- Changes from version 9.5E (8.1.2021) to version 10.1E (10.1.2022)
After more than 10 years of development work, the new version 10.1 of the EBC Guidelines was published on January 10, 2022. As always, the publication was preceded by a careful coordination process in which the various feedbacks were incorporated. We would like to thank all those involved for their various valuable suggestions and proposals.
In version 10.1, there are the following significant changes:
- Chapter 3: Introduction of certification classes
- Chapter 4: Permissible biomasses
- Chapter 5: Definition of batches and control dates
- Chapter 7.7: Introduction of WHC and electric conductivity of the solid biochar (chap. 7.9) as obligatory analyses, but BET is no longer obligatory
- Chapter 7.12: A long, enormously important chapter on PAHs, which puts the entire system on a firm and more comprehensible footing and makes it compliant with EU REACH.
- Chapter 10.3: The separation of impurities is no longer directly controlled by EBC, but outsourced to the actual feed certifiers.
All changes from version 9.5 to 10.1 can be found in the following document marked by Track Changes: Version 10.1 with Track Changes
- Changes from version 9.4E from 07/19/21 to version 9.5E from 08/01/2021
Biochar producers are increasingly packaging their products directly in their customers' packaging units, so that the products are traded and labeled under the name of the distributor and not under the name of the actual manufacturer. For this special case, Chapter 12.2.d was newly introduced and Chapter 12.2.c shortened:
12.2.d Traders of packaged goods under their own brands (non-mention of the manufacturer).
If the biochar and biochar-based products are manufactured, packaged, and labeled by the manufacturer for another company, and the name and contact information of the manufacturing company do not appear on the packaging, the retailer who is marketing the goods under its brand name must be EBC certified as an own-brand retailer. Otherwise, the own-brand retailer may not label the goods as EBC certified.
This also applies if closed packaged biochar goods are purchased from other manufacturers or distributors and then relabeled in such a way that the manufacturing company and its contact data are no longer recognizable as such. The company placing the goods under its own brand must necessarily be EBC certified. Otherwise, he may not label the goods as EBC-certified.
Provided there is no repackaging of the goods, EBC certification of own-brand retailers does not require on-site inspection; it can be done via online declaration and remote assessment.
- Changes from version 9.3E to version 9.4E from 07/19/2021
The only change from version 9.3 to 9.4 concerns the addition of the Swedish annex as chapter A5.
In the Summary of the EBC we added the following point:
6.3 Specifications, additional thresholds, or more stringent limit values that apply only to certain countries are regulated in the respective country annex.
In this context, the analysis and declaration of the silver content of the biochar for the application classes EBC feed and EBC Agro became obligatory. However, a limit value for this heavy metal was not introduced.
- Changes from version 9.2E to version 9.3E from 11/04/2021
For version 9.3E, the guidelines for EBC-Feed certification were updated. We suggest reading the entire chapter 9 to review the modifications.
The main and most important additions in this chapter are:
9.3 Magnetic separation
It is suggested to pass the feedstock or the biochar through a metal separator to prevent any metal impurities. However, if a diligent feedstock selection and control are guaranteed, the milling of the biochar to < 3mm (c.f. chapter 9.11) is considered sufficient to reduce the risk of metal impurities for the animals.
9.4 Pyrolysis temperature and intensity
Although contaminated feedstock is not allowed within EBC feed, trace contaminations e.g. with pharmaceuticals or mycotoxins, can never be excluded completely. To assure the pyrogenic degradation of these organic micropollutants the pyrolysis temperature has to reach at least 500 °C for at least 10 min (Ross et al., 2016).
9.11 Milling of the biochar to a particle size < 3 mm and packaging
To prevent any risk of choking or other digestive complications due to sharp impurities like glass, stones, or metals, the biochar has to be milled to a particle size below 3 mm before packaging, labeling, and trading the biochar under the EBC Feed label. After milling, the biochar has to be packed and sealed or at least tightly closed to avoid any post-production contamination of the feed product.
In chapter 2 the definition of the application class EBC-materials was specified to prevent its application to soil:
The EBC-Material Certificate guarantees sustainably produced biochar, which can be used in industrial materials such as building materials, plastics, electronics, or textiles without risk to the environment and users. However, they may not be used in agriculture or for other soil applications such as planting urban trees, remediating polluted areas or renaturalising industrial and mine sites.
EBC comment: The application class EBC material was created only for the application in inert materials. Not only the PAH but also the heavy metal limit values are significantly higher in the material class than for soil applications.
Although, different rules and limit values apply when planting urban trees compared to the use of substrates in agriculture, this must not result in a loophole for the application of inferior biochar qualities. However, rainwater in cities is often heavily contaminated with various pollutants such as PAHs and heavy metals, and biochar could significantly reduce this problem, even if the PAH limits of the biochar are higher than permitted for agricultural use. For these reasons, the EBC plans to introduce a new application class EBC-Urban for soil substrates in non-agricultural use by September 2021.
- Changes from version 9.1E to version 9.2E from 12/02/2020
Due to the changes of the EU limit values for heavy metals in organic farming, we had adjusted the limit values for EBC-AgroBio. However, this led to the fact that the limit values for EBC-AgroBio were partly lower than for EBC-Feed. This has now been corrected so that the limit values for EBC-Feed are never higher than for EBC-AgroBio, so that a feed-product could, in theory, be used as a biological soil conditioner.
Moreover, the limit values for the PCB and PCDD/F were written back again in chapter 6.11 as well as into the summarizing table of chapter A.
- Changes from version 9.0E to version 9.1E from 9/25/2020
The changes only affect chapter 11 regarding the EBC trademark law, since the trademarks are now registered and not just pending as in the previous version.
Chapter 11.1.3 was added:
11.1.3 Advertising with laboratory analysis according to EBC standard
If an analysis of the biochar has been carried out by an accredited laboratory (see list at https://www.european-biochar.org/en/ct/10) in accordance with the EBC standard, but no EBC certification was obtained, the lack of certification must be pointed out in a suitable form when advertising the analysis result. Misleading statements in this regard should be avoided in any case. Permissible are for example formulations like "laboratory analysis after EBC standard*", footnote: "not certified".
- Changes from version 8.2E to version 9.0E from 6/1/2020
The migration from version 8.2 to version 9 is the most important and comprehensive renewal of the EBC guidelines since their introduction. It is therefore recommended to read version 9 completely new.
All changes from version 8.2 to version 9 can be read with tracked changes in the following document:
- Changes from version 8.1E to version 8.2E from 4/19 2019
Changes from version 8.1E to version 8.2E from 4/19 2019
We added some precisions in regard to the certification of biochar based products
10.1 Exclusive use of EBC certified biochar
The risks associated with the use of non-certified biochar in agriculture, livestock farming and in products ultimately destined for agricultural use, such as compost or biogas slurry, are considered to be very high, since in this case pollutants such as PAHs, dioxins and heavy metals may enter the human food chain and accumulate permanently in soils and the environment.
Therefore, products made with biochar can only become EBC certified if the processing company uses exclusively EBC certified biochar for their biochar-based products. The certified company may not use, store or trade any biochar for agronomic purposes that is not EBC certified. Non-EBC certified biochar may be used by means of a written EBC exemption permit for industrial purposes such as in building materials and plastics or as charcoal for barbecue, provided that the spatial separation of certified biochar and the user protection are ensured. Without EBC exemption, no non-EBC certified biochar may be used, stored and traded by the certified company.
Only EBC-certified companies are entitled to use the EBC logo for the labeling of their products.
12. Control and Certification
The pure trade of ready packed and EBC certified biochar is subject to no further control and certification if correctly labeled by the certified manufacturer according to EBC regulations. Thus, if a non-certified company or individual markets EBC-certified biochar or biochar-based products, both the certified producer and the biochar batch must be clearly traceable. The certified manufacturer must therefore be named on the label or delivery note. If the original manufacturer is not mentioned on the packaging or on the delivery note, the company placing the goods on the market must inevitably be EBC-certified, otherwise he may not label the goods as EBC-certified.
- Changes from version 8.0E to version 8.1 from 4/4 2019
Changes from version 8.0E to version 8.1 from 4/4 2019
With the new version, only small changes or precision of version 8 have come into force.
Furthermore, an internet link or QR code must be printed on the label and the shipping note, via which the analytical values of the biochar contained in the product can be consulted. It does not necessarily have to be a copy of the official EBC analysis of the biochar producer. The inspector checks the conformity of the biochar analysis on the website and the supplier's EBC Eurofins analysis.
The pure trade of ready-packed and labeled biochar is not subject to any control and certification requirements. The trade with unpackaged, loose goods (for example containers) or underpackaging and repackaging as well as relabelling are subject to the control and certification obligation of processing companies.
- Changes from version 6.3E to version 8 from 1/1 2019
Changes from version 6.3E to version 8 from 1/1 2019
At the start of 2019, several essential modifications of the EBC standard occur. They concern in particular the chapters 10 and 11. In the new chapter 10, the guidelines for the certification of companies that process EBC-certified biochars are set. In the equally new chapter 11, the labeling requirements, the use of EBC certification logos are regulated. All further modifications are documented in the following passages. Additions are highlighted in red, comments are set in italics:
3.5 Biochar may only be produced from forestry wood if appropriate standards, laws or certificates (e.g. PEFC or FSC) can prove sustainable forest management.
3.6 Only biomass that was grown in Europe is allowed as feedstocks for the production of biochar.
3.6 Feedstocks used for the production of biochar must not be transported over distances greater than 80 km. An exception is made for pyrolysis additives or special biomasses for use in production tests. [Since the current network of pyrolysis facilities is not yet extensive an exemption to this transport distance requirement can be granted as long as such exemption is only a temporary measure.]
Comment: In principle, we still believe that biomass transport over long distances should be avoided and that biochar should be produced as decentrally as possible. Despite the steady development of biochar production in Europe, however, limiting the transport distance is currently not practicable. For this reason, the guideline point 3.6 is replaced by the requirement that the biomass for the production of biochar be of European origin. This is to prevent biomass production from being relocated to developing countries or countries with low regulatory environmental targets (such as the US), as can be seen in the highly problematic wood pellet trading.
5.10 The monthly sample bags (3 kg) have to be stored for at least three years at a protected and dry location.
It is not the task and purpose of the EBC certificate to provide a complete physico-chemical characterization of biochar. The costs of analyses for such a characterization would go beyond economically reasonable limits. Rather, it is crucial for the EBC certificate to guarantee compliance with all environmentally relevant limit values and to declare all product characteristics relevant to agricultural practice.
The permissible test methods as well as the analytical methods for the individual parameters are detailed in Chapter 13.
Comment: The permissible test methods are only mentioned and described in Chapter 13 and therefore no longer mentioned in Chapter 6.
7.1 Biomass pyrolysis must be operated in an energy-efficient manner in an energy-autonomous process.
The external energy used for operating the reactor (electricity for power drive systems, ventilation and automatic control systems, fuel for preheating, etc.) must not exceed 8% (basic grade) or 4% (premium grade) of the calorific value of the biomass pyrolysed in the same period. With the exception of the preheating of the pyrolysis reactor, the use of fossil fuels for heating the pyrolysis reactor is prohibited. The use of waste heat from other industrial processes, such as bio-digesters or cement production or the use of solar thermal energy is permitted. If the pyrolysis reactor is electrically heated, the use of renewable energy sources or the use of surplus electricity must be proven.
7.2 The pyrolysis gases produced during pyrolysis must be recovered or burned. They are not allowed to escape into the atmosphere.
[...] However, if pyrolysis gases are trapped and are cleanly burned or used as bio-oil for the chemical industry, the environmental impact is neutral and even improved compared to biomass burning or natural decomposing. The EBC certificate guarantees that only biochar production technology is used that does not release unburned pyrolysis gases to the atmosphere.
7.4 The heat produced by the pyrolysis process must be used
35 to 60 % of the energy contained in the biomass feedstock is eventually contained in the pyrolysis gas. Part of the energy released during the combustion of these gases is usually used to heat the biomass for pyrolysis. However, high amounts of waste heat remain. At least 70% of this waste heat must be used, e.g. for drying biomass, for distant heating, for generating electricity or for similar sustainable purposes. Bio-oil and pyrolysis gases can also be stored for later material and/or energetic uses.
Comment: Pyrolysis technology has evolved significantly in recent years. The research and development of pyrolysis are increasingly oriented towards solutions that convert almost all of the biomass-carbon into a usable and/or sequesterable form. However, if the pyrolysis gases are processed into chemical raw materials and fuels, they are no longer available for heating the pyrolysis reactors. In that case, the heat for the pyrolysis reactors can be provided by renewable electricity (so-called E-pyrolysis). In order to take these new developments into account, the limitation on the use of external energy is removed. The ban on using fossil fuels to heat reactors remains. Added to this is the requirement that, when the reactor is electrically heated, the electricity must come from renewable sources (solar, wind).
8.2 All workers must be informed in writing about possible risks and dangers of and around the production facility and sign the document. In particular, this concerns the self-ignitability of char dust, respiratory protection, contact with bio-oil and tars and possible gas leakage.
10. Certification of biochar-based products and biochar processing companies
Comment: So far, the EBC has only certified the production of biochar. This, however, meant that companies that purchased certified biochar as raw material for new products could not qualify for EBC certification, as no control was set for the processing procedures. With the rapidly growing market for biochar based products, there was an urgent need to fill this gap. From now on, products containing EBC certified biochar can become EBC certified. It should be noted, in particular, that a manufacturer of biochar-based products can only become EBC-certified if all processed biochar is EBC-certified. The chapter regulates the incoming goods inspection, storage, and processing (keeping of processing journals).
For the exact wording of the new chapter 10, please consult the guidelines.
11. Labeling requirements, EBC logos, and sales
Comment: Also newly regulated is the labeling of EBC biochar and biochar based products. This serves better information of the customers as well as any control authorities. Moreover, it sets the standard for transparent product information. The aim of this standardization is not at least to prevent non-certified companies from making unclear product information at the expense of EBC producers.
An important addition is that an internet link or QR code must be printed on the label and the shipping label, via which the EBC-certified analysis of the corresponding batch can be viewed and downloaded.
12. Control and certification
[...] If a biochar producer desires to become EBC certified, their entire biochar production site must be controlled and certified, regardless of whether only one batch, several or all batches qualify for one of the EBC certificates. Biochar from non-EBC certified batches may not be sold for agriculture or livestock uses.
For small biochar-processing companies, a small-scale producer regulation may also apply. If less than 10 tons of biochar are processed into biochar-based products per year, these establishments are exempt from the annual on-site inspection. Compliance with the production and quality guidelines is evaluated by the government accredited inspection body using self-declaration and processing protocols.
- Changes from version 6.2E to version 6.3E from 14th August 2017
Changes from version 6.2E to version 6.3E from 14th August 2017
added to chapter 4 page 8
Sending the biochar sample to the accredited laboratory:
4.1 The biochar samples have to be sent within the first three days after the start of a batch to the accredited laboratory. As long as it can be guaranteed that the same biomass feedstock and the same process parameters are used, the biochar sample can be sent up to three weeks before the start of a batch. 4.2 When sending the biochar sample to the EBC accredited laboratory, the batch number of the sample has to be transmitted to the lab. 4.3 The accredited laboratory has to be informed that the sent sample should be considered as a sample to obtain the EBC certification. 4.4 The accredited lab will then send a copy of the results of the analyses to the accredited controlling organism as well as to the EBC. 4.5 The EBC has the right to use the analytical results anonymized for statistical analyses.
added to chapter 5 page 9-10:
5.9 Alternatively, an automated incremental cross-stream sample of 100 g could be taken every 30 min for at least 24 hours. Such an automated incremental cross-stream sample could replace the above-described sampling method.
5.10 Random Sampling
At each control visit, the controller takes a random sample of the biomass feedstock and the resulting biochar, seals both sample bags and lets the producer send them to the EBC.
5.11 Retention Sample
In addition to the EBC-analysis sample and random sample, the producers are obliged to take daily an incremental cross-stream sample of at minimum 100g. The time of the daily sample has to be marked in the production protocol. The daily cross-stream samples have to be collected in a monthly sample bag or case. After one month the sample bag has to be sealed and dated. The next 30 cross-stream samples will be collected in a new monthly bag or case. The incremental cross-stream sample can be taken manually or implemented as e.g. presented in Gy (2004). The incremental cross-stream sampling guarantees the most representative sampling of the product.
added to chapter 10 page 21:
Manufactures producing more than 50 t biochar per year are not considered as artisan producers which is independent of the fact if they want to certify only a portion < 50 t of their total production. If e.g. a manufacturer produces 200 t of biochar per year and want to certify only one batch of e.g. 40 t, a yearly on-site inspection by the accredited controlling body becomes obligatory.
- Changes from version 6.1 to version 6.2 from 4th February 2016
Changes from version 6.1 to version 6.2 from 4th February 2016
The annual biochar production limit for small scale producers was increased from 20 t to 50 t. In order to be reasonably proportional to the risk assessment and to the environmental protection goals, producers with annual production capacity below 50 t of biochar are exempt from on-site inspection of production. The compliance with production requirements is controlled by the accredited quality assurance agency via self-declaration and a detailed description of the complete production process. The requirements for biochar batch analyses, thresholds, feedstock sustainability and handling of biochar maintain the same as for industrial producers.
PAH analytical method DIN CEN/TS 16181 (soxhlet-extraction with toluol, to be analyzed with GC-MS or HPLC) was added to 6.8
The threshold for Arsen at As < 13 g t-1 DM was introduced.
- Changes from version 6 to version 6.1 from 19th June 2015
Changes from version 6 to version 6.1 from 19th June 2015
The main modifications concern the general requirements for biochar production records listed in chapter 4 which were adapted for the inclusion of small scale production. The terminology of "biochar production batch" was changed to "biochar production series" because in batch pyrolysis systems several batches may constitute one productions series. This is especially relevant for small scale production systems that are mostly batch systems.
[Modification in chapter 4:]
Each biochar series must be clearly labeled and be given a unique identification number for reconstructing the circumstances of production and guaranteeing the quality of the biomasses used. For each biochar series, separate production records are to be kept. Each series must be tested to ensure compliance with the required threshold values.
A uniform biochar series is deemed to exist when the following criteria are met:
- The pyrolysis temperature in °C does not fluctuate more than 20%. Interruption of the production is allowed as far as the production parameters keep the same after the resumption of production. For small-scale production with a yearly production below 20 t of biochar the continuous recording of production temperatures is not requested.
- The composition of the pyrolysed biomasses does not fluctuate more than 15% based on the type of feedstock listed in the feedstock positive list.
- Changes from version 5 to version 6 from 21st March 2015
Changes from version 5 to version 6 from 21st March 2015
The main modification concerns the inclusion of small scale producers with less than 20 tons annual biochar production. In order to be reasonably proportional to the risk assessment and to the environmental protection goals, producers with annual production capacity below 20 t of biochar are exempt from on-site inspection of production. The compliance with production requirements is controlled by the accredited quality assurance agency via self-declaration and a detailed description of the complete production process. The requirements for biochar batch analyses, thresholds, feedstock sustainability and handling of biochar maintain the same as for industrial producers.
[Modification in chapter 5.3:]
5.1 15 subsamples of 1.5 liters each have than to be arbitrarily gathered from different spots of the homogenized biochar lot (ISO (2006) or Bunge & Bunge (1999)). For small scale production of fewer than 200 liters per day the subsample size may be reduced to 0.5 liters.
[Modification in chapter 6.1:]
6.1 The biochar's carbon content must be higher than 50% of the dry mass (DM). Pyrolysed organic matter with carbon content lower than 50% are classified as Bio-Carbon-Minerals” (BCM). Pyrogenic Carbonaceous Material (PCM).
[Modification in chapter 6.3:]
6.3 The molar O/Corg ratio must be less than 0.4
In addition to the H/Corg ratio, the O/Corg ratio is also relevant for characterizing biochar and differentiating it from other carbonization products (Schimmelpfennig and Glaser, 2012). Compared to the H/Corg ratio, direct measuring of the O content is relatively expensive and not standardized. Therefore the calculation of the O content from C, H, B, S and ash content is accepted.
Permitted test methods: DIN 51733, ISO 17247
(Specify for each batch)
[Addition in chapter 6.4:]
(Specify for each batch for producers of more than 200 t biochar or PCM per year)
[Addition in chapter 6.9:]
(Specify for each production unit for producers of more than 200 t biochar or PCM per year)
[Addition in chapter 7.2:]
Most of the global charcoal and biochar production is still done using obsolete technology (Brown et al., 2015) where most of the original feedstock carbon is released as toxic emissions to the atmosphere. Even though the quality of biochar produced in such kilns may meet EBC requirements, the environmental impact of such production techniques is highly negative.
If pyrolysis gases are trapped and used as fuel and bio-oil or are cleanly burned the environmental impact is neutral or even improved compared to biomass burning or natural decomposing. Under the EBC biochar production technology that releases unburned pyrolysis gases are not permitted.
[Addition in chapter 7.4:]
Although it is highly recommended, small-scale biochar production units with an annual output of fewer than 20 tons are exempt from the heat recovery.
[Addition in chapter 9:]
In order to be reasonably proportional to the risk assessment and to the environmental protection goals, producers with annual production capacity below 20 t of biochar are exempt from on-site inspection of production. The compliance with production requirements is controlled by the accredited quality assurance agency via self-declaration and a detailed description of the complete production process. The requirements for biochar batch analyses, thresholds, feedstock sustainability and handling of biochar maintain the same as for industrial producers.
- Changes before 2015
Changes before 2015