HVO, FAME and UCO: inspection and sustainability papers

HVO (hydrotreated vegetable oil) and FAME (fatty acid methyl ester) are two common diesel substitutes made from biomass: renewable diesel and biodiesel. UCO (used cooking oil) is one of the feedstocks for both. A cargo of any of the three travels with two sets of papers: inspection documents that fix quantity and quality, and a sustainability declaration that carries origin and greenhouse gas data, so the fuel can count towards an EU target.

Operium is not ISCC-certified and is not a certification body; the official sources are listed below.

HVO, FAME and UCO: what each product is

In Annex III of the Renewable Energy Directive (RED), FAME is a methyl ester produced from oil of biomass origin, and HVO is oil of biomass origin thermochemically treated with hydrogen to replace diesel. UCO is a raw material: ISCC defines it as vegetable or animal oils and fats used for cooking or frying food, usually in restaurants and canteens.

	FAME	HVO	UCO
Role	Biodiesel, blended into diesel	Renewable diesel, blended or used neat	Feedstock for FAME and HVO
Standard, by name	EN 14214	EN 15940	Contract specification
Energy content, RED Annex III	37 MJ/kg, 33 MJ/l	44 MJ/kg, 34 MJ/l	Not listed

The Fuel Quality Directive (98/70/EC) requires FAME in diesel to comply with EN 14214. RED III raised the maximum FAME content of diesel from 7% to 10% by volume, while suppliers must keep a B7 grade on the market. HVO can be sold as EN 15940 diesel, which the Dutch Emissions Authority (NEa) counts as a standard fuel and which can be 100% HVO.

UCO sits in Part B of Annex IX of the RED, with category 1 and 2 animal fats. Fuels from Part B feedstock count towards the transport target only up to 1.7% of the energy supplied to transport, unless the Commission approves a higher national limit. What RED III changed around these limits is covered in RED III for biofuels.

The inspection papers for an HVO, FAME or UCO cargo

• Quantity. Ship's tank measurements go into an ullage report (the free space above the cargo); shore tanks are measured by sounding (the height of the liquid). Either way the figures are converted with the calibration tables and corrected to 15 °C. See ullage reports and sounding tables and the volume correction factor at 15 °C.
• Samples. Drawn, sealed and labelled, and recorded on a sampling receipt. The contract decides the method and who keeps the retained samples; see sampling rules in the agricultural trade.
• Quality. A laboratory analysis against the agreed specification: EN 14214 for FAME, EN 15940 for HVO, the contract parameters for UCO. The report can take different forms; see certificate of analysis versus certificate of quality.

For UCO the quality terms come from the contract. The Dutch NOFOTA Trading Rules (edition of 1 January 2026), for example, specify UCO on free fatty acids, moisture, impurities and unsaponifiables (MIU), sulphur, iodine value and polyethylene; free fatty acid and iodine value explains two of them.

The two sets of papers meet in the quantity. An ISCC EU sustainability declaration states the delivered sustainable quantity in metric tonnes or cubic metres at 15 °C, the same units the surveyor certifies.

The sustainability declaration, or proof of sustainability

Implementing Regulation (EU) 2022/996 defines a proof of sustainability (PoS) as a declaration by an economic operator, made on the basis of a certificate issued within a voluntary scheme, that a specific quantity of feedstock or fuel meets the RED sustainability and greenhouse gas criteria. ISCC calls the document a Sustainability Declaration and notes that the trade usually says PoS.

Annex I of that Regulation sets the minimum data passed down the chain, among them the scheme and PoS number, compliance with the sustainability criteria, greenhouse gas data, the raw material and its country of origin, plus supplier, buyer, loading and delivery point, date and volume.

Three rules decide what that paper is worth.

1. The supplier's certificate must be valid on the date of physical dispatch. ISCC makes the recipient check this in its public certificate database, which also shows suspended, expired and withdrawn certificates.
2. The declaration comes out of a mass balance kept per site. How that works, and where ISCC EU and ISCC PLUS differ, is set out in ISCC EU and ISCC PLUS.
3. A PoS proves sustainability, not delivery. The NEa states that a proof of sustainability is not a valid way to show that biofuel was present in a delivery. For deliveries registered in the land sector, the Dutch rules require sampling and analysis.

Why UCO origin is checked so closely

The first reason is the incentive: under the share-based transport target, RED III counts biofuels from Annex IX feedstock twice. ISCC classes operators that handle Annex IX material eligible for such extra incentives as high risk.

The second reason is the laboratory. In September 2026 an ISCC working group reported that a single marker molecule for authentic UCO is unlikely to exist. Its inter-laboratory study (18 samples from five regions, nine laboratories, five parameters including FFA, anisidine and peroxide value) gave comparable results between laboratories, but UCO proved too variable for universal standard values. The resulting screening tool is not part of certification.

The rules focus on the paper trail and the site:

• No mixing to create waste. Adding UCO to unused vegetable oil to turn it into waste is prohibited. RED Article 30(3) requires audits to verify that material was not intentionally modified or discarded to become a waste or residue.
• Back to the restaurant. Under Article 13 of Regulation 2022/996 a collecting point lists its points of origin with self-declarations, and the auditor verifies at least the square root of that number. Points of origin supplying five tonnes or more a month of Annex IX waste get an on-site audit.
• Early surveillance and samples. A surveillance audit follows within six months of first certification, and an auditor with reasonable doubt about the declared waste may have samples analysed by an independent laboratory.

In July 2025 the European Commission closed its examination of alleged fraud in biodiesel imports from China: it found systemic weaknesses in certification audits, could not confirm fraud, and announced a revision of Regulation 2022/996. In September 2026 the NEa announced sampling visits to Dutch storage sites for biodiesel feedstock, focused on UCO, food waste and POME oil.

What this means for the HVO or FAME surveyor

The surveyor does not certify sustainability, but the work ends up in the file. ISCC describes inventory, measured or metered, as the basis for the mass balance and for checking whether sustainable quantities are plausible. The tank figure and the sealed sample become evidence in someone else's audit.

FOSS

FOSS is software for inspection companies and port operations, with a sector specialist at the table. Measurements are entered once and feed nine report types, samples are tracked, the client portal shows live status and the system works offline on board. To see how your own reporting flow would fit, get in touch.