Group Certification according to the DM of August 7, 2024: opportunities and requirements for small operators

Group certification represents one of the most significant innovations introduced by the DM of August 7, 2024, to make the national sustainability certification system accessible to small producers. This organizational modality allows small-sized operators to access incentives for biofuels by drastically reducing costs and simplifying bureaucratic compliance, while maintaining all the traceability and sustainability requirements mandated by European legislation.

Article 14 of the decree details the different types of admissible group certification, each with specific characteristics designed to address the peculiarities of different production sectors. Understanding which organizational model is most suitable for one’s reality and how to structure it correctly is fundamental to avoid errors that could compromise the validity of the certification.

Understanding why Group Certification was introduced

The renewable energy sector in Italy is characterized by a high degree of production fragmentation, with thousands of small agricultural companies, forest owners, residue producers, and small-scale biogas plant managers. Requiring individual certification from each of these entities would have entailed prohibitive costs and unsustainable administrative complexities for most operators.

Group certification was specifically designed to overcome this hurdle, enabling multiple operators to pool resources under a single certificate managed by a coordinating entity. This model significantly reduces per-capita certification costs, distributes administrative burdens, facilitates access to the technical expertise required for traceability systems, and creates economies of scale during audits by certification bodies.

The legislative approach recognizes that supply chain sustainability does not necessarily depend on the size of the individual operator, but rather on overall compliance with criteria throughout the production chain. A small-scale farmer supplying biomass to a cooperative can contribute to sustainable biofuel production just as effectively as a large integrated company, provided that traceability and adherence to environmental and social standards are guaranteed.

The six types of Group Certification provided by the Decree

The DM of August 7, 2024, identifies six distinct types of group certification, each designed to address the organizational specificities of different production sectors. This articulation reflects the legislator’s awareness of the diversity of biofuel supply chains.

Group Certification for agricultural Biomass

The first type concerns the production of agricultural biomass and is aimed at agricultural enterprises, agricultural producers’ organizations, consortia, and agricultural cooperatives. This form of aggregation is particularly relevant for the production of energy crops destined for biofuel production or agricultural raw materials used in biogas plants.

The group can organize in two alternative ways. The first involves the establishment of an autonomous legal entity, such as an agricultural cooperative, an agricultural consortium, or a recognized producers’ organization. In this case, the entity itself assumes the role of coordinator and centralizes all certification management functions. The second way involves a structured group of producers contractually linked to an entity responsible for a subsequent phase of the chain, such as a biofuel producer or a biogas plant manager.

A fundamental aspect is that in the second organizational model, the role of coordinator cannot be held by entities operating in phases subsequent to pressing (e.g., oil extraction). This limitation ensures that coordination remains in the hands of entities directly linked to the agricultural phase, preventing contractual imbalances and ensuring effective representation of the primary producers’ interests.

The decree also introduces an important element of territorial proximity. The agricultural enterprises belonging to the same group must belong to the same NUTS2 area or to NUTS2 areas bordering the one where the coordinating entity has its operational headquarters. This geographical requirement addresses verification and control needs, making inspections by certification bodies more effective and guaranteeing some homogeneity in the group’s agricultural practices.

A distinctive feature of agricultural biomass group certification is the admission of the intermediary figure, who carries out raw material storage or collection activities up to the coordinating entity. This figure was introduced to recognize the role of merchants and collectors who act as a link between small producers dispersed throughout the territory and the entities aggregating the batches for sale to processors.

Group Certification for woody Biofuels

The second type concerns the production of woody biofuels and presents both similarities and significant differences compared to agricultural biomass certification. The group consists of economic operators involved in the production or harvesting phase of agricultural and forest woody biomass, who may take the form of agricultural and/or forest enterprises, collector organizations, consortia, or cooperatives.

As with agricultural biomass, the intermediary figure who performs storage or collection activities up to the coordinator is allowed. However, a fundamental difference concerns the identification of the coordinator: in the forest supply chain, the coordinator can also be the economic operator that uses the biofuel to produce electrical or thermal energy. This possibility reflects the reality of many biomass power plants that procure directly from small forest owners or surrounding forest utilization companies.

The decree introduces a particularly important exception for the forest supply chain: operators can join multiple group certifications, up to a maximum of three groups, where the coordinating entity is identified as the user of the biofuel to produce electrical or thermal energy. This flexibility was provided to allow small forest owners and utilization operators to diversify their commercial outlets, supplying biomass to multiple power plants or facilities in the area.

When an operator participates in multiple certification groups, they must maintain separate and distinct records and mass balances for each one. To confirm compliance with the mass balance system, operators must make available to each certification body of every group they participate in all documentation related to their company activities, including that referring to the other groups. The sale of woody biofuel accompanied by sustainability declarations must occur exclusively towards entities and commercial supply chains included in the groups the operator participates in.

This more complex structure reflects the specificity of the Italian forest sector, characterized by highly fragmented ownership, the presence of occasional utilization, and the need for commercial flexibility to ensure the economic sustainability of forest management operations.

Group Certification for small producers of waste and residues

The third type of group certification is dedicated to producers of waste less than 100 tonnes per year or residues. This organizational model is particularly relevant for aggregating numerous small producers who individually would not justify individual certification.

The group consists of the economic operators where the waste or residues originate and the first collection point thereof. The organizational structure is simpler than the other types: the group is organized as a structured group of producers contractually linked to the first collection point, which mandatorily assumes the role of coordinator.

This configuration recognizes that the first collection point is the entity that effectively manages the traceability of the batches, performs storage and treatment operations, and interfaces with subsequent processors. Centralizing the certification responsibility on this figure ensures operational effectiveness and clarity in roles.

Each operator joining the group is obliged to sell the certified products only within the group of belonging. This exclusivity ensures the correct maintenance of the mass balance and prevents the double accounting of materials that could be certified through different channels.

In the specific case of used cooking oils (UCO), all provisions of Article 13 of the decree must still be respected, which introduces further traceability and verification requirements for this particular category of waste, given its economic relevance and documented risks of fraud in the past.

Group Certification for winemaking by-products

The fourth type concerns winemaking by-products, specifically grape marc (vinacce) and lees (fecce) supplied to distilleries. This model was designed to integrate with the existing sectoral legislation regarding the distillation of alcohol of vinous origin.

The group consists of producers who supply lees and grape marc to distilleries pursuant to Regulation (EC) 1623/2000, provided that this regulation is respected in compliance with the procedures set out in the decree of September 14, 2001, of the Ministry of Agricultural, Food, and Forestry Policies.

Group certification is structured as a group of winemaking by-product producers supplying a distillery, which assumes the role of coordinator. The group must be established through written contracts stipulated between the individual producers and the coordinator.

A significant simplification concerns documentation: the documentation transmitted by the winemaking by-product producers pursuant to the decree of September 14, 2001, is considered equivalent to the declaration of sustainability to be provided to the distillery. This avoids bureaucratic duplication by leveraging the traceability system already operational in the wine sector.

The coordinator is responsible for calculating the greenhouse gas (GHG) emissions related to the transport phase of lees and grape marc from the producers to the distillery, and it is the distillery itself that issues the declaration of sustainability provided for in Article 9 of the decree.

Group Certification for olive mill by-products

The fifth type concerns by-products derived from olive mills, particularly olive pomace supplied to pomace oil extraction facilities. Also in this case, the legislator coordinated with pre-existing sectoral legislation, referencing the decree of the Ministry of Agricultural, Food, and Forestry Policies no. 8077 of November 10, 2009.

The group consists of the olive mills that supply pomace to the extraction facilities according to the procedures of the cited decree. The organizational structure involves a group of olive mills contractually linked to the pomace oil extraction facility, which assumes the role of coordinator.

Each olive mill is obliged to sell the certified products only within the group of belonging, thereby ensuring the closure of the mass balance and complete traceability of the supply chain.

Group Certification for Biogas production

The sixth and last type regulated by the decree concerns the production of biogas, also intended for the subsequent production of biomethane. This form of aggregated certification is particularly relevant given the high number of small and medium-sized anaerobic digestion plants present nationwide.

The group consists of the economic operator producing biogas and the economic operators producing and supplying raw materials to the same. The intermediary figure, who performs raw material storage or collection activities up to the biomethane production plant, is also admitted in this case.

The coordinator of the group is the biogas plant manager. A specific characteristic of this type is that the biomethane production plant may be owned by the economic entity producing the biogas or by another entity; in the latter case, the biomethane production plant cannot be part of the group.

The supply of raw materials must occur based on written contracts stipulated between the parties, and the coordinator must be able to exercise the right to require adherents to comply with the certification requirements. The agreements must include the obligation for the group adherent to retain and make available the records proving the activities carried out that are relevant for the traceability of the biomass and the calculation of greenhouse gas emissions.

The requirement of geographical proximity also applies to this type: agricultural enterprises must belong to the same NUTS2 area or to NUTS2 areas bordering the area where the coordinating entity has its operational headquarters.

Documentation by economic operators adhering to a group must be managed pursuant to the technical standard UNI TS 11567, which provides specific guidelines for the qualification of operators in the biomethane supply chain.

Common requirements for all Group Certifications

In addition to the specificities of each type, the decree establishes a series of common requirements that must be met by all group certifications, regardless of the sector.

Formalization of contractual relationships

The first fundamental requirement is that the group must be established through written contracts stipulated between its members. Informal forms of aggregation or those based solely on verbal agreements are not permitted. Written formalization ensures clarity of roles, responsibilities, and reciprocal obligations, and is essential to allow the certification body to verify the correct structuring of the group.

The contracts must specify at least the obligations related to compliance with sustainability requirements, the methods for document management, the traceability systems to be adopted, responsibilities in case of non-conformity, and the methods for leaving the group.

Central management with written Policies and procedures

The group must be equipped with central management, with internal policies and procedures drafted in writing. This requirement guarantees that the coordinator has clear operating tools to manage the activities of the group members consistently with the certification requirements.

The written policies and procedures must cover at least the management of raw material and product traceability, the methods for calculating and recording GHG emissions, the internal controls to be performed on group members, the management of non-conformities, and the communication methods with the certification body.

Role and responsibility of the coordinator

The group coordinator plays a central role and assumes significant responsibilities. They must ensure that the adhering entities conform to the provisions of the certification scheme and the rules for the group’s operation, verifying compliance also through the execution of internal controls.

The agreements must include the obligation for the group adherent to retain records for five years and make them available to the coordinator and the certification body, proving the activities carried out by the company that are relevant for the calculation of greenhouse gas emissions.

The coordinator is responsible to the certification body for compliance with the requirements of the certification scheme as well as compliance with the group’s internal provisions. In case of non-conformities detected in one or more group members, the coordinator must take action to ensure the adoption of the necessary corrective measures.

Obligation of commercial exclusivity

A recurring principle in almost all types of group certification is the obligation for members to sell the certified products only within the group of belonging. This requirement, while limiting the commercial freedom of the adherents, is essential to ensure the correct maintenance of the mass balance and prevent phenomena of double accounting.

The only explicitly provided exception concerns group certification for woody biofuels when the coordinator is not the final user, and the possibility for forest operators to join up to three groups while maintaining separate records.

How Group Certification is managed

From an operational standpoint, group certification entails some specificities in the verification methods used by the certification bodies.

The Group Certificate of conformity

In derogation of ordinary provisions, when multiple operators adhere to a group certification, the application for adherence to the system is submitted by the group of operators, through the coordinator, to obtain a Group Certificate of Conformity.

The certificate is issued to the group as a whole, but it authorizes all group components to issue Declarations of Sustainability for the batches sold, accompanying them as required by the decree. This means that each member retains the responsibility for correctly issuing their own documentation, while operating under the group’s certification umbrella.

Verification methods on Groups

Verifications by certification bodies on certified groups follow a methodology based on statistical sampling. The body performs checks on the coordinator and on a sample constituted by a number of members equal to the square root of the total number of agricultural or forest enterprises participating in the group.

This methodology, also provided for by the Technical Regulation RT-31 of Accredia, allows for a significant reduction in verification costs while maintaining an adequate level of control. For example, a group composed of 100 agricultural companies will require the verification of 10 sampled companies, while a group of 25 members will require the verification of 5 members.

Sampling must be carried out according to representativeness and risk analysis criteria, favoring members who manage the largest volumes, those with greater operational complexity, or those for whom there are elements suggesting possible critical issues.

The Group Certificate of conformity

The management of non-conformities within certified groups presents some peculiarities compared to individual certifications. The decree establishes that if a critical or relevant non-conformity is identified in the initial sample of the group, another sample of the same size must also be audited.

A critical or relevant non-conformity found in more than 50% of the group members in the sample leads, depending on the case, to the suspension or revocation of the certification for the entire group. This provision reflects the principle that if the problems are so widespread as to affect the majority of the verified sample, it is reasonable to assume that the problem is systemic and concerns the overall management of the group.

Conversely, non-conformities found only on individual group members do not entail consequences for the entire group but are managed with reference to the individual non-compliant operators. The coordinator must take action to ensure that the affected members adopt the necessary corrective measures within the established deadlines.

What are the economic advantages of Group Certification?

Group certification offers numerous advantages, both economic and organizational, making it particularly attractive for small operators.

Reduction of Certification costs

The most evident economic advantage concerns the drastic reduction of per-capita certification costs. The fixed costs of certification, such as preparing the system documentation, managing contracts with the certification body, and general administrative costs, are distributed among all group members.

Verification costs are also significantly reduced thanks to the sampling system. Instead of having to bear the cost of a complete individual verification, each group member contributes proportionally to the costs of the audits on the coordinator and the extracted sample. Considering that on average only about 10-30% of members are actually subjected to field verification in each surveillance cycle, the savings can be very significant.

Simplification of administrative Compliance

Another significant advantage concerns the simplification of administrative burdens. Group members don’t have to manage relationships with the certification body directly, as these are centralized with the coordinator. This considerably lightens the administrative load for small operators, who can concentrate on production activity, entrusting the certification management to a more structured entity.

The coordinator is responsible for keeping the document management system updated, interfacing with the certification body for audits, managing any non-conformities, and ensuring that all members have the necessary documentation to correctly issue the declarations of sustainability.

Access to specialized technical expertise

Group certification facilitates access to specialized technical expertise that would be difficult for single small operators to access. The coordinator can use qualified consultants to correctly structure the management system, calculate GHG emissions, prepare documentation for audits, and train group members on the requirements to be met.

These skills, whose cost would be prohibitive if they had to be acquired by every single operator, become economically sustainable when shared within the group.

Greater contractual power

Aggregating into a certified group also increases contractual power vis-à-vis downstream supply chain entities. A group that guarantees significant volumes of certified raw material can negotiate more favorable economic conditions compared to small operators who supply limited quantities.

This aspect is particularly relevant in sectors characterized by a strong asymmetry between fragmented producers and concentrated buyers, as often happens in agro-energy supply chains.

Critical elements in structuring a Group Certification

Despite the numerous advantages, group certification also presents some critical issues that must be carefully considered before embarking on this path.

1. Choosing the appropriate coordinator

The choice of the coordinator is perhaps the most critical element for the success of a group certification. The coordinator must possess adequate technical skills, organizational capacity, reliability, and must enjoy the trust of the group members.

An inadequate coordinator can compromise the entire certification, exposing all group members to risks of non-conformity, suspensions, or revocations. It is essential that the coordinator has dedicated resources for certification management and is able to effectively perform internal controls on members.

2.  Management of contractual Obligations

The formalization of relationships through written contracts requires attention in defining the contractual clauses. The contracts must adequately balance rights and obligations, provide clear mechanisms for dispute resolution, regulate the methods for entering and exiting the group, and precisely define the economic responsibilities of each member.

Poorly structured contracts can lead to disputes that undermine the stability of the group and compromise certification.

3. Maintaining Group homogeneity

Over time, it can become difficult to maintain the homogeneity of the group in terms of operational practices, compliance levels, and member commitment. Some members may improve their performance while others may not keep pace, creating imbalances that complicate overall management.

The coordinator must be able to support members in difficulty, providing technical support and training, but must also be ready to exclude members from the group who are unable or unwilling to comply with the requirements, to avoid putting the entire certification at risk.

4. Costs of internal controls

The decree requires the coordinator to perform internal controls on group members to verify compliance with certification requirements. These controls represent a cost that must be borne by the group and must be adequately planned in the overall certification budget.

An ineffective internal control system increases the risk that non-conformities will emerge during the certification body’s audits that could have been prevented or corrected promptly.

How to establish a Group Certification: operational aspects

For operators interested in establishing or joining a group certification, it’s useful to understand the operational aspects of the process.

Preliminary analysis and design phase

Before formally initiating the certification process, an analysis phase is necessary to evaluate the feasibility of group certification. This phase includes identifying potential group members, verifying compliance with territorial requirements where applicable, assessing available competencies, and estimating expected costs and benefits.

It’s also important to identify the most appropriate organizational model among those provided by the decree for one’s sector, evaluating whether to establish an autonomous legal entity or opt for a contractually structured group.

Identification and formalization of the coordinator

Once the decision to proceed is made, the first operational step is the formal identification of the coordinator. If the choice is to establish a cooperative or a consortium, the procedures provided by civil law for the establishment of such entities must be followed.

In the case of a structured group, the entity that will assume the role of coordinator must be identified, and the economic and organizational terms of coordination must be defined.

Drafting contracts and procedures

The group must then proceed to draft the contracts between members and prepare the required written internal policies and procedures as required by the decree. This documentation must cover all relevant aspects: traceability, emission calculation, internal controls, non-conformity management, member obligations, and coordinator responsibilities.

It’s advisable to be assisted by consultants with specific experience in biofuel sustainability certification to ensure that the documentation is complete and compliant with the certification scheme requirements.

Submission of the Certification Application

Once the documentation is completed, the coordinator submits the certification application to a certification body accredited for the national scheme. The application must include the complete list of group members, contractual documentation, internal policies and procedures, and all information required by the body to assess the group’s compliance with the requirements.

The certification body then performs the initial verification, which includes examining the system documentation, auditing the coordinator, and auditing a sample of group members drawn according to the established criteria.

Issuance of the Certificate and ordinary management

In case of a successful outcome of the initial verification, the body issues the Group Certificate of Conformity, which authorizes all members to issue declarations of sustainability for the batches sold.

The ordinary management phase then begins, characterized by annual surveillance audits, internal controls by the coordinator, management of the possible entry of new members or exit of existing members, and continuous updating of the required documentation and records.

The objective of the Group Certification

Group certification, detailed in Article 14 of the DM of August 7, 2024 , is much more than administrative simplification: it is the key tool that the Italian legislator has adopted to make the energy transition inclusive and non-penalizing for the thousands of small operators who form the backbone of the agro-energy and forest supply chains.

By leveraging statistical sampling and centralizing management with a coordinator, this model breaks down economic and administrative barriers, ensuring that sustainability, traceability, and compliance with European criteria (RED II) are met efficiently. The correct structuring of the group, the careful choice of the coordinator, and the formalization of contractual relationships are critical elements that determine the success of the entire certification and continuous access to incentives.

For small operators, joining a group is not just a regulatory obligation, but a strategic decision that ensures:

• Economic Sustainability: drastic reduction of verification and management costs.
• Reliability and competence: centralized access to specialized technical know-how (e.g., GHG calculation).
• Contractual power: greater negotiation strength with final users.

In a rapidly evolving regulatory context towards RED III, the ability to operate in a certified and rigorously traced supply chain will become an indispensable distinguishing factor.

To understand in detail the scope of application and the specific requirements of the forest supply chain, whose fragmentation necessitated the introduction of group certification, we invite you to read our in-depth article:

Forest Biomass Certification: DM August 7, 2024 and MASE FAQ

Prometheus supports the establishment and management of Group Certifications

The structuring of a group certification requires multidisciplinary skills ranging from in-depth knowledge of sector-specific legislation to organizational management, from contract law to traceability system management.

Prometheus supports economic operators and organizations in the establishment and management of group certifications, offering complete support that includes feasibility assessment and choice of the most appropriate organizational model, identification and training of the coordinator, drafting of contracts between group members and internal policies and procedures, implementation of traceability and emission calculation systems, preparation of documentation for the certification body, assistance during initial and surveillance audits, and continuous training of group members.

Our team has specific experience in all types of group certification provided by the DM of August 7, 2024, and understands the operational specificities of each production sector.