Compliance with Puro’s Biomass Sourcing Criteria (BSC) is a two-step exercise. At the Production Facility Audit, the Supplier presents a demonstration plan showing how compliance will be evidenced for each biomass source and applicable criterion; this plan is reviewed and validated by the auditor. At subsequent Output Audits, the Supplier then collects and presents the evidence defined in that validated plan.
The first step — the Production Facility Audit — is therefore the more detailed and time-consuming one, but it is performed to establish a robust and repeatable compliance approach. Once this has been validated, the Output Audit process should be more streamlined and focused on execution.
At the Production Facility Audit, compliance should be demonstrated criterion by criterion. In practice, this is a matching exercise: for each applicable criterion, the Supplier should identify which evidence option is being relied on and explain how that evidence addresses the criterion.
For categories with only a few sustainability criteria, one piece of evidence may be sufficient. For more complex categories — including Category G (Forest Biomass), Category I (Non-food agricultural crop), Category J (Food agricultural crop), and Category M (Palm oil biomass and derivatives) — several pieces of evidence may be needed to cover all applicable criteria.
For Category G, an FSC or PEFC certificate may cover many of the sustainability requirements, but it should not simply be cited as a blanket demonstration of compliance. The relevant standard, scope and claim should be checked against the BSC criteria. The type of FSC evidence also matters: FSC 100%, FSC Controlled Wood, and an FSC Chain of Custody (CoC) certificate provide different levels and types of assurance; a CoC certificate alone does not demonstrate that the biomass itself carries a qualifying sustainability claim.
At the Production Facility Audit, the Supplier should therefore:
identify the applicable BSC criteria for each biomass source used;
map each criterion to the relevant evidence option — such as certification, regulation, permits, management plans, declarations or other supporting documentation — and explain how the selected evidence demonstrates compliance;
identify any gaps that require additional evidence; and
based on the above, define which evidence and traceability records will be collected and presented at Output Audits.
Where certification is used, the Supplier should be able to indicate which part of the relevant standard addresses the BSC criterion, rather than relying only on the certificate itself.
Some criteria may require separate evidence even where a recognized certification is in place. For example, FSC certification will typically not by itself demonstrate compliance with Puro’s material-use criterion, which requires evidence that the biomass is not suitable for long-lived wood products. This may need to be demonstrated through biomass specifications, supplier documentation, purchase or delivery records, intake records, or processing records. Other certification schemes with broader biomass-sustainability requirements, such as higher-assurance SBP certification, may address this type of criterion more directly, depending on the applicable scope and claim.
At the second step — the Output Audits — the Supplier should provide the evidence and traceability records defined in the validated demonstration plan, covering the biomass actually used during the reporting period. The purpose is not to redesign the compliance approach at each audit, but to apply the previously validated approach consistently and demonstrate that the required evidence has been collected. Naturally, if biomass sourcing changes between audits — for example through a new source, feedstock type, certification status, or evidence pathway — the relevant information can be updated and re-validated efficiently as part of the Output Audit.
Keywords: biomass; sustainability; certificate; criteria; category
Puro Library: Biomass Sourcing Criteria
