small, single-truck UCO collectors to large, multinational organizations with advanced compliance systems. We can provide tailored training, guidance, and support at each stage. The result is reduced risk and stronger financial performance across the supply chain.

If you are looking for support with feedstock compliance, or just want to better understand the traceability rules under global low carbon fuels programs, please reach out to our low carbon fuels team leader Hannah Losey, P.E. at Hannah.Losey@tricordconsulting.com.