RED III Reporting Requirements for French Producers

How to Prepare for UDB Compliance and Digital Declarations in France

France is moving fast on RED III enforcement.

If you’re an ISCC-certified producer or trader supplying biofuels, biogas, or waste-based feedstocks into or within France, the rules have changed. What used to be a paper-based declaration is now expected to be digitally structured and ready for the Union Database (UDB).

And while the EU has made UDB mandatory for cross-border trade, France is among the few countries that expect digital alignment even for domestic compliance.

Here’s what you need to know to stay ahead.

What Is France Enforcing Under RED III?

The DGEC, under France’s Ministry for the Ecological Transition has adopted the RED III framework and expects producers to:

• Align their sustainability declarations with UDB-compatible formats
• Register all eligible transactions in digital systems (eventually, fully synced with the UDB)
• Maintain full batch-level traceability, even for domestic deliveries
• Provide auditable documentation tied to real GHG savings and chain-of-custody

This means that even if you’re not exporting, your SDs must now meet higher digital standards, both for traceability and for audit readiness.

What Are French Buyers Looking For?

Whether you’re supplying a fuel blender, distributor, or obligated party under the French quota system, your documentation needs to be:

Requirement	Expectation
Format	Aligned with ISCC EU templates (not custom Excel sheets or scanned PDFs)
Language	Often bilingual (French + English) to ensure smooth audits
Data depth	Must include GHG values, double-counting status, and full upstream traceability
References	Valid ISCC certificate numbers and matching batch IDs
Export-ready	If your buyer exports, your SD must work for UDB uploads too

Failure to meet these expectations can result in rejected shipments, delayed payments, or even audit red flags.

What Makes France Different?

Compared to other Member States, France:

• Audits suppliers more thoroughly through third-party verifiers
• Requires more localized documentation (including translations)
• Often expects pre-validation of SDs before delivery
• Uses stricter definitions of waste/residue status for double-counting

Even if you’re UCO, POME, or animal fat certified, expect closer scrutiny on how the material was collected, documented, and declared.

How to Stay Compliant in France Under RED III

To avoid friction with buyers, certifiers, or customs:

1. Standardize your SD templates using ISCC EU’s latest PoS/SD format
2. Pre-validate your documents against UDB fields (batch ID, GHG, country of origin, feedstock)
3. Track every shipment digitally, scanned PDFs are no longer enough
4. Use compliance software to structure, store, and retrieve SDs with audit trails
5. Prepare for French audits by maintaining bilingual documentation and linking each SD to its original certificate and supplier record

Are You Exporting from France?

If you’re exporting to Germany, Italy, or the Netherlands:

• You will initiate the UDB transaction through ISCC HUB, and your buyer will confirm it once the data aligns with their national system.
• You should issue UDB-ready declarations to avoid formatting issues
• GHG values must be traceable and linked to ISCC-verified batch data
• Double-counting claims (like UCO) must be properly documented and accepted by the receiving country’s national scheme

Final Thought

France is not just enforcing RED III, it’s shaping how digital sustainability reporting should work across the EU.

For ISCC-certified operators, this means moving beyond the basics. Your SD isn’t just a file. It’s a data object that enables trade, earns incentives, and proves your compliance in a RED III world.

Don’t wait for your buyer to ask for it. Start structuring it right, today.