Semi Refined Oil under ISCC EU: A Small Wording Update with Practical Consequences

In certified vegetable oil and biofuel feedstock supply chains, the way a product is named on an ISCC certificate is not an administrative formality. It determines how the material is classified in a mass balance system, how it flows through a chain of custody, and whether downstream buyers can accept it under their own certification requirements.

In April 2026, ISCC EU published an update introducing ‘Semi refined oil’ as a new material entry. The update is concise and technical, but its commercial implications extend to any operator handling vegetable oils — including rapeseed oil, used cooking oil, and processed streams such as free fatty acids — that have undergone partial processing between the oil mill and the refinery.

What the ISCC EU Update Says

The ISCC EU update establishes ‘Semi refined oil’ as a named material entry in Table 2: Intermediate and Final Products of the ISCC EU material list.

The update defines the new material as follows: crude oil that undergoes processing or partial refining at an oil mill — including processes such as degumming or neutralisation — but which has not reached the specification of fully refined oil, should receive the material name ‘Semi refined oil’.

This is a classification clarification, not a new product category in a commercial sense. The physical material — partially processed vegetable oil — has existed and been traded for many years. What ISCC EU has done is provide an explicit named entry that distinguishes it from both crude oil and refined oil.

The Three-Step Classification

The update formalises a three-step material classification for vegetable oils processed through a refining sequence:

• Crude oil: the oil as extracted at the oil mill, without any further processing. Examples include crude rapeseed oil before any refining step.
• Semi refined oil: crude oil that has undergone partial refining — for example, degumming (removal of phospholipids) or neutralisation (removal of free fatty acids) — but which does not yet meet the specification for refined oil.
• Refined oil: oil that has completed the full refining sequence — degumming, neutralisation, bleaching, and deodorisation — and meets the commercial specification for refined vegetable oil.

Why the Classification Matters Commercially

In ISCC-certified supply chains, the material name on a Proof of Sustainability (PoS) document is the primary basis on which downstream operators identify and record the incoming material in their own mass balance systems.

If a cargo of partially refined oil is declared as ‘crude oil’, the downstream processor receives a PoS that does not accurately describe the material’s processing history. This creates several practical problems:

• Mass balance discrepancy: the downstream operator’s mass balance may not correctly account for the refining yield loss already incurred at the previous stage.
• Certificate scope mismatch: if the operator performing partial refining was not certified under the ‘Refinery’ scope, the chain of custody has a gap.
• Buyer acceptance risk: a buyer specifying ‘crude rapeseed oil’ or ‘refined rapeseed oil’ will have a documentation mismatch if they receive a PoS for a different material category.
• Audit exposure: ISCC auditors reviewing documentation flows will check that material names are consistent across the chain.

Operator Certification Requirements

ISCC EU specifies that the economic operator performing partial refining must hold certification under the ‘Refinery’ scope. An oil mill certified only as a ‘Point of Origin’ for crude oil production may need to extend its ISCC certification scope if it is also performing partial refining steps.

Additionally, if the partial refining process generates waste or residue materials — such as gums from degumming or soapstock from neutralisation — and if those streams are supplied into certified biofuel feedstock supply chains (for example as free fatty acids or acid oil), the operator must also hold individual certification as a Point of Origin for those waste or residue streams.

Practical Compliance Steps

For operators and traders active in vegetable oil supply chains, the update requires a review of current practices:

• Material identification: for each product handled, determine whether it is crude oil, semi refined oil, or refined oil. Any partially processed oil — described commercially as ‘degummed’ or ‘neutralised’ — should now be classified as semi refined oil in ISCC documentation.
• Certificate scope review: if your organisation performs partial refining and is currently certified only as a Point of Origin or Trader, assess whether a Refinery scope extension is required.
• PoS and contract alignment: ensure that material names on Proofs of Sustainability, purchase contracts, sales contracts, and invoice descriptions are consistent.
• Mass balance update: update mass balance records to use the semi refined oil material name, with the appropriate input-output conversion factor for the partial refining step.
• Waste stream certification: verify that Point of Origin certification is in place for waste or residue streams generated during partial refining.

An Important Compliance Caveat

ISCC states explicitly that its material list is not a ‘positive list’ for sustainability classification. The appearance of a material in the ISCC material list does not, by itself, classify it as a waste or residue, double-counting eligible, or advanced feedstock under RED III. Eligibility depends on the applicable national legislation of the member state where the biofuel is placed on the market.

For the regulatory framework governing biofuel feedstock classification in Germany and the broader EU, see our post on Germany’s renewable fuel targets and what they mean for biofuels feedstock supply in Europe.

Technical Reference: Key Quality Parameters

The practical distinction between crude oil, semi refined oil, and refined oil maps onto measurable quality parameters:

• Free fatty acid content (FFA %): neutralisation reduces FFA substantially; semi refined oil will show lower FFA than crude but may differ from fully refined on other parameters.
• Phosphorus content (ppm): degumming removes the majority of phospholipids; a degummed but not further refined oil will show lower phosphorus than crude.
• Moisture and impurities: typically reduced by partial refining.
• Soap content: present in neutralised oil before water washing; relevant for processor acceptance.
• Colour and odour: addressed in bleaching and deodorisation — not by partial refining alone.

How Prime Elements Can Help

Prime Elements supplies vegetable oil feedstocks — including rapeseed oil, used cooking oil (UCO), animal fat Category 2 and Category 3, and free fatty acids (FFA) — with full RED III-compliant documentation and ISCC or equivalent certification. Prime Elements holds German registration under EU Regulation (EC) No. 1069/2009 for trading rendered fats and UCO; see our registration announcement for details. Our team maintains current knowledge of ISCC EU updates and their operational implications for physical feedstock supply chains. Contact our team to discuss feedstock sourcing and supply chain compliance.