Who gains from saving nature
Ledger 1 : 33 — For each dollar financing nature-based solutions in 2023, about $33 financed activities harmful to nature. (UNEP)
Cases / Carbon credits · European Union · 2016–2025

Used cooking oil and POME biofuel certification fraud (ISCC, EU/UK)

Nature's voice · report
No measurement of the harm done to me here is on record.
Did nature suffer? Not measured. Disputed
Not on record
  • The record does not name which of my species, waters, soils or forests were harmed.
What the record lacks: 3 none on record · 3 insufficient · 1 not measured · 3 disputed · 3 unclear See the gaps
Accounts of the harm differ
How much of the UCO imported into the EU is really mislabelled palm oil?
  • Communities and civil society Transport & Environment: About 80% of the UCO the EU imported in 2022 was suspected of being mislabelled palm oil; China supplied about 40% of EU supply. Hellenic Shipping News
  • Standard-setters and registries A sector estimate based on Commission data: About one third.
  • Government and regulators Regulators: Estimated that 1.8 million tonnes of POME with fake ISCC certificates entered the EU in 2023.

Fuel made from ‘waste’ oils counts double in the EU and the UK, and certificates from the ISCC scheme attest that the oil is waste. Estimates of how much imported used cooking oil is mislabelled palm oil range from about one third to about 80 per cent; no regulator finding has put a figure on it.

about 80% estimateShare of the EU's 2022 used-cooking-oil imports suspected of being mislabelled palm oil
Estimate by Transport & Environment, a suspicion estimate and not a regulator finding. An industry estimate based on Commission data put it at about one third.

Status As of 2025: EU committee discussion of suspending ISCC recognition ended with no Commission decision recorded; UK Department for Transport investigation into HVO under way with no outcome found.

What?
Palm-oil-derived material suspected of being sold as waste-based biofuel feedstock under ISCC certificates in the EU and the UK. Hellenic Shipping News
Where?
EU and UK markets; imports from China and other Asian suppliers; ISCC is based in Germany. Hellenic Shipping News
When?
2016 audit report; imports in 2022 and 2023; regulatory actions in 2023–2025.
Who?
Gained
  • Traders, exporters and fuel blenders — Waste-labelled oil sells above crude palm oil because waste-based biofuel counts double in the EU and the UK.
Lost
None on record
Harmed
None on record
Why?
Waste-based biofuel counts double in the EU and the UK, so UCO can sell above crude palm oil.
How?
Feedstock labelled as UCO or POME and certified by ISCC; T&E estimated that a large share of 2022 UCO imports may have been palm oil. Hellenic Shipping News
6 of 6 questions answered from the record

What happened

The record, in order.

In the EU and the UK, biofuel made from waste counts double compared with biofuel made from virgin vegetable oil, so used cooking oil (UCO) can sell for more than crude palm oil. Hydrotreated vegetable oil (HVO) is a diesel substitute made from vegetable and waste oils; palm oil mill effluent (POME) is the sludge from palm oil mills. The International Sustainability and Carbon Certification (ISCC) is a Germany-based voluntary scheme, recognised by the EU, that certifies feedstocks as ‘sustainable’ and ‘waste’.

Transport & Environment (T&E) estimated that about 80 per cent of the UCO the EU imported in 2022 was suspected of being mislabelled palm oil, and that China supplied about 40 per cent of EU supply. The figure was reported as an estimate; Hellenic Shipping News, reproducing it in December 2023, also gave Bulgaria's UCO imports as 96 per cent from China. A sector estimate based on Commission data put the share at about one third. Regulators estimated that 1.8 million tonnes of POME carrying fake ISCC certificates entered the EU in 2023. According to BBC data, as relayed by Forecourt Trader, Europe and the UK consumed about 2 million tonnes of POME in 2023 while world production was about 1 million tonnes a year.

ISCC audited Asian firms in 2023, revoked or suspended seven certificates and said it had found no evidence of crime. In 2025 Germany's Federal Agency for Agriculture and Food (BLE) doubted that a UAE-registered, Hong Kong-addressed HVO producer, whose ISCC certificate had been revoked, existed. In March 2025 an EU committee discussed suspending ISCC's recognition for waste-based fuels for two and a half years. ISCC said on 28 March 2025 that the proposal had no legal basis and would be a severe blow to the market; the Commission said no decision had been taken. In 2016 the European Court of Auditors had written that the Commission did not audit voluntary schemes, that small-membership governance raised conflict-of-interest risk and that schemes without procedures to verify the origin of waste had been recognised.

In September 2023 the US Department of Agriculture wrote that palm oil labelled as UCO might have entered Neste's Singapore refinery. Neste denied it, and the department acknowledged an error and withdrew the report. On 10 February 2025 the EU imposed definitive anti-dumping duties of 21.7 to 35.6 per cent on HVO and biodiesel from China, with a rate of 10 per cent recorded for EcoCeres and about 50 companies covered. The German oilseed association UFOP referred to ‘suspected fake imports’.

The UK Department for Transport opened an investigation into HVO after BBC reporting and whistleblowers' claims in 2025. ISCC had certified 92 per cent of renewable fuel in the UK. The outcome of the UK investigation was not found.

  1. 2016European Court of Auditors special report 18/2016 on voluntary schemes recognised by the Commission
  2. 2022EU imports of UCO that T&E later estimated to be about 80% suspected palm oil
  3. 2023ISCC audits Asian firms, revokes or suspends seven certificates; regulators estimate 1.8 Mt of fake ISCC-certified POME entered the EU; September: US Department of Agriculture report on Neste, later withdrawn
  4. 202510 February: EU anti-dumping duties on Chinese HVO and biodiesel. March: EU committee discusses suspending ISCC recognition; 28 March: ISCC responds. UK Department for Transport opens an HVO investigation. BLE doubts that a UAE-registered HVO producer exists

What was said

Claims, in the words of those who made them.

Where accounts differ

Each party's account, side by side, with its source. The record does not settle these points; it shows them.

How much of the UCO imported into the EU is really mislabelled palm oil?
Communities and civil society
Transport & Environment

About 80% of the UCO the EU imported in 2022 was suspected of being mislabelled palm oil; China supplied about 40% of EU supply.

Hellenic Shipping News
Standard-setters and registries
A sector estimate based on Commission data

About one third.

Government and regulators
Regulators

Estimated that 1.8 million tonnes of POME with fake ISCC certificates entered the EU in 2023.

Did the certification scheme police the chain adequately?
Standard-setters and registries
ISCC

Audited Asian firms, revoked or suspended seven certificates and found no evidence of crime; called a suspension of EU recognition legally baseless and a severe blow to the market.

Government and regulators
BLE (Germany)

Doubted that a UAE-registered, Hong Kong-addressed HVO producer, whose ISCC certificate had been revoked, existed.

International bodies
European Court of Auditors (2016)

The Commission did not audit voluntary schemes; small-membership governance raised conflict-of-interest risk; schemes without waste-origin verification were recognised.

Government and regulators
European Commission

No decision taken on suspending ISCC recognition (March 2025).

Did palm oil labelled as UCO enter Neste's Singapore refinery?
Government and regulators
US Department of Agriculture

Wrote in September 2023 that it might have; later acknowledged an error and withdrew the report.

Biofuels Digest
Company or project
Neste

Denied receiving fraudulent UCO volumes.

Biofuels Digest

How it looked

What was shown, beside what was recorded.

Shown

  • ‘Waste to fuel’ and ‘circular economy’
    As presented to the public (no single source named)

Recorded

  • T&E estimated about 80% of the UCO imported by the EU in 2022 was suspected mislabelled palm oil; China supplied about 40% of EU supply
    Hellenic Shipping News
  • Regulators estimated 1.8 Mt of fake ISCC-certified POME entered the EU in 2023
  • BBC data (as relayed by Forecourt Trader): about 2 Mt of POME consumed in Europe and the UK in 2023 against about 1 Mt of world production a year
    Forecourt Trader
  • ISCC revoked or suspended seven certificates after auditing Asian firms and said it found no evidence of crime
  • ISCC had certified 92% of renewable fuel in the UK; the UK Department for Transport opened an investigation
    Forecourt Trader
  • The US Department of Agriculture withdrew a September 2023 report on Neste after acknowledging an error
    Biofuels Digest

Who gained

Money that reached nature, beside money that stayed elsewhere.

Reached nature or the ground

Not published
No figure published.

Gained elsewhere

Not totalled
Currency: EUR · Window: . All figures cover the same period. * Estimate built from cited figures.

Responses on record

  • iscc (2023 and 28 March 2025): Audited Asian firms in 2023, revoked or suspended seven certificates and said it found no evidence of crime. On 28 March 2025 it said a suspension of its EU recognition had no legal basis and would be a severe blow to the market.
  • neste (September 2023): Denied that palm oil labelled as UCO entered its Singapore refinery. · Biofuels Digest
  • usda (September 2023): Acknowledged an error and withdrew its September 2023 report on Neste. · Biofuels Digest
  • european-commission (March 2025): Said no decision had been taken on suspending ISCC recognition.

In court and with insurers

Every proceeding and every insurer decision on record.

Lawsuits and rulings

  1. 2025-02-10Claimant won
    EU anti-dumping duties on HVO and biodiesel from China
    European Union · Regulatory · European Union → Chinese HVO and biodiesel producers (about 50 companies)

    Definitive duties of 21.7 to 35.6 per cent were imposed, with a rate of 10 per cent recorded for EcoCeres. The duties concern dumping; UFOP referred to suspected fake imports.

  2. Outcome not on record
    EU committee discussion on suspending ISCC recognition for waste-based fuels
    EU committee · Regulatory · European Union (committee) → ISCC

    In March 2025 a committee discussed suspending recognition for two and a half years. ISCC said there was no legal basis. The Commission said no decision had been taken. Whether recognition was suspended is not known.

  3. 2025–Ongoing
    UK Department for Transport investigation into HVO
    UK Department for Transport · Regulatory · UK Department for Transport → Not named

    Opened after BBC reporting and whistleblowers' claims of large-scale fraud involving HVO. No outcome found. Forecourt Trader

  4. 2025Outcome not on record
    German BLE doubts over a Hong Kong-addressed HVO producer
    BLE (Federal Agency for Agriculture and Food) · Administrative · BLE → A UAE-registered, Hong Kong-addressed HVO producer whose ISCC certificate was revoked

    BLE doubted that the producer existed. The remainder of the entry in the sources reviewed is cut off, so any measure imposed is not known.

Insurers

No insurer decision on record.

What nature saw

Outcomes measured on the ground, and nature's note.

Nature's report opens this page. Below: further outcomes measured on the ground.

Share of EU 2022 UCO imports suspected of being palm oil
about 80%
Estimate by Transport & Environment; an industry estimate based on Commission data said about one third
Fake ISCC-certified POME entering the EU
1.8 Mt
Regulators' estimate for 2023
Certificates revoked or suspended by ISCC
7
After audits of Asian firms, 2023; ISCC found no evidence of crime
ISCC share of UK renewable fuel certification
92%
Reported 2025 (Forecourt Trader)

What we don't know

Undisclosed, unproven, untried: recorded as data.
No court caseUnder standard-setter review

Nature

  • Not measured Harm to nature: The record holds no measurement of harm to nature.
  • Disputed How much of the UCO imported into the EU is really mislabelled palm oil?

Court

  • Unclear EU committee discussion on suspending ISCC recognition for waste-based fuels: outcome not on record.
  • Unclear German BLE doubts over a Hong Kong-addressed HVO producer: outcome not on record.

Figures

  • Insufficient China uco exports tonnes: Reported all-time high (S&P Global).

Accounts

  • Disputed Did the certification scheme police the chain adequately?
  • Disputed Did palm oil labelled as UCO enter Neste's Singapore refinery?

Record

  • Unclear Whether the EU suspended recognition of ISCC for waste-based fuels: not known from the record.
  • None on record The outcome of the EU investigation into Indonesian oil circulated through China and the UK: not known.
  • None on record The outcome of the UK Department for Transport's HVO investigation: not found.
  • None on record The 80% figure is a suspicion estimate for 2022 imports and not a regulator finding; a sector estimate based on Commission data gives about one third.
  • Insufficient Reported but not independently verified: China exported 2.951 million tonnes of UCO in 2024, an all-time high (S&P Global).
  • Insufficient Reported but not independently verified: the BBC data on POME consumption and world production, because the original BBC report could not be read.

Did the harm stop?

Not recorded as stopped. ISCC continued to issue certificates after revoking some, and the outcomes of the EU and UK reviews are unknown.

Who paid?

The record does not say who bore the cost. T&E's suspicion estimate concerns imports of palm oil labelled as waste, which would have received the double-counting advantage.

Sources

Voices on record: — Company or project— Government and regulators— Courts✓ Press and investigations— Communities and civil society— Researchers

Press and investigations

Connected cases

Related matters, and cases linked to this one through the same organisations, with the role each played in both.
Terms used on this page

Carbon and conservation finance

Standard-setter and registry
An organisation that writes the rules for carbon credits, approves projects, and records when credits are issued and retired. Such bodies typically charge fees per credit.
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