ISCC in Italy: Guide to Exports, Declarations & GSE Compliance

You’re an ISCC-certified trader or producer operating in Italy.

You know how to generate your Sustainability Declarations (SDs), your suppliers are on board, and your documentation is in order.

But now you’re preparing an export, and the buyer asks if your SDs are ready for the Union Database (UDB), or worse, if you’ve uploaded anything into Germany’s Nabisy.

Wait: Italy has no national sustainability database. So how are you supposed to comply?

Here’s the answer. Italy’s system works differently, but it’s fully compatible with ISCC. And your exports to Germany, France, the Netherlands, or any other EU country depend on how well your documentation and processes align.

Let’s break it down.

How Italy Handles Sustainability Declarations

Unlike Germany (Nabisy) or EU-wide UDB workflows, Italy does not operate a centralized digital registry for sustainability proofs.

Instead, compliance runs through two main authorities:

• GSE (Gestore dei Servizi Energetici) – oversees sustainability declarations and incentive eligibility (CICs, biofuel quotas)
• ADM (Agenzia delle Dogane e dei Monopoli) – customs authority that reviews sustainability documentation for import and export formalities

Italian ISCC-certified operators issue Sustainability Declarations (SDs) manually or using Excel/PDF templates that follow ISCC EU system documents. These must include:

• Batch ID and material
• Country of origin
• GHG value and emission savings
• Certification scheme and validity
• Quantity and double-counting status (if applicable)

These SDs are provided to GSE for national incentive verification or to ADM during customs clearance, depending on the transaction path.

What Happens When You Export from Italy

If You’re Exporting to a UDB Country (France, Netherlands, Spain, etc.)

For the UDB leg of your transaction, you won’t use GSE.
Instead, you must ensure that:

• Your ISCC EU SDs are correctly formatted and complete
• Your site and batches are registered on ISCC HUB
• You, as the seller, initiate the transaction in the Union Database via ISCC HUB
• Your buyer then reviews and confirms the record in UDB

Your declaration does not go directly into the UDB as a PDF upload. The UDB record mirrors the data from your ISCC SD, including GHG values, country of origin, and batch-level traceability through ISCC HUB.

Tools like Carboledger help automate this formatting, flag errors, and track supplier compliance, making your UDB exports much smoother.

If You’re Exporting to Germany (Nabisy System)

This is where many Italian suppliers get confused.

Germany runs Nabisy, the BLE-managed national database where Proofs of Sustainability (PoS) must be generated within the BLE portal.

As an Italian exporter, you don’t have Nabisy access.

Here’s what happens:

• You issue an ISCC EU-compliant SD and send it to your German buyer.
• The German buyer, certified under ISCC DE or REDcert DE, creates the Nabisy PoS in their system using your SD data.

As long as your SD is clear, aligned, and traceable, BLE accepts the PoS on their side.

Summary Table: Italy vs. Common EU Export Destinations

Country	System Used	What Italy Must Provide
Germany	Nabisy (BLE)	ISCC SD → German buyer issues Nabisy PoS
France	UDB	ISCC SD → Seller initiates via ISCC HUB → Buyer confirms in UDB
Netherlands	UDB + REV (NEa)	ISCC SD → Seller initiates via HUB → Buyer confirms UDB entry; REV manages national HBEs
Spain	UDB	ISCC SD → Seller initiates UDB transaction via HUB → Buyer confirms

Best Practices for Italian ISCC Operators

• Prepare SDs in standardized, batch-level formats with complete GHG data and traceability fields.
• Register your site on ISCC HUB early if you plan to export to UDB countries.
• Coordinate with buyers to confirm submission workflows (UDB vs. Nabisy).
• Provide SDs and supporting documents to ADM when required for customs verification.
• Submit SDs to GSE only for national incentive programs (e.g., CICs) — not for UDB exports.
• Keep all certificates and declarations audit-ready for ISCC, GSE, ADM, or foreign regulators.

Final Thought

Italy may not have a centralized PoS database, but that doesn’t mean you’re behind.

Whether you’re exporting to Germany, France, or the Netherlands, ISCC EU certification combined with clear, structured documentation is your passport to compliance.

By understanding how your Sustainability Declarations connect, directly through ISCC HUB for the Union Database or indirectly through buyer-side systems like Nabisy, you can stay audit-ready, avoid delays, and open certified markets across Europe.