Nabisy 101 – An Introduction to EU RED Compliance in Germany

EU RED regulation requires all biofuel sales to and within EU member states to include standardized chain of custody forms, called Proof of Sustainability (PoS) documents.  Nabisy was developed by Germany’s Federal Office for Agriculture and Food (BLE) to meet this requirement and track and document sustainability characteristics of biofuels made with sustainable biomass sold into Germany.  PoS for all biofuels sales into Germany must be logged within Nabisy, whose is taken from the first few letters in each of the words for Sustainable Biomass System in German, “Nachhaltige Biomasse System”.    

From a biofuels producer standpoint, Nabisy functions as a PoS generation system and serves to pass on sustainability characteristics of biofuels as the fuel is sold.  These characteristics include feedstock country of origin, feedstock type, and relevant greenhouse gas emission elements.  It does not function as a mass balance and cannot be used as the only compliance method for any voluntary and mandatory carbon certification schemes.  Mass balances can be managed within the Union Database for Biofuels (UDB) or other bespoke tools.

If a fuel producer is also complying with EU RED III through a UDB mass balance, all relevant information on the sustainable fuels should be sent through the UDB and then either through Nabisy or other EU RED-compliance program PoS forms.  As UDB data entry is a requirement for mandatory EU RED III compliance, this can be understood as a prerequisite to sending PoS by either Nabisy or by issuing other PoS forms through other compliance programs. 

Nabisy can also be used an as optional tool for compliance with EU RED requirements for countries other than Germany.  To comply with requirements from other programs like ISCC EU, sustainable fuel should be passed along to the fuel purchaser either via Nabisy or through ISCC template PoS forms.  When using Nabisy to comply with EU RED regulation using the ISCC EU certification scheme, the Nabisy PoS will entirely replace an ISCC template PoS.

It is extremely critical that fuel producers entering PoS ensure accuracy of all information entered in Nabisy before the PoS are finalized and submitted to the purchaser for review and acceptance.  After the purchaser accepts the Nabisy PoS, the PoS requires a review by the BLE before it can be reopened if updates need to be made.

If you are a fuels producer who is interested in using Nabisy for selling into the EU or German biofuels market, our experts are here to help.  Nabisy can be both opaque and tedious but, once understood, the process of entering information into the website is not difficult.  For inquiries, please contact our low carbon fuels team lead, Hannah Losey P.E., at Hannah.Losey@tricordconsulting.com.